SáGa Foods Food Industrial Ltd’s Code of Conduct


One of the keys to market success is to have a positive value system, that supports the goals of the company and which is reflected in the behaviour of the employees. A culture based on this strengthens the internal integration of the organization and promotes flexible adaptation to the environment.

Our Business Code of Conduct includes the highest standards of fair business that are demanded by the owners of our company. A system which is based on our believes and values, which – applied to the everyday life situations of the Company – expresses our commitment to honesty, fairness and transparency.

Compliance with laws is necessary, but it is not sufficient in itself. The purpose of the Code of Conduct is not only to help all of us in ensuring the legality of our activity, but also to align ourselves with the high standards of our own. This can be achieved by adopting a clear set of rules defining our business conduct and by providing guidance in helping us to make the right judgments and decisions during our work,

The success and recognition of the Company – beyond the financial results – is greatly influenced by the commitment of its employees, their positive attitude towards the company goals, as well as the identification with the goals. With this in mind, the goal is to develop a company culture which features are clear strategy, mission and goals that everyone knows and accepts.

It is important that the senior staff creates the right background for achieving the set goals. In addition to this, a two-way communication is indispensable, one element of which is that managers shall communicate results, successes and problems openly and in a timely manner to all concerned workers. The other pillar is to provide feedback, and let the employees to give feedback.

The Company’s Code of Conduct is a set of moral requirements towards the employees of the Company, which sets out those behaviours that are accepted by the Company and are in line with the Company’s interests.

It covers all those behaviours that shall be followed by the employees during their work:

  • towards each other and towards the Company,
  • towards clients and business partners,
  • towards suppliers and competitors,
  • towards state organizations, authorities and
  • towards media forming the public opinion.

Adhering to the requirements set for ourselves and maintaining and increasing the reputation of our company are all our personal responsibilities. For this reason, we have to take our time and understand what is expected from us, furthermore with our announcements and actions we have to meet these expectations. By following the Code of Conduct as well as the spirit of the Code we all contribute to creating an organization within Sága, which not only effectively works, but it is also a workplace where we are happy and proud of.

The Code of Conduct is binding on all:

  • Employees, apprentices, students,
  • Workforce employed through a school cooperative,
  • Hired labour force,
  • Advisers,
  • Contractors supplying services to the Company and on their associates

and the Company expects

  • Acting in compliance with the internal and external rules, regulations, as well as
  • in compliance with Code of Conduct.

All the managers are responsible for keeping and enforcing the ethical norms. The Company may only engage with customers, business partners and suppliers, who comply with the regulations of the Code of Conduct. This is the responsibility of all the employees/managers of the Company.

The Code of Conduct defines those rules and guidelines that shall be adhered to by all Sága employees, furthermore provides support and guidance to employees helping them in meeting behavioural and ethical standards.

Everyone should act in line with the legal regulations. Furthermore obligations of our employees regarding the irreproachable business activities go far beyond the strict legal regulations, which means:


  • responsible behaviour
  • fair, honest and reliable business activities
  • appropriate procedures in line with the set behavioural standards /always have to choose what we believe is the best/



Expected behaviour towards employees and the Company, as well as unethical behaviour

All employees of the Company are obliged to adhere to ethical behaviour during its work.

The ethical behaviour manifests itself in the fair and honest working relationships. Good reputation and fairness of the Company are ensured via its employees. If someone becomes aware of an unlawful or unethical situation at the Company, s/he is obliged to call the attention of the employee concerned, in a more serious case the immediate supervisor, the HR manager, or the owners of the company.

The employee who breached the stipulations of the Code of Conduct, the party exercising the rights of the employer might sanction following an investigation, a recorded employee hearing and consideration of the case.

The atmosphere at the Company shall be free from any discrimination and harassment. The prohibition of discrimination is a fundamental principle, that shall be enforced in each human contact.

Nobody can be discriminated by skin colour, religion, gender, age, family status or disability, maternity, national / ethnicity, political beliefs and affiliation with interest representation.

Strictly prohibited to behave on a way – especially racial or religious mockery, scolding, etc. –, that generates bad workplace atmosphere.

