A company may choose one  or several of several methods on how to include bribery prohibition provisions into contracts with subcontractors or suppliers: 

  • To include the provisions into a contract with subcontractors/ suppliers; 
  • To enclose an annex to a contract, which shall describe the  ethics provisions of the company, and this annex shall be an integral part of the contract to be signed together with the contract. 


Template – TEO LT, AB Supplier Code of Conduct[106]



1. TEO LT, AB (hereinafter – Teo or the Company) is a leading provider of telecommunication services and a vital part of the social and economic infrastructure in the markets where the Company operates. We provide services that help people and companies communicate in a simple and effective way, when and where needed. Our values: “Dare, Care and Simplify” form the foundation of our everyday work.

2. Our aim is to become a world-class service company that provides high quality networks and services. Whereas Teo is a signatory member of the UN Global Compact and committed to the OECD Guidelines for Multinational Enterprises. Therefore, we have adopted this Supplier Code of Conduct in order to ensure  that we and our suppliers are aware of our expectations and approach to sustainability.

3. The provisions of this Supplier Code of Conduct are in line with the provisions of the Code of Ethics and Conduct of Teo Group of Companies  that are based on international agreements (the UN Universal Declaration of Human Rights, International Labour Organisation Conventions, UN Convention against Corruption and the Rio Declaration on Environment and Development).

4. All companies of Teo Group and their employees must follow the Group Code of Ethics and Conduct. Similarly, all Teo Suppliers must follow the requirements of the Supplier Code of Conduct even in such cases, where  the latter establish higher requirements than those set by national laws or regulations.

5. This Supplier Code of Conduct applies to all companies providing products and/or services to any Teo Group company. The Code applies to all the employees and consultants of Suppliers and  sub-contractors, regardless whether they are permanently employed, temporarily contracted, directly employed or supervised from otherwhere.

6. Where appropriate or if necessary, Teo may conclude individual contracts with suppliers and to establish additional special requirements therein.  In contracting with subcontractors, it should always be established that the Supplier Code of Conduct will apply.

7. The Suppliers should have such a process in place in their company, which would allow to verify the compliance with the requirements of the Supplier Code of Conduct. Upon request, they should participate in a self-assessment process organized by Teo. Teo has the right to audit how the Suppliers and sub-contractors fulfil the requirements laid down in the Supplier Code of Conduct or those equal to them . Having identified any  non-compliance with the Supplier Code of Conduct, in all cases, the Suppliers must submit a corrective action plan to be approved by Teo.

8. The Suppliers must follow the amendments, modifications and updates to the Supplier Code of Conduct, which Teo will publish on the website:



9. Human Rights

9.1. All employees hired  by a Supplier or its sub-contractors, regardless whether they are employed under permanent or temporary employment contracts, must be treated with respect, without prejudice to their  dignity and be  all guaranteed the fundamental human rights. The Supplier shall  ensure that all employees working for it directly or indirectly know and understand these rights.

9.2. The freedom of expression and the privacy of employees, clients and other stakeholders must be particularly respected by the Supplier.

9.3. The Supplier must promote diversity. Any form of discrimination is prohibited, and, in particular, on the  grounds  of ethnicity, gender, sexual orientation, marital or social status,  paternity or maternity, religion, political attitudes, nationality, disability, age or union affiliation.

9.4. No person shall be employed by the Supplier who is younger than  the minimum legal working age. It is strictly prohibited both for suppliers themselves and their sub-contractors directly and in cases, where they use the services of temporary staffing agencies, to use children or juveniles who are under the minimum legal working age or those who are under fifteen (15) years old, i.e. in all cases the higher minimum age limit shall apply. Employees under eighteen (18) years of age shall not be assigned to work neither in night shifts, nor to do dangerous or hard work.

9.5. The Suppliers that provide Teo with products, which contain tin, tungsten, tantalite and/or gold,   must have a clear policy for the use of all contentious minerals and  ensuring  their traceability in place.

10. Rights at Work

10.1. All employees hired by a Supplier or its sub-contractors, regardless whether they are employed under permanent or temporary employment contracts, must have  written contracts made in the language understandable to them, which would  contain: the working hours (per day and week), conditions of overtime compensation, duration of a notice period, salary and frequency of its payment.

10.2. A normal working week shall not exceed 48 hours.  The overtime shall be organised only upon consent of employees  and it may not exceed 12 hours per week, unless otherwise provided in collective  agreements. The employees shall be entitled to at least one day off in every seven-day period.

10.3. The salary and its payment conditions  must be fair and must meet the basic requirements, the expression of which might be equal to a minimum wage established by national laws, including premiums and allowances. Overtime pay rates shall be premium to regular wages.

10.4. The employees must be  informed about their employment conditions in their own language. It is necessary to ensure that they  fully understand these conditions. The Suppliers must  encourage the employees to use grievance mechanisms, i.e. to have an opportunity  to voice their concerns without fear of punishment or retribution.

10.5. The Suppliers and subcontractors must have job  descriptions, including documented dangerous works. Such descriptions must be  updated on a regular basis, and  all employees and consultants should be familiarised with them. All employees should have access to basic amenities such as, for example, drinking water, toilets and adequate rest facilities or dorms that should be clean, safe and fit for purpose.

10.6. Any forms of forced labour are strictly prohibited. The  employees shall also not be required to lodge deposits or original identity papers or their equivalent documents. The employees must be allowed to move freely and have the possibility to leave the working premises after  the working hours.

10.7. Nobody shall be subject to physical punishment, unlawful detentions, physical, sexual, psychological or verbal harassment or abuse. Deductions from wages as a disciplinary measure are prohibited.

