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"Doverie above all"
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Solidarity pension systems will not disappear, but will undergo serious reforms
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Code of ethics




The Code of Ethics of PAC Doverie AD outlines and sets the Company's policy and principles with respect to its customers, employees, shareholders, external co-operators, partners and other persons from the outside environment.


The trust in the Company and in its overall activity on the part of all persons and entities is the main value on which the company management is built.


The Company's reputation and the people's trust are part of its most important advantages and their preservation is amongst the company's major tasks.


For all people working in and for the Company the Ethical Code shall have powers equal to all laws and regulation in the country and they shall be required to adhere in their overall activity to all ethical rules and standards provided for herein and the violation of any provision of this Code shall be treated as a hard offence lowering the reputation and damaging the good name of the Company.




1.  Legal Compliance

1.1. The employees and all persons working for the Company shall obligatorily comply with all applicable national laws and regulations and any other relevant statutory requirements whichever requirements are more stringent.


1.2. Any interpretations of statutory requirements as well as any legal decision or action shall be based on the supremacy of morals and professional ethics.


2. Principle of management

A major obligation of the management of the Company is that all employees and persons working for the Company shall adhere to the „primum non nocere" ("First, do no harm") principle.


3. Social responsibility

3.1. In its entire activity the Company shall implement a socially responsible policy manifested mainly in providing a stable and upward development of the corporate business, which all people working for the company shall accept as their primary responsibility towards society.


3.2. On investment of the assets of the persons insured with the supplementary pension funds managed by PAC Doverie AD, the Company adheres to a socially responsible investment policy and ethical rules concerning funds investments. These rules are within the legal framework, they are applicable in practice in the operative management of the fund and include as follows:

3.2.1. The assets of the supplementary pension insurance funds managed by the Company shall not be invested in: companies violating the United Nations conventions on human and labor rights, environment protection and against corruption, expressed in the following major principles: Human rights principles - to support and respect the protection of human rights internationally; denial from participation in abusive acts or violations of human rights;  Labor rights principles - to support freedom of association and acknowledgement of the right of collective bargaining; prohibition of compulsory labor; child labor prohibition; elimination of discrimination upon staff selection; Environment protection principles - introduction of preventive and effective programs for protection of the environment, initiatives demonstrating responsibility for the environment; promoting and applying environmental friendly technologies Anticorruption principles - promoting and supporting activities reacting against all forms of corruption, including blackmail and subornation; in companies the business of which is production or trading with weapons. Investment in such companies is allowed only provided that their major business is not related with that activity and the substantial part of their income does not come from production or trading with weapons. in companies for which there are reasonable assumptions that their income comes from illegal sources. 


3.2.2. Managing the fund for supplementary pension insurance the Company shall follow a consistent policy striving at investments where there is a cross-point between financial and ethical principles and there is a relation between the positive choice and the principles under item 1.


3.2.3. The Company shall make regular observation of the investment portfolio of each of the funds under its management and every investment shall be evaluated according to the ethical rules.




In performing the activity of the Company the following shall not be allowed or tolerated:

1.  No discrimination with regard to equal attitude to potential and existing clients, in hiring, access to training, promotion,  termination or retirement based on gender, age, religion, race, social background, disability, ethnic and national origin, nationality, membership in workers' organisations including unions, political affiliation, sexual orientation.


2. All forms of exploitation of child labor.


3. All forms of forced labor;


4. Retention of identity documents of employees;


5. The use of corporal punishment, mental or physical coercion and verbal abuse;


6. Sexual harassment, including behavior that arouses suspicion for sexual harassment;


7. Corruption practices of any kind or character, the reaction against such practices being major task of every employee of the Company.




1. Persons working for the Company may not be involved in the decision making process, including discussion, preparation, making and execution of any decision when those persons or parties related to them have interests in the concrete decision or when those persons are in such relations with interested parties that may arouse doubts in their objectivity.


2. Being assigned a task, the fulfillment of which might arouse a conflict between professional obligations and private interests, the employees and the people working for the Company shall in due time report to their direct superior or the appropriate officer of the Company in charge for the fulfillment of the concluded contract.


3. The employees shall be obliged to avoid, and if impossible, to declare in writing any conflict of interest right after the appearance of any circumstances or a situation that might provoke such conflict.  




1. Professional and personal behavior of employees

1.1. The employees of the Company shall:


1.1.1. Perform their functions with high professionalism, impartiality and activity in compliance with the following principles:  Competence - the employee has the necessary knowledge, skills and training for the respective post; Efficiency - the employee achieves maximum labor results with minimum physical and mental efforts and resource costs; Responsibility and punctuality - the employee shows a strong sense of duty in performing the tasks. Helpfulness - the employee is responsive to all people asking for the services of the Company, information or assistance; Civility - the employee has a well-mannered and kind behavior. Uprightness - the employee is straight in presenting his/her point of view. Loyalty - the employee behaves respectably and with regard for the Company, never engaging in any practices that could be damaging to the public image of the company. Appropriate appearance - the employee keeps within the bounds of decorum and business attire corresponding to his official status and the financial institution he represents.


1.1.2. The employees shall not allow at the working place any behavior incompatible with good manners.


1.1.3. The employees shall follow a behavior never damaging the prestige of the Company, whether discharging official duties or in their social and personal life.


1.1.4. The employees shall not allow to be placed in financial dependence or any other involvement with external persons or organizations, nor to demand or accept presents, services, money, benefits or other profits which might influence the performance of their official duties, their decisions or their professional approach to certain issues.


2. Relations with colleagues

2.1. The employees of the Company shall treat their colleagues with respect and accuracy, never allowing behavior that might hurt the dignity or infringe upon the rights of the individual.  


2.2. The employees of the Company shall respect the opinion of their colleagues and shall consider their right to personal life.  




1. The entire activity of the Company is focused on clients as the company's most important value and target of work of all employees.   


2. The employees of the Company shall:


2.1. Discharge their duties impartially and without any prejudice, creating conditions for equal treatment of all cases and persons and doing their best to make services accessible for all.   


2.2. Ensure that clients' personal data and information entrusted to, or obtained by them in the course of discharge of their occupational or professional duties is protected.   


2.3. Render service to clients in compliance with law, in due time, accurately, conscientiously and without prejudice. The employees shall express opinion on the clients' requests and present all the information necessary for the protection of the client's rights and interests in conformity with the requirements of the applicable legislation.


2.4. Answer the clients's questions in accordance with their functions and if necessary forward the client to another officer having the necessary competence.  


2.5. Inform clients about the possibilities to lodge an appeal in case of breaches or refusal of a particular service.




The Company encourages and supports free economic and market competition and rejects completely unfair competition, all actions that might be defined as unfair competition being forbidden for the employees, the insurance intermediaries and the other external co-operators of the Company.




The Company shall provide healthy and safe working conditions and invest in their improvement, demanding from employees a strict observation of the established rules.  




Within the meaning of this Code:

Related persons/parties are spouses and relatives to third line inclusive in direct or collateral line and relatives by marriage.




§ 1. This Code is approved by resolution of the Board of Directors of Doverie Pension Insurance Company, minutes № 203 /28.10.2008.


§ 2. A Commission on Ethics shall be established, which shall include as ex officio members the members of the Board of Directors of PAC Doverie AD and the representative of the persons employed by PAC Doverie AD in the General Meeting of Shareholders. The Commission membership shall be determined by names by decision of the Board of Directors of PAC Doverie AD.


§ 3. The Commission on Ethics shall supervise the adherence to the Code of Ethics and shall adopt rules for the organization of its activity.


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