Everyone is obliged to respect private life. Each employee has the right to separate private life and work.

It is forbidden and it is a harassment to make discrimination, comment or other statement, any behaviour that frustrates, violates or inconveniently affects the other party.

It is forbidden to maintain situation with conflict in interest, the legal provisions of which are defined in the Labour Code, the relevant MD’s directives as well as in the corporate internal rules.

Working in secondary jobs is considered to be unethical, if it reduces the employee’s attention and time in maximizing performance during its employment with the Company.

The Company expects from its employees not use their work time to manage their personal affairs and external works without the permission of the Company, furthermore not to use the equipments, resources and non-public information about the Company for such activities or for entertainment.

The Code of Conduct does not contain guidance for any life situation.

However the absence of a rule applicable to a particular case does not exempt the employee from acting properly, its behaviour shall be characterized by honesty, fairness and highbrow.

Employees shall amend the provisions of the Code of Conduct on their own discretion, ensuring the compliance with the spirit and content of the Code of Conduct.

No clear-cut solutions are available all the time. In case of doubts and questions regarding the right action, consider the following:

  • am I calm about what I am planning to do?
  • would be conscience be clear if I should explain my attitude to the management, to my family or to my friends?
  • who is influencing me and would s/he judge my behaviour fair?

The Company encourages its employees to express their views on these principles and to make proposals to improve them. Opinion, suggestions and questions shall be sent to the HR department in person, in e-mail or in a sealed envelope. It is the duty and responsibility of the HR manager to investigate the reports, treat their content anonymously, confidentially and coordinate any necessary corrective actions with the approval of the owners and senior management of the Company.


Obligation to cooperate

Close cooperation between the employees of the Company and the departments of the Company is indispensable. The behaviour of the Company employees is determined by the mutual respect and shared interest in common goals.

It is not ethical to generate competition between the employees and the departments based on individual interest, as the interest of the Company requires the cooperation of the employees based on mutual trust.

Within the framework of the cooperation, all Company employees shall strive to solve specific issues. It not ethical to make general negative statements regarding the problems arising without striving to get a solution, whether it applies to individuals or to organizational departments.

The manager is responsible for presenting the Company results at regular intervals with all of its employees, as well as the expected fulfilment of the set goals, for informing the employees on issues affecting them, for helping the employees in solving tasks efficiently and on the basis of uniform principles.

Both the managers and the employees are obliged to observe the deadlines, to be well prepared on the meetings and on the business negotiations, as well as to use and maintain the external and internal communication channels.

A manager cannot give instructions to his supervised employees, the execution of which in not possible without breaching the ethical behaviour.  If the manager assigns an activity that involves unlawful tasks or it seems to be unlawful, furthermore with completing such an activity the employee would breach the Code of Conduct, the management team members shall be notified immediately.

The Code of Conduct strictly prohibits to raise sanctions against those employees, who report information in good faith or raise questions about the potential breach of the legal regulations or of the Code of Conduct.

If the task of the employee is to hire or supervise contractors, agents and service providers, s/he has to strive

  • to get them complying with the Code of Conduct, including contractual commitments as well as the requirement to work in line with the stipulations of the Code of Conduct as long as they work the Company. All the affected parties shall set an example with its own behaviour and shall ensure the high level compliance with the Code of Conduct. It has to demonstrate the integrity with its own behaviour. It must be ensured that the service providers and those performing the task have the appropriate support and resources to enable them to comply with the Code of Conduct.
  • It shall learn the content of the Code of Conduct issued by the contractors, clients, service providers or the ethical norms implemented in their daily lives. The learnt information shall be shared with its managers.

Managers always have to take time to give guidance to those who have questions regarding the Code of Conduct.

The HR department shall ensure, that the staff (employees, trainees, students, etc.) also become familiar with the content of the Code of Conduct and obligations arising from it, furthermore it shall be part of the induction training, that shall be documented.

Health care and environment protection

By their work and behaviour employees of the Company cannot jeopardize the health and safety of their own, of their colleagues and of others, as well as the condition of the built and natural environment. Employees must have a personal concern for the protection of the environment, as our company  does that.

