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Ethics And Anti-Corruption Policy

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Ethics Policy

The Ethics And Anti-Corruption Policy

at Sp. z o. o. with registered office in Warsaw, Republic of Poland of 14th March 2020 appreciates and focuses on honesty and reliability. Compliance with legal and ethical standards and generally accepted patterns of behavior is a matter of course for us. Actions aimed at ensuring high quality of products and services, reliability towards contractors, employees, the State Treasury and care for the environment testify to a responsible approach to managing the Company and is one of the sources of success. is of the opinion that in all activities of the company it is necessary to maintain basic ethical values and recognize obligations towards all interested in the Company's activities. Integrity is a prerequisite for corporate stability and success. The reputation of the Company and trust in it is one of the greatest values of the Company.

Table of Contents:


1. Customer Relations
2. Relations With Shareholders And Other Investors
3. Employee Relations
4. Relations With Contractors
5. Relations With Competitors
6. Anti-Corruption Activities
7. Relations Of Business And Politics
8. Public Procurement
9. International Business Issues
10. Relations With Authorities And Local Communities
11. Natural Environment
12. Implementation Of Ethics And Anti-Corruption Policy


1.1. The Company provides valuable products and services of good quality, solidly made and safe to use.

1.2. The Company does not provide incomplete information or misleading descriptions of the services and products offered.

1.3. In advertising and other forms of communication, the Company avoids providing untrue, exaggerated or incomplete information.

1.4. To ensure full customer satisfaction, the Company provides a high standard of maintenance services.

1.5. The Company's employees do not give customers money or gifts that may be treated as material benefits, nor do they accept such things themselves.

1.6. The Company avoids practices aimed at increasing sales through any unlawful marketing activities.

1.7. The Company keeps proprietary information obtained from the Customer secret, and maintains the highest standards of ensuring the security of personal data processing.


2.1. The company cares about the interests of shareholders and other investors, and does nothing to favor one group of shareholders or investors to the detriment of another.

2.2. The Company strives to achieve an attractive rate of return on capital in the long term.

2.3The Company honestly informs about its policy, achievements and development prospects.


3.1. Relations with employees, by which we also mean all associates performing their duties on the basis of any legal titles, are based on respect for their personal dignity.

3.2. The Company recruits and promotes employees, taking into account the qualifications required for a given position. Employees are not discriminated against because of race, religion, nationality, skin color, age, sex, marital status or disability that do not affect the results of their work.

3.3. The Company strives to provide stable jobs and reliably informs employees about employment prospects.

3.4. The Company provides a clean, healthy and safe working environment in accordance with the standards and laws. Employees, for their part, have a duty to make every effort to avoid accidents, injury to themselves, their colleagues and bystanders.

3.5. The Company ensures the confidentiality of medical data provided by employees. The results of periodic examinations will not be made available to other employees and third parties.

3.6. With a view to appreciating the efforts of individuals who contribute to the success of the Company, the Company applies the rules of a transparent and clear remuneration policy. The rules of the remuneration system are designed to take into account the individual contribution of each employee.

3.7. The Company helps employees improve their qualifications and supports their career in the Company.

3.8. The Company informs employees about the goals of its activities and tasks at individual workstations.

3.9. Information obtained from employees while working is not used for any competitive purpose other than that for which it was made available.

3.10. The Company does not disclose the direct personal interests of employees in managerial positions and their family members related to the company's operations. Disclosure of a potential conflict of interest may involve CEOs, directors, major shareholders and the employment of family members.

3.11. The Company does not tolerate sexual harassment and other forms of mental or physical abuse of employees.

3.12. The Company recognizes its special responsibilities towards employees who will soon retire.

3.13. When purchasing supplementary pension insurance, the Company is solely for the benefit of its employees. The Company makes every effort to choose the most secure offer of an insurance company or investment fund.

1.14. The Company will develop procedures for resolving disputes and will do everything possible to resolve these disputes without allowing the conflict to escalate.

1.15. The Company strives to ensure the fullest possible communication with each employee. The Company recognizes the need to inform and consult employees in the teams in which they work. Where possible, employees are duly represented in negotiations. If there is an appropriate agreement with trade unions, the Company will provide appropriate solutions that will facilitate constructive dialogue.

