CODE OF BUSINESS CONDUCT
From the Desk of the CEO
Dear Team Nemiroff and Business Partners.
It is my honor and privilege to introduce our Code of Business Conduct, a foundational document that embodies the values, ethics, and principles we hold dear as a company. This code is more than just a set of rules—it’s a testament to our commitment to excellence, integrity, and responsibility in all our endeavors.
At Nemiroff, we believe that true success extends beyond the bottom line. Our journey has taught us that the best business practices are rooted in respect, transparency, and a deep sense of accountability to our employees, customers, partners, and the communities we serve. We have developed this Code of Business Conduct by adopting the best practices and policies worldwide, ensuring we operate with the highest ethical standards in everything we do.
Embracing Excellence and Integrity
Our Code of Business Conduct reflects our unwavering commitment to excellence. Every bottle of Nemiroff Vodka that reaches our customers should embody our dedication to quality, safety, and innovation.
Integrity, a cornerstone of our values, means conducting business honestly, fairly, and ethically. We strive to build trust with our stakeholders through openness and transparency.
Our Sustainable Growth Commitment
As we look to the future, we recognize that environmental, social, and governance (ESG) factors are vital to sustainable growth and success.
We commit to making a positive impact on the world around us, understanding that our responsibility extends far beyond the walls of our facilities. By integrating ESG principles into our business strategy, we ensure that Nemiroff Vodka Co remains a responsible and forward-thinking leader in the industry.
A Collective Effort
This Code is not the responsibility of a few; it belongs to all of us. Each member of Team Nemiroff is integral to upholding these standards and driving our success. Together, we will continue to build a culture that reflects our values, inspires trust, and encourages growth.
Let us stand united in our mission to craft exceptional products and positively impact our communities and the world. I am excited about the journey ahead and the opportunities it holds for each of us.
OUR VISION 2028
Our Vision is to become a globally recognized Top-3 player among international vodka brands with undisputable leadership in our home market. We offer vodka and vodka-based products of exceptional quality and craftsmanship made from natural ingredients on a global scale while promoting the indomitable spirit of Ukraine. Driven by consumer-centric marketing, continuous innovation and collaboration with best-in-class partners, we create an authentic and empowering drinking experience. At the heart of our success are dedicated and talented Nemiroff’s employees, who embody our values of passion, expertise, and integrity.
We relentlessly pursue profit growth to create long-term value for our stakeholders and business at large.
Our values
- 01
Our Commitment to Challenge
Challenge is our catalyst for personal and professional evolution, fostering an environment where learning from setbacks is as vital as celebrating triumphs. We thrive on the complexities that others might shy away from, seeing them as gateways to innovation and advancement. Our culture is one of audacity and unwavering determination. We inspire and empower our team to view challenges not as obstacles, but as stepping stones towards experimentation, iteration, and progress as a result.
- 02
Inspiring Excellence: Leadership
Our leadership is rooted in integrity and accountability. We lead by example, setting the highest standards for ourselves and our teams. We recognize that true leadership is built on a foundation of trust, transparency, and ethical conduct. Innovation is at the heart of our leadership philosophy. We empower our leaders to envision the future and guide our teams towards it. We embrace change, cultivate creativity, and foster an environment where calculated risks are taken in pursuit of transformative breakthroughs. At Nemiroff leadership is not confined to a title; it’s an embodiment of values that guides us towards excellence.
- 03
Pioneering Performance: Our Commitment to Efficiency
At Nemiroff efficiency is our guiding principle. We embrace innovation, demand accountability, and harness the power of time to exceed expectations. Through our dedication to efficiency we pioneer performance and set the benchmark for excellence in everything we do. We are dedicated to optimizing processes, maximizing resources, and delivering exceptional results with precision and speed.
- 04
Elevating Impact: Responsible Partnership
Our partnership is founded on transparency and shared values. We believe in open and honest communication, ensuring that our collaborations are built on a strong foundation of trust and integrity. Our partnerships are aligned with ethical considerations, valuing social responsibility as an essential aspect of shared success. We engage with communities, supporting initiatives that uplift society and empower individuals. Through our collaborations we aim to leave a legacy of progress and transformation that extends far beyond our immediate goals.
- 05
Unleashing Excellence: Our Dedication to Continuous Improvement
At Nemiroff continuous improvement is not a mere aspiration; it’s our way of life. We innovate, we learn, and we grow — always striving to unleash excellence in every endeavor. Through our dedication to continuous improvement we shape a future defined by progress and achievement. Our culture thrives on a relentless pursuit of betterment. We believe that by constantly seeking innovative solutions, refining processes, and learning from every experience, we can stay at the forefront of our industry. Nemiroff encourages our teams to challenge the status quo, to think creatively, and to experiment fearlessly.