We pay attention not only to the environment surrounding us, but also to our circumstances within the company and to our employees. In this context the health and well-being of our employees is important to us, therefore we support the health consciousness of employees is supported through regular medical check-ups, screenings and we do our best to improve our working conditions.

Conflict of interest

A conflict of interest is if an employee gets/obtains additional benefits due to his/her duties or position (beyond the normal remuneration of work).

It is considered a conflict of interest if an employee exercises his/her job related obligations or obligations to the Company not in the interest of the Company, but takes into account the interests of himself/herself or an organization, a company or a partner related to him/her.

All workers must avoid situations in which their personal interests may be contradictory or conflicting with the interests of the Company. In a given situation, a case of conflict of interest arises when it allows for personal gain, regardless of whether or not the profits have actually been made.


It is impossible to list all those situations that may rise a conflict of interest or its suspicion, therefore any situation must be assessed on the basis of specific facts.

A few examples, the list is not complete:

It is forbidden to use information or data obtained during the employment, contractual partnership or private activities to derive private benefit from a certain situation.

It is forbidden to gain personal advantage or benefit by information or data obtained in the connection with the Company.

It is forbidden to carry our any activities (either it is voluntary) by or on behalf of a third party without the prior written approval of the HR manager. Work carried out for or on behalf of a third party involves a secondary jobs, a management position as well as providing any services.

It is forbidden to misuse the names of the owners and the management of the Company, or to act on their behalf.

It is prohibited to participate in the business of a competitor, business partner or service provider to Sága, to get and maintain interest in them, or to profit from their activities.

Employees should not get in a position in which they employ their own relatives, control them or have influence on their work conditions and employment terms or in which they are in manager-employee relationship. If such a situation occurs, it must be immediately reported to the HR manager in order to avoid the possibility of improper or unauthorized influencing.


Reputation of the Company

The reputation of a Company is earned by the results of its employees. All employees have the moral duty to represent these results and get them known by the external parties. The Company shall perform its activities in a way which further ensures this trust. Therefore, what an employee of the Company makes or what it makes on behalf of the Company shall comply with the ethical expectations of the Company.

It is an integral part of the Company’s business policy that its employees base their product evaluations on the positive characteristics of their products and not on the negatives ones of the competitors’ products. It is not acceptable to have incorrect comparisons in advertisements to gain consumers.

Any external organization or natural person with whom the Company has business or other contact has the right to be approached without discrimination, on a correct, fair and cultural way by the employee representing the Company.

While the employees of the Company are abroad – either sales representatives or employees from other positions – shall comply with the rules of the foreign Company. Furthermore the employee shall keep in mind, that with its behaviour as a private person it can further strengthen the good reputation of the Company.

Behaviour towards business partners and external parties

The partnership between the Company and its business partners shall be based on mutual benefits in order to maximize the satisfaction of the business partners and the Company’s profit. For this, the strategy and long term goals of the Company shall be known.

Employees need professional skills and information to be able to fulfil the demands of the business partners quickly and efficiently.

In order to meet the business partners’ demands, reveal the problems and to sort them quickly, high-quality internal cooperation shall be established and maintained. One of the key pillars of outstanding performance is team work, which makes the Company successful.

In order to maximize the satisfaction of the business partners, the Company strives not only to produce high quality products, but also puts high emphases on knowledge, caution, flexibility, politeness and kind attitude while employees representing the Company are communicating and working together with external parties.

While representing the Company, a positive picture shall be built on the Company. It is unethical to make negative statements on the Company or on the employees of the Company, to mention a professional information on the basis of which a negative view can be built on the Company’s activities and services.

It not ethical to establish a business relationship with a Company or a business association in which the employee is directly or indirectly interested or which is managed by the close relative of the employee

Representation and gifts

It is forbidden to accept larger gifts or representations (approx. for a value of 20,000.- HUF) the aim of which is to influence decision making.


  • A gift may be money, goods or services that are offered for personal use at a price lower than the market value or free of charge.
  • Representation or entertainment means generous hospitality or an invitation to an event, as well as offering services that is more than an occasional even, such as drinks or refreshments.

The Company acknowledges that smaller gifts such as pens, diaries, calendars, books, folders, mugs, mousepads… etc. (approx. for a value of 20,000.- HUF) are normal part of business practice. Such minor gifts can occasionally be accepted without reporting.

Business lunch or dinner is also allowed with the business partners.

Occasionally there may be circumstances in which the acceptance of bigger gifts or representations is appropriate. These shall be reported each year (see Annex No. 1).

Considering the restrictions above, it is not prohibited to accept gifts or representations if the following criteria are met:

  • presented for a good reason (recognition or a real business purpose);
  • does not impose an obligation on the recipient, so no expectation arises;
  • done openly and not in secret;
  • proper;
  • proportionate;
  • complying with the reporting obligations for giving and acceptance.

The employee cannot:

  • give, promise or offer money, gift or representation with the expectation or hope for gaining business advantage, or with the aim of rewarding a business advantage, that has already been acquired;
  • give, promise or offer money, gift or representation to state official, agentor representative to “promote” or speed up a routine procedure;
  • accept money from a third party if the employee knows and assumes that it is offered with the expectation of gaining business advantage;
  • threaten or retaliate on an other employee, if it refuses to commit bribery or who expresses its concerns;
  • engage in activities that may result in the violation of these principles.

If the employee has doubts about what can be accepted and what not, it shall consult the HR manager.

The employees are individually responsible for announcing any gifts or representations offered, which shall be made in writing by January 31. of each year (see Annex No. 1).


The Company uses zero tolerance against bribery.

Bribery means offering, promising, dedicating, accepting, receiving or claiming any undeserved bonus or advantage from a particular person or to a person in order to influence its behaviour; encourage to carry our unlawful activities, to misuse trust; and to carry out activities which are contrary to the expectations of acting in good faith and impartiality.

Bribery is a criminal offense. Bribery and corruption might lead up to 10 years of imprisonment in case of individuals. If it turns out the Company participated in bribery, beyond the penalties the profit realized via the subject contract may be repayable, can be excluded from tenders or its reputation might be damaged.

The Company is committed to pursue its business in a fair and ethical way, and in particular not to commit or take part in bribery. It is a basic goal and expectation from the Company to act on a fair and honest way in all business relationships and business partnerships, and to develop and maintain a process that effectively prevents bribery.

The prevention, detection and reporting of bribery and any other forms of corruption is the responsibility of the Company employees as well as of the employees manager by the Company. All employees are required to comply with Company’s rules on bribery. Employer might start sanctions against employees, who are violating these rules, furthermore the employer might terminate the contract.

Any employee, who was approached or encourage to offer or accept bribery, or thought that such an event had or has occurred, is obliged to immediately contact HR manager. If the employee is uncertain about what counts as bribery, it shall contact the HR department is seeks for guidance.

The Company is committed that no employee may be placed into a lower position, punished or otherwise adversely affected if it is not willing to participate in bribery, even if it causes financial losses to the Company.

The Company inform each supplier, subcontractor and business partner on the zero tolerance regarding bribery when commencing the business partnership, and thereafter as necessary.

Public life and policy

The Company does not provide any material or moral support for political parties or political organization as well as for their representatives.

The social, political activity of employees – performed outside of the company on the basis of personal rights – is not prevented by the Company. If an employee of the Company publicly speaks on matters of public interest, it shall be declared and made clear for everyone, that it makes it as a private person. It cannot even make the appearance of speaking or acting on behalf of the Company.

Employees of the Company cannot influence the political views and convictions of each other neither by power nor by other means.


Material and intellectual values of the Company

The Company has a wealth of assets, which include the physical assets of the Company as well as the “know-how” type classified information and intellectual property, which means market value for the Company. The latter include the intellectual property of the Company created by the employees of the Company during their work, their knowledge, furthermore those classified information that is handled by the employees during their work.

The protection of all these assets is extremely important. Each employee is personally responsible for the protection of the assigned assets, as well as for the protection of the material and intellectual values of the Company. Any damages to the assets of the Company or the risk of damages shall immediately be report to the direct supervisor and the HR department.


It is a breach of the law therefore responsibility shall be taken for any behaviour  that damages the financial interests of the Company, behaviour that not only harms the norms related to the expected behaviour but also causes damages to the Company.

Protection of physical assets

Loss, theft, damage, misuse and use of the Company assets for a purpose different from the designated one violates the interests of the Company. It is prohibited to lend assets owned (managed) by the Company without permission, to use them for personal purposes or to carry out tasks that were not approved by the managers of the Company and not helping the interests of the Company.

Classified (secret and confidential) information

a.) In order to maintain the competitiveness of the Company all employee has the obligation to protect confidential and classified information.

This is part not only complying with the legal regulations, but also an ethically expected behaviour.

Therefore neither during the employment, nor after the termination of the employment for whatever reason, the employee cannot disclose data, documents, procedures, methods and other classified information relevant to the operation of the Company to a third party, which were acquired during the employment at the Company, except it was previously approved by the Company in writing.

b.) Extra care shall be paid to those documents, data which contain information relevant to the Company and to the operation of the Company and which were prepared in connection with the position of the employee.

c.) It is the responsibility of the employee to return any document, media or other material containing classified information to the employer in case of the termination of the employment for whatever reason.

d.) The bona fide disclosure of secret and confidential information to third parties through information links can cause such harm to the Company as if they were disclosed deliberately. It is important, therefore, for employees not to reveal classified information in their possession to unauthorized persons, not even during conversations with family members or friends, as they can pass these information on without intent.

e.) The protection of the Company’s interest requires the approval of any publication by the direct supervisor prior to the actual issue, especially if the author mentions the Company name or the information disclosed affects the Company’s fields of expertise or its reputation.

f.) Employees of the Company may not use unfair means to obtain business secrets or other confidential information from market competitors. Therefore it is prohibited to obtain classified information from competitors’ employees on unauthorized, unlawful unethical way.


Anti-competitive behaviour, money laundering

The Company believes in free competition. We strive for fair and ethical competition while respecting the applicable legal regulations.

The Company employees are also obliged to ensure that they comply with the laws on competition in force.

The actions of our employees are more convincing than our words, therefore it is important to meet the legal regulations and makes this visible for our consumers, suppliers and market competitors.

The laws on competition have an impact on the daily activities of the Company which include the sale and display of our products,  keeping contact with the suppliers, sales partners and consumers; for example it is unethical to unilaterally modify the prices or sales terms or pre-negotiate certain contractual conditions.

The employees of the Company are prohibited from negotiating with the competitors or exchanging information in order to:

  • fix prices or certain aspects of pricing, including but not limited to the discounts, pricing method, payment terms and costs, timing of price increase or its percentage or scale,
  • fox other conditions,
  • distribute or split the markets, customers and different areas between them,
  • limit the production or the performance
  • influence the competitive bidding procedures or
  • enter into collective agreement on not buying or not selling to certain market participants.

Taking part in the market competition is not possible without collecting information form the competitors, but only legally, within the framework of law on competition. These data cannot be obtained unlawfully or on any other incorrect way, such as theft, illegal entry, bribery, deception, etc.

Money laundering and anti-terrorism

Money laundering includes possessing profit resulted by crime or the use of such profit. It also includes the willingness to conceal the origin of the money illegally acquired, so that the money appears to come from a lawful source. The Company does not support money laundering, does not help it.

The Employees are prohibited from making transactions about which they know, or at least believe that they are related to money from illegal activity; it is forbidden to take part deliberately or indirectly in money laundering.

The Company and its employees are obliged to ensure that they do not consciously take part in financing terrorist activities and otherwise do not support activities that might promote terrorism, furthermore they are engaged in activities which do not conflict with counter-terrorism measures.


This Code of Conduct comes into force on January 1, 2021. At the same time, Code of Conduct issued in 2018. will expire.

When the Code of Conduct enters into force or in case of new recruits, employees shall acknowledge with their signature (with filling Annex No. 2.) the content of the Code of Conduct and shall consider it binding in their work.

Employees of areas defined in Annex No. 3 are obliged to – January 31, following the subject year, as required by the HR department – acknowledge with their signature, that they have carried out their works in line with the Company’s Code of Conduct.

Dated: Sárvár, December 29, 2020.

Bárány László
Managing Director

Dr. Kántor Gyöngyi
HR manager