Code of Ethic Conduct


This Code of Ethic Conduct defines how all those who workfor Inercom should conduct themselves. The purposeof the Code of Ethic Conduct is to cover the basic forms of conduct, behaviourand responsibility of each person within the Company,and thus set clear principles and boundaries.

Table of Contents

  1. Introduction
  2. General Principles
  3. Employees
  4. Customers
  5. Suppliers
  6. Public authorities and other institutions
  7. Media
  8. Compliance
  9. Reputation Protection
  10. Fair play


From its foundation Inercom EOOD has as a main purposes the correct business, the trust inside or outside the company, good attitude toward its customers, business partners and employees The goal of Inercom EOOD is to remain among modern, successful and competitive companies;

I, as a General Manager will always make efforts and actions for the reducing of the risk unethical and illegal conduct and believe that our suppliers, customers, employees and competitors will appreciate this.

I expect that all of us will observe this Code of Ethic Conduct in our daily work, based on professional expertise and good conduct, always performed with honour and integrity.

Each company that wants to be strong and successful should observe these rules and principles.

General Manager:
Ginka Varbakova

General Principles

  • In our business activities, we follow our internal control documentation, based on the applicable and effective legislation, relevant standards and law of the European Union and the UN, and also the Ethical Conduct Policy of Inercom EOOD.
  • We observe ethical principles, laws and regulations, and deal with our partners with respect.
  • We respect the rules of ethical conduct and the internal documentation of other companies (if these are publicly accessible, provided that they are not in conflict with the relevant legislation and the Inercom Ethical Conduct Policy)
  • In our business activities, we respect the right to compete and the applicable competition law, as we firmly believe that only fair competition and a transparent market can freely develop the society as such.
  • We do not give preference to any party, nor support any event or initiative with solely or prevalently political objectives.
  • We do not accept nor grant any extraordinary benefits of any kind.
  • We neither encourage nor tolerate fraud, corruption, breach of competition rules, discrimination or harassment in any form.
  • We provide timely, reliable and accurate information to everyone that need it.

And we expect the same approach and conduct from our business partners and customers.


  • We create a positive working environment for our employees in which they can develop their potential and grow professionally. We do not accept any form of discrimination and harassment.
  • We strive to maintain a strong and sound relationship with our employees that is based on mutual respect and trust. We foster a fair approach to all of our employees.
  • We require that each of our employees conduct themselves in line with the relevant ethical standards and values, regardless of their position within the firm.
  • We respect the relevant standards and laws of the European Union pertaining to employee relations. We honour the conventions of the International Labour Organization and of the United Nations.
  • We do not allow any discrimination, whether direct or indirect, nor harassment of any form, or any child labour and forced labour.
  • We honour the freedom of association, privacy protection, and collective bargaining.
  • We offer our employees appropriate options for personal and professional growth and motivate them to make use of these options, which improve their skills and competencies. We support our employees who contribute to the sustained success of Inercom with their specialised knowledge and capabilities.
  • We mutually respect each other and provide timely, reliable and accurate information to one another.
  • We do not misuse any information obtained for personal benefits or for any activity that would be inconsistent with the legislation of the Republic of Bulgaria or with the Inercom’s rules and values.
  • Any civic or political engagement of our employees cannot harm Inercom’s reputation. Our employees must refrain from any conflicts of interest or activities that conflict with their work and activities performed for Inercom.


  • We always deal transparently and honestly with all of our customers.
  • We provide our services in a qualified and professional manner.
  • We look for such solutions that will meet the needs of our customers and comply with consumer protection requirements to the greatest possible extent.
  • We provide intelligible, unbiased, complete, up-to-date and not misleading information in line with the best available knowledge.


  • We always treat our suppliers fairly and with respect.
  • We request them to observe our ethical standards and rules.
  • We deal with our suppliers on the basis of mutual respect and honesty.
  • Apart from honouring their contractual obligations, we expect our business partners to adhere to all legislative and ethical rules and requirements including environmental protection and corruption mitigation.
  • We only establish business relationships with partners who enjoy a good reputation, who do their business solely through legal activities, and whose funds come from legitimate sources.
  • We honour the rules of international trade

Public Authorities and Other Institutions

  • We fully cooperate with governmental bodies and public administration authorities.
  • We maintain an apolitical stance in our business activities and treat public administration authorities with mutual respect.
  • We establish our relations with them on the basis of correctness, transparency and full respect for the roles of both parties.


  • Information provided to the public must always be objective and true.
  • We protect internal information and prevent their unauthorised disclosure or misuse for the sake of gaining unjust benefits
  • We use advertisements, the content of which must always be true, in line with the fundamental ethical values of the civic society.
  • We solely use social networks to support our business and business model.


  • This Code of Ethic Conduct includes “Rules for Observing the Code of Ethic Conduct”, which are instrumental in correctly understanding their meaning, significance, and observing the principles in the following fundamental areas:
  • Every employee needs to bear in mind that they are Inercom representatives; therefore, not only are they responsible for observing the Code of Ethic Conduct, they may not overlook any breach thereof either.
  • The rules contained herein may be further detailed in Inercom’s internal control documentation or the internal control documentation of each of the group companies and may reflect both industry and national specifics.
  • Those of us who have demonstrably breached the laws, regulations or internal guidelines in force, or this Code of Ethic Conduct shall not only face the sanctions defined by law but also disciplinary actions.

Reputation Protection

  • The reputation of Inercom is to a great extent dependent on what we do and how each of us conduct ourselves.
  • The Inercom Group Code of Ethic Conduct is based on the legislation of the Republic of Bulgaria and of the European Union and fully respects the applicable standards, international conventions on human rights, on fighting corruption and on protecting the environment.
  • This Code of Ethic Conduct applies equally to all of us who are part of Inercom. Each of us is expected to observe this Code of Ethic Conduct as a matter of course in our corporate business activities and in the dealings of all stakeholders regardless of their position and office held.
  • Any illegal or otherwise inappropriate conduct on the part of just one of us may harm our company’s reputation. Therefore, each of us should make sure that our conduct will keep up the reputation of Inercom.
  • The principles defined in the Code of Ethic Conduct represent a summary statement of our values, define an ethical framework, and include fundamental principles and rules of ethical conduct that are required within the company and also toward external partners and the public

Fair play

Fair play is not just open and honest behaviour but also helping others. Each company will have success and will grow if there is a good working team and strong relationships in the workplace. Everyone of us experienced overestimating his or her abilities. The important is to face the problem, admit an error and not to look for excuses. There is always a solution.

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