3.16. The company reliably informs employees about paid social security contributions and about the nature of concluded contracts. Employees will be notified in advance of the intention to conclude and the form of a possible civil law agreement. The Company does not enter into civil law contracts in cases not permitted by law..

3.17. If it is necessary to dismiss employees, the Company will make efforts to help them find a new job, if possible.


4.1. Relations between the company and its contractors should be based on mutual trust.

4.2. Payment for the service performed or the goods delivered will be made on time and in accordance with the concluded contract.

4.3. The Company's financial strength will be used sparingly.

4.4. The Company recognizes that the acceptance of gifts or other benefits by employees of a cooperating Company may result in situations perceived as an attempt to encourage the donor to offer certain benefits in return. The following rules should be followed:

          - do not force anyone to accept the gift,

          - do not give cash gifts,

          - reasonable, small gifts and hospitality may be accepted if they do not create any obligation for the recipient and can be reciprocated to the same extent,

          - the obligation to inform superiors about each received expensive gift and about the service rendered, related to the company with which the cooperation is carried out.

4.5. Information regarding the relationship between the company and contractors should be treated as confidential.


5.1. The Company competes fairly with competitors and does not undermine their reputation.

5.2. When dealing with competitors, employees avoid situations that allow them to disclose confidential information about the Company.

5.3. The Company does not obtain competition information by illegal means. These include industrial espionage, hiring employees of a competitor in order to obtain secret information from them, inducing employees of a competitor or its customers to disclose information they possess, and other means not listed above.

5.4. The company does not use any restrictive commercial practices that are unlawful.


6.1. Corruption crime hinders economic development, violates free competition, increases the costs of doing business, lowers the safety and quality of products and services, which may threaten the interests and damage the image of any entity participating in economic transactions. The possible occurrence of corruption and abuses related to it could result in criminal liability of persons engaging in such practices and consequences for the Company itself. Acceptance of corrupt activities would make it difficult to run a business, limit the possibility of promoting services and products, and could make it impossible to obtain public contracts, as well as threaten with high financial penalties.

6.2. The anti-corruption solutions adopted by the Company protect against legally defined corrupt activities, and also counteract mismanagement, improperly managed conflict of interest or collusion of contractors in the event of their connection with corruption.

6.3.'s Anti-Corruption Policy and its implementation is also based on and reflects international law (such as the UK Bribery Act, the French Loi Sapin II and the US Foreign Corrupt Practices Act) and good practices in preventing, detecting and responding to bribery, identifying corruption-related technological, financial and image-related threats, and other corrupt behavior that may harm's economic interests.

6.4. The policy aims in particular to:

          - preventing and detecting corruption events by implementing systemic solutions;

          - identifying threats, assessing risk and taking actions to protect the Company's economic interests;

          - initiating control or audit activities in order to assess events and determine the responsibility of persons suspected of corruption, including employees and representatives of the Company who neglect the implementation and application of anti-corruption standards;

          - implementation of rules of conduct for employees and representatives of the Company that increase anti-corruption security, including counteracting abuses that may indicate corruption;

          - shaping the awareness of people making business decisions in the field of identifying corrupt behavior and counteracting it.

6.5. The anti-corruption policy contained in this section of the Ethics and Anti-Corruption Policy is the formal basis for the implementation of the Anti-Corruption System, which regulates relations between employees, entities and persons representing the Company, contractors, suppliers, clients and representatives of public administration.

6.6. The Anti-Corruption System is implemented in the Company and managed personally by the President of the Management Board with the support of the legal team, a set of measures, forms and methods of counteracting and detecting corruption and related abuses.

6.7. The Company does not tolerate corrupt behavior involving the abuse of positions or functions in order to achieve undue financial or personal benefits.

6.8. The company effectively counteracts the phenomenon of corruption by implementing systemic solutions based on the analysis of information available within the organization and obtained from external sources.

6.9. The Company responsibly and consciously identifies and manages the risk of fraud and corruption threats.

6.10. Representatives of the Company's management staff are obliged to create a work environment based on respect for ethical standards and compliance with applicable regulations.

6.11. The policy introduces an obligation in the Company to create conditions for anonymous reporting of irregularities and the rules for accepting and giving gifts in connection with the business activities of employees and representatives.

6.12. The company actively builds and verifies the awareness of ethical attitudes and corruption risks among employees and contractors.

6.13. The company trains employees and representatives in counteracting corruption and responding to corruption-generating situations.