10.8. All employees shall be free to form and to join (or not to join) trade unions or similar employee representative organisations and to negotiate on the conclusion of the collective agreement.

11. Occupational Health and Safety at Work

11.1. Construction,  technical maintenance, repair and network roll-out services, which include works in enclosed or confined spaces, overhead works/ lifting operations, ground and civil construction works, works with radio frequencies; electrical assembly works; works at height; driving (where it is an integral part of the work), must l comply with the OHSAS 18001 or equivalent standard requirements.  If that is not the case,  the Suppliers  must provide Teo with a plan for the implementation of  an appropriate standard.

11.2. The Supplier’s working environment must have acceptable working conditions, which would  be safe and healthy  both in terms of physical and psychosocial health. Training and appropriate health and safety information on occupational health and safety at work should be provided to employees, including but not limited to,  fire safety, proper handling of chemicals and use of equipment, standby for emergency  and first aid situations.

11.3. In order to limit the built-in causes of hazards in working environment, the Suppliers must take adequate actions, which would allow not only reduction of the number of  accidents and injuries as well as psychosocial illnesses, but also prevention against them. The Suppliers must free of charge  provide their employees with the proper personal safety devices. Incidents, which affect physical health of the person, accidents at work  and psychosocial illnesses must be documented and reported to the Supplier’s top management.



12. All forms of corruption, including but not limited to, extortion, bribery, facilitation payments, favouritism, fraud and money laundering, are strictly prohibited.

13. Nobody may , ask for, give or accept, directly or indirectly, any personal payment, gift1 or gain benefit in exchange for favourable treatment intended to influence a business transaction or to obtain a business or personal advantage. This provision applies both to Teo employees and their families,  and to the Suppliers and their sub-contractors.

14. Teo employees are strictly prohibited to accept or give any types of gifts during the procurement process or during communication with civil servants. Moreover, it is also strictly prohibited for Teo employees to publicise  themselves  in any advertising or promotional materials of the  Supplier products or services.

15. Employees of Teo Procurement Unit may  accept and give gifts only on behalf of Teo and only in such cases, where the gifts are given and accepted for the clear business purpose , are suitable in terms of the nature of the business relationship,  and where their value does not exceed the limit of the established value. All events must be directly related to business. All gifts must be registered with the gift register and they  are the ownership of Teo.

16. Fair competition and open market principles  must be respected. The business decisions shall not be motivated or affected by any personal relations or interests.

17. An anti-corruption programme in compliance with internationally recognized standards must be adopted and implemented, which shall be transparent and effectively supported by arranging adequate training and providing relevant information for the above purposes. 



18. The Supplier shall have a system for environmental management, including environmental objectives and their evaluation, which would meet the requirements of, for example,  ISO14001 standard or equivalent to it. The Supplier must reduce the negative impact of its economic activities on the environment. Moreover, the Supplier must apply a precautionary approach and strive for maintaining and increasing biodiversity.

19. The Supplier must prioritize energy generated from renewable energy sources and limit water consumption, in particular,  in poor regions.

20. The Supplier should have monitoring processes of emissions, effluents, pollutions and waste management, including electronic waste, in place. All waste should be properly managed or recycled in a traceable manner.

21. The Supplier must strive for reduction of the environmental impact of  road, sea or railway transportation, whenever possible. Fuel-efficient vehicles shall be prioritized when transporting goods and providing services to Teo.

22. The Supplier must evaluate any cases of use of chemicals and substances on a regular basis and investigate whether there is a possibility to replace them with less hazardous alternatives. Chemicals should be handled and disposed in a safe and  adequate manner, thus ensuring that  the environmental negative consequences are minimized. The chemicals used by the Supplier must be documented.

23. Neither the Suppliers, nor their  sub-contractors may use hazardous substances on Teo‘s Black List (Appendix No. 1). The Suppliers and their sub-contractors should seek to avoid all substances on Teo‘s Grey List (Appendix No. 2). If currently the use of such substances is necessary, a written plan for their replacement with alternatives should be adopted.

24. Suppliers’ innovative developments of products and services that offer environmental and public benefits, for example,  eco-design, are strongly promoted.

25. In the architecture and location of antennas, towers and masts,  electromagnetic waves, noise, view disturbances, ownership rights, accessibility, environmental impact and public health and safety should be taken into consideration.



26. In conclusion of contracts with subcontractors, the requirement to comply with the Supplier Code of Conduct must  be stipulated. Upon request,  the Supplier must participate in a self-assessment process organized by Teo. Teo has the right to check how the Suppliers and their sub-contractors comply with the Supplier Code of Conduct and the requirements related to it in the  current, planned and former places of economic activities.

27. The Supplier shall, upon request, provide data and information required for the preparation of  Teo‘s annual report and other reports.

28. Any material breach of the requirements set out in this Supplier Code of Conduct gives Teo the right to immediately terminate any or all agreements with the Supplier.

29. The Supplier shall inform Teo if it discovers a breach, or a suspected breach of the Supplier Code of Conduct. This will not be used against the Supplier or sub-contractor if the notification on the breach was provided acting in good faith. If the employees  themselves observe the activities, which would mean the breach of  the Supplier Code of Conduct, and they would be notified of such activities or if they suspect the existence of such activities, they should report the information  by e-mailing:


Footnotes, explanations:

[1] A gift means any valuable thing, including but not limited to, events, products, services, meals, lodging, cash, discounts, prizes, transport, holidays and membership. 



[106] TEO LT, AB Supplier Code of Conduct. Link: