Third party code of conduct


  • Employee: Any person who is engaged in Unifarm d.o.o, with a fixed-term or indefinite-term contract, regardless of the type of work they do or their responsibilities within the company, as well as any authorised person.
  • Relevant employees: The persons in decision-making positions and/or the persons whose positions are particularly at risk of corruption and/or the persons whose job positions are important for the proper implementation of the Programme and other internal procedures.
  • Third party: It means any entity which Unifarm d.o.o. does business with. This includes suppliers, manufacturers, service providers, distributors, consultants, agents and any other persons acting for and on behalf of the company.
  • Misconduct: It means violations of relevant external regulations, internal rules and procedures and ethical standards or failure to take action necessary for proper conduct by employees and/or third parties.
  • Business Ethics and Compliance Management Representative: An appointed person with special authority in charge of implementing the Anti-Corruption Programme. He/she has the right to access all documents relevant to the performance of his/her duties. He/she gives consent to all internal and external documentation as well as business processes in the Anti-Corruption Programme segment.
  • Public official: A person performing the public government functions at all levels, an elected representative, a political party, a party official or a political candidate or any person representing them, a civil servant and employee, an appointed official, a manager and an employee of a company with majority state capital, a representative or an employee of international bodies and organisations.


At Unifarm d.o.o., we are responsible to our employees, suppliers, and business partners, service providers, agents, and all other persons who act for and on behalf of Unifarm, the social and natural environment. Understanding and ensuring a positive customer experience is our priority responsibility. This includes understanding the needs of our stakeholders and the associated risks to them and to Unifarm. We carefully and responsibly build partnerships with those with whom we enter into business relationships. As employees, we have a duty to each other, as well as to everyone involved, to act professionally, with dedication to and respect for each other in our work. We stand for integrity and face the challenges boldly. We take good care of the reputation of the pharmaceutical and medical systems.


We expect all third parties with whom we do business and who act for and on behalf of Unifarm d.o.o. to align their conduct with the following:

Prohibited activities

As a third party partner doing business with Unifarm d.o.o., you may not be directly or indirectly involved in any of the prohibited practices as follows:


Corruption is the offering, giving, receiving, or soliciting, directly or indirectly, of anything of value, including the influence or exchange of services that would cause the other party to engage in improper activity.

The company and the third party doing business with the company shall consistently respect the principle of zero tolerance concerning the prohibited practices. The prohibited practices include, but are not limited to:

  • promising, offering, giving and receiving bribes,
  • improper promising, offering, receiving and giving gifts,
  • embezzlement and unauthorized use of someone else’s property,
  • direct or indirect promising, offering, giving or receiving benefits for unlawful mediation, obtaining and retaining business, concluding business under more favourable conditions,
  • omission of due supervision over the performance of contractual obligations or other conduct, or omission which causes damage to the other party or made it possible to obtain unlawful benefit to a representative of one of the parties, to their broker, agent, vendor or other legal or natural person that is related to one of the parties in any manner.


Fraud means any act (deed) or omission, including misrepresentation, which intentionally or unintentionally misleads, or attempts to mislead, in such a manner that the contractor receives monetary or other benefits that do not belong to them or allow them to evade an obligation. In addition, fraudulent practices can be reflected in business books and business reports.

The term fraud refers, but is not limited, to:

  • Concealment of information that must be communicated in accordance with regulations,
  • Incorrect recording of business changes,
  • Irregularities in the management and/or reporting related to finances and transactions,
  • Disclosure of confidential and proprietary information,
  • Disclosure of confidential business-related information to other persons.

Fair competition

We are committed to improving free and competitive markets and respect the rules of fair competition and the rules governing market conduct at the international level.

Breach of competitive procedure

The breach of the competitive procedure is an agreement between two or more parties that affects the true purpose of contracting, including arrangements that affect the improper activities of the other party. The breach of competitive procedure applies to any combination or contract – no matter how informal it was (between bidders), with the aim of raising or lowering prices or reducing the volume of work in order to maximize profits.

Conflict of interest

We strive to identify and avoid potential conflicts of interest when conducting our business, and strict internal guidelines are in place for this purpose. All employees must ensure that their personal interests do not conflict with their obligations to Unifarm and the third parties.


Interference means intentional destruction, counterfeiting, altering or concealment evidence materials of an investigation or making false statements in order to impede the process of establishing the factual state by authorised bodies or other bodies; and/or threats, harassment or intimidation of any party in order to prevent disclosure of the facts relevant to the process of establishing the factual state by authorised bodies or other bodies, or acts intended to physically obstruct the process of establishing the factual state by authorised bodies or other bodies.

Payment to expedite the process

Payment for the purpose of expediting the process is a term used for payments made in exchange for services to which the company is legally entitled to receive without making such payment. These are usually relatively small payments to civil servants or persons at positions to ensure or expedite routine procedures.


Misuse is the deliberate exceeding of the permissible limits or authority for the purpose of gaining some benefit or harming others, which includes: misuse of position, misuse of information and misuse of material and technical assets.


Coercion is the act of causing damage or injury to property or rights, or threatening to cause harm or injury, made directly or indirectly, to any party in order to unduly influence the activity of the other party. The term coercion refers, but is not limited, to: blackmail, threats, extortion, intimidation, psychological pressure, violence.

Legal Compliance

It is essential for you to comply with all applicable laws, rules, regulations and contracts, including, but not limiting to, anti-corruption laws, competition, business, product and ingredient quality, privacy, and other laws governing your business.

The third party undertakes not to engage subcontractors, consultants, brokers, authorised representatives or agents associated with this contract without previous documented thorough review of the identity, reputation and integrity of the subcontractors; and it will not employ any subcontractor, consultant, agent, or authorised representative who does not comply with the prohibited activity rules and, in the event of any breach thereof, immediately notifies the company about it.

It is the obligation of all third parties with whom we do business and who act for and on behalf of our company:

  • to be thoroughly informed with the provisions of this Code,
  • to confirm in writing the acceptance of the provisions of this Code,
  • to comply strictly with the provisions of this Code,
  • to take reasonable steps to communicate this Code through their organisation and make it available to their relevant employees and the employees related to the cooperation with Unifarm d.o.o.

In the event that there is a conduct or omission, which is a prohibited practice, in connection with the conclusion of the contract or the execution of the order, we will require immediate termination of the contract and/or compensation.

If, during the communication and cooperation with the employees of Unifarm d.o.o., you notice any improper and/or illegal conduct, you are obliged to immediately the Business Ethics and Compliance Management Representative.

You can contact us directly or by e-mail: or by phone at 035/369-887.