- 06
Sustainability
Responsible stewardship of resources guides our philosophy. We recognize the impact of our actions and prioritize sustainable practices that preserve natural resources and minimize environmental footprint. Our culture is rooted in a deep respect for the environment. We believe that our success is intrinsically linked to the health of the ecosystems we operate within. We aim to create a legacy of sustainability, innovation, and ecological responsibility that resonates for generations to come. By harmonizing growth with environmental well-being, we shape a future where business and nature thrive together.
WHAT IS THE NEMIROFF CODE OF BUSINESS CONDUCT?
The Code establishes basic requirements for business conduct and serves as the basis for our Company policies, procedures, and guidelines, which are integral parts of this Code. The values and principles set forth in our Code is our road map.
Sometimes you might face a difficult situation about business conduct. In this case the Code serves as a guide in preserving our reputation and upholding our values. The Code does not cover every situation or issue, but it can show you the way to find the right answer.
WHOM DOES THIS CODE APPLY TO?
All Nemiroff team members are required and responsible for compliance with the Code of Business Conduct, Company policies as well as laws and regulations that govern its activities. This applies to every team member at every level of the Company, regardless of location, labor duties or type of engagement.
Individuals and companies (including suppliers, service providers, business partners, and other stakeholders) when dealing with Nemiroff are welcome to share our values and follow our Code of Business Conduct.
HOW TO MAKE GOOD DECISIONS?
If you have doubts about your decisions or actions, ask yourself these 5 questions:
- Does this comply with our Code?
- Is it legal?
- Does it follow our policies?
- Does it benefit the Company as a whole – not just a certain individual or group?
- Would I be comfortable if my actions/decisions were made public?
If you answer “YES” to all of these questions, the action is acceptable. If your answer to any of these questions is “No” or “Maybe” do not do it. In any case, if you are not sure about your actions, please contact the legal and/or HR department
RESPONSIBILITY OF EACH EMPLOYEE
- 1
Be aware of and know the Code. Read it and follow it, as well as any other policies and rules that apply to your work.
- 2
First think, then act. Be honest, judicious and ethical in all your actions. Use the 5-question rule if you have doubts.
- 3
Share this Code. Promote a culture of honesty and integrity by making ethical decisions. Do not seek to achieve a business result by violating our Code or the law.
- 4
Do not ignore a violation. Prevent damage to our Company and its reputation by reporting your concerns immediately.
- “These documents need to be signed urgently”
- “Processing a transaction bypassing the normal process”
- “Do it because we are running out of time”
- “No one needs to know about this”
Comments like these can harm the Company’s business processes and lead to losses. Make sure that the achievement of the business goal will comply with our Code. Analyze all possible ways to achieve the business goal in an ethical way.
LABOUR AND HUMAN RIGHTS
Respect for human rights is one of the main values of the Company.
We follow and act in accordance with the UN Guiding Principles on Business and Human Rights in our relationships with our employees and business partners. We expect all employees and business partners to respect human rights in their work and the Company’s business activities. Comply with the highest standards of labour rights.
Be aware of your actions and how they may affect others. Keep our standards high. Remember that as an employee you represent the company to the world.
• Apply the Human Rights policy to your colleagues, customers and partners.
• Request partners, customers, and other stakeholders to follow the Human Rights provisions.
• Keep the Human Rights policy an integral part of your work.
• If you become aware of a potential human rights violation, report it immediately. You may report your manager, Human Resources, or the Legal Department.
DIVERSITY AND RESPECT. EQUAL OPPORTUNITIES
Each person is a key player in our team. Remember about non-discrimination and respect for other cultures and backgrounds. The attitude to a person should be based on such factors as skills, qualifications, efficiency, and business needs. Never go into personal characteristics.
We believe diversity brings strength to our team. We aim to create an inclusive environment that promotes the value of different perspectives and experiences.
We are committed to providing equal opportunities for all, ensuring fair treatment in hiring, promotions, and compensation. Harassment, mobbing, any types of discrimination shall not be tolerated in Nemiroff.
ANTI-CORRUPTION AND ANTI-BRIBERY
Nemiroff takes a strong stance against corruption and bribery.
- We do not tolerate acts of bribery, corruption, fraudulent conduct or kickbacks. We demand the same from our employees, representatives, business partners, and stakeholders.
- We do not offer, give, ask for or receive any presents in order to gain an unfair advantage or achieve a business goal.
- Our relationships with our business partners and government regulators do not create bribery or corruption risks for our Company.
- We make sure that our business partners do not pose a risk of bribery or corruption with the “Know Your Business Partner” procedure.
Please contact the legal department for clarification if you have heard: “A charitable donation can help speed things along”
The success of the Nemiroff brand is based on the high quality of our products, not illegal or unethical behavior.
TRANSPARENT TAXATION
We value transparency as the basis of trust with all stakeholders. We recognize and comply with reporting requirements set by authorities.
Nemiroff takes a straightforward approach to taxes and appreciates Benjamin Franklin’s approach that taxes are certain. We comply with all applicable laws and are not engaged in tax optimization.
We believe that paying taxes is in line with our responsibility to be a good corporate citizen and our fiduciary duties to the Sovereign.
RESPONSIBLE DRINKING AND MARKETING
Nemiroff follows a responsible drinking policy. We have been and always will support the importance of moderate drinking.
We comply with health warning laws in each country and sell our products responsibly. We believe it is important that consumers are well informed about alcohol and our products. We make sure to emphasize this on our packaging, in our advertising and promotions.
Nemiroff has been and will continue to be engaged in cooperation and interaction with various social partners to promote responsible drinking and condemn excessive or irresponsible alcohol consumption.
CONFLICT OF INTEREST
A conflict of interest is a situation when your personal, financial or any other interests conflict with the Company’s interests or may have a negative impact on the Company’s business activities.
We expect that every employee makes business decisions and acts based on the best interests of our Company, not for personal gain. Every decision we make at work must be objective and take into account the business interests of Nemiroff.
Even a probable conflict of interest may harm our Company and our reputation. We expect all employees to disclose any information about actual or potential conflicts of interest.
HOW TO IDENTIFY A CONFLICT OF INTEREST?
- 1. Could my personal interests or relationships influence the decisions I make?
- 2. Could I or someone close to me benefit from my participation in this situation?
- 3. Can my decisions be questioned or considered to be against the interests of the Company?
If ‘YES’ to any of these questions, you must disclose a potential conflict of interest to your manager.
GIFTS AND HOSPITALITIES
We value our clients, suppliers, and business partners. As a company, we operate in the markets of more than 80 countries, all of which have their own cultural customs. We respect all local traditions, but they may not violate this Code. Cultural customs can be in the form of modest gifts or hospitality such as lunches or dinners and gifts of minimal value that do not influence business decisions.
How to distinguish an inappropriate gift?
The best approach is to exercise good judgment. We do not exchange gifts or other hospitality that look like an attempt to influence improperly a business decision.
Check yourself to find out if a gift is acceptable:
- 1. Modest in cost
- 2. A symbolic item (for example, a branded t-shirt)
- 3. Designed for a public
What about giving gifts?
Make sure the gift furthers the business purpose and is reasonable and appropriate. Please note that our business partners have their own rules for receiving gifts. Do not offer any gift that would violate such rules and put a business partner in an uncomfortable situation.
DATA PROTECTION AND DIGITAL TRANSFORMATION
We are committed to protecting personal data and ensuring its security across all our operations. Employees and partners must handle data responsibly and in accordance with our data protection policies.
We will be transparent about data collection and usage, providing clear information to stakeholders.
In the event of data breach, we have procedures to mitigate damage and notify affected parties promptly.
We encourage adopting new technologies to improve efficiency, customer experience, and competitiveness.
Our innovation strategy emphasizes ethical considerations in the use of technology, ensuring responsible adoption and implementation.
SOCIAL MEDIA AND COMMUNICATION
Employees must be responsible for using social media, ensuring personal posts meet the company values and do not harm the company’s reputation.
Only authorized personnel may speak on behalf of the company, ensuring that communications align with our values and objectives.
RECOVERY OF UKRAINE STATEMENT
As every Ukrainian, Nemiroff is granted with the nation’s indomitable spirit. We believe in our victory and nowadays contribute to recovery of Ukraine expanding our productions facilities in the home country.
We believe in prosperous Ukraine and despite of the ongoing war we have started construction of a new Spirit Plant in Nemyriv, which shall be completed in 2025.
CORPORATE SOCIAL RESPONSIBILITY
We believe in giving back to our communities through philanthropy, volunteering, and partnerships.
We work with suppliers that share our commitment to ethical practices and environmental sustainability.
ENVIRONMENT CARE
We look beyond the present, therefore sustainable development is a priority direction of our business activities. We strive to limit harmful environmental aspects of the production cycle. The main steps are reducing carbon footprint, reducing greenhouse gases, and optimizing water use.
In 2024 we aim and actually we have already started development of Nemyrivsky Biogas Complex – project regarding production of biogas from post-alcohol bard.