Effective date: 1 May 2026 · Last updated: 12 May 2026 · Owner: Board of Directors · Review cycle: Annual
1. Our commitment
ERAM Real Estate Sh.P.K. conducts its business with integrity, honesty and respect for the law, for the people we work with, and for the communities in which we build. This Code of Conduct sets out the standards of behaviour we expect of every person associated with ERAM.
2. Who this Code applies to
This Code applies to every director, officer, employee, consultant and contractor of ERAM and its project SPVs. Equivalent standards are passed down contractually to our suppliers, partners and agents.
3. Integrity and honesty
We do what we say we will do. We do not make commitments we cannot keep. We communicate truthfully with customers, investors, regulators, colleagues and the public. We do not knowingly mislead.
4. Compliance with law
We comply with all laws and regulations applicable to our business in Kosovo and any other jurisdiction in which we operate. Where ERAM's policies set a higher standard than the law, we apply the higher standard.
5. Respect for people
We treat colleagues, customers, suppliers and the public with respect. We do not tolerate harassment, bullying, intimidation, or discrimination on the basis of race, ethnicity, national origin, religion, gender, sexual orientation, age, disability, marital or parental status, political opinion, trade-union membership, or any other protected characteristic.
6. Health and safety
We commit to providing a safe and healthy workplace and to ensuring safe construction sites. Every employee and contractor is responsible for following safety procedures, reporting hazards and incidents, and stopping work where they identify an unsafe condition.
7. Conflicts of interest
We identify, disclose and manage conflicts of interest in accordance with the Conflict of Interest Policy. We do not allow personal interests to influence business decisions.
8. Anti-bribery and corruption
We do not give, offer, accept or solicit bribes or improper advantages, anywhere in the world. The Anti-Bribery & Corruption Policy sets out the standards in detail.
9. Confidentiality and data protection
We protect the confidential information of ERAM, our investors, customers, suppliers and colleagues. We use information only for legitimate business purposes and in accordance with ERAM's Privacy Policy and the Kosovo Law on Personal Data Protection.
10. Books, records and reporting
We maintain accurate and complete books and records. We do not falsify documents, hide transactions, or misrepresent results.
11. Use of company resources
We use ERAM's resources — funds, property, time, information — for legitimate business purposes. We do not misappropriate, waste, or use them for personal gain.
12. Speaking up
If you believe this Code has been or may be breached, speak up. Use the Whistleblowing channel. Reports may be made anonymously. Retaliation against good-faith reporters is strictly prohibited.
13. Consequences
Failure to comply with this Code is a disciplinary matter. Depending on circumstances, it may also expose the individual and the Company to civil and criminal liability. Disciplinary action ranges from informal counselling to termination of engagement and referral to competent authorities.
Contact
Questions regarding this policy, or to report a concern: [email protected]. Confidential reports may also be made via our Whistleblowing channel.
ERAM Real Estate Sh.P.K. · Business no. (NUI) 812052025 · Registered 13/06/2023 · Rruga Agim Ramadani, Nr. 2, 10000 Prishtina, Kosovo