6.14. The Company avoids conflicts of interest that may undermine the integrity and credibility of the Company, its employees or management.

6.15. The Company complies with the internal regulations listed in this Policy regarding expenses and gifts.

6.16. The Company actively notices and explains cases of violations of the law and internal regulations regarding counteracting corruption, and we immediately take appropriate disciplinary and corrective actions.

6.17. The Company adheres to equally high anti-corruption standards in all places of business.

6.18. The Company imposes an obligation on all employees and representatives of the Company to comply with the anti-corruption regulations introduced in all countries in which the Company conducts its activities.

6.19. The Company imposes on all employees and representatives of the Company the obligation to comply with the principles of ethics, honesty and conduct in accordance with applicable law in all activities undertaken, in particular in business transactions in relation to natural persons, contractors, public institutions and social organizations.

6.20. Employees and representatives of the Company are prohibited in particular, but not exclusively, from the following acts:


Employees and representatives may not, in connection with the performance of activities performed for the Company, accept a financial or personal benefit or its promise, including for behavior constituting a violation of the law, or make the performance of such an activity dependent on receiving a financial or personal benefit.


Employees and representatives may not grant material or personal benefits to any person performing a public function in connection with the performance of this function. Employees and representatives may also not take actions aimed at persuading a person holding a public function to violate the law or give or promise to give such a person a financial or personal benefit for violating the law.

Influence trading - paid passive protection

Employees and representatives may not, by referring to their influence and position in the Company, or by persuading another person or convincing him or her of the existence of such influence, undertake mediation in settling a matter in exchange for a financial or personal benefit, or a promise thereof.

Influence trading – paid active protection

Employees and representatives may not provide or promise to provide a material or personal benefit in exchange for intermediation in settling a case in a state or local government institution, international or national organization or in a foreign organizational unit with public funds, consisting in unlawfully exerting influence on a decision, action or failure to act by a person performing a public function in connection with the performance of this function.

Managerial bribery

Employees and representatives may not demand or accept a material or personal benefit, or a promise thereof, in exchange for abuse of the rights granted to them or failure to fulfill their obligation, which may cause material damage to the Company in which they are employed, or constitute an act of unfair competition or an unacceptable activity preferential to the buyer or recipient of goods, services or benefits.

Manipulation in tenders

Employees and representatives may not, in order to obtain a financial benefit, thwart or hinder the tender or enter into an agreement with another person, acting to the detriment of the owner of the property, or the person or institution for whom the tender is being conducted.

Employees and representatives may not, in connection with the tender, disseminate information or conceal important circumstances relevant to the conclusion of the contract being the subject of the tender, or enter into an agreement with another person, acting to the detriment of the owner of the property or the person or institution for whom the tender is being conducted.


7.1. The Company's activities are characterized by full respect for the law, implemented by democratically appointed local, regional and national authorities.

7.2. The Company does not support political activities based on promoting hatred, prejudice and discrimination against specific groups or individuals.

7.3. The Company's policy on supporting social and political activities is public.

7.4. The Company does not treat politicians and representatives of the authorities in a particularly privileged way.


The Company complies with the Public Procurement Act and all national and international regulations in this regard, in particular:

8.1. The Company does not influence decision-makers by giving them gifts, promising benefits or giving financial gratuities.

8.2. The Company provides in its offers such substantive conditions that it will actually be able to meet.

8.3. The Company Reliably presents its achievements and experience in its offer.

8.4. The Company does not take actions that discredit competitors.


9.1. The company complies with the law applicable in other countries, as well as the law in international relations.

9.2. The company respects the traditions and culture of each country in which it operates.

9.3. The company acts responsibly in the field of international trade, in accordance with recognized international agreements.

9.4. The Company pays special attention when cooperating with current clients, as well as when establishing cooperation with potential clients, whether these entities are not subject to sanctions resulting from recognized international regulations.


10.1. The Company makes every effort to be a socially sensitive business entity, serve the community through activities that are beneficial to the Company and the community, and provide favorable employment opportunities and good working conditions.

10.2. The Company takes into account the interests of the entire environment, taking into account both national and local interests.

10.3. The Company supports the local community as far as possible. Any charitable donations are made under the rules set by the shareholders.


11.1. In its operations, the company is guided by a high degree of responsibility for the natural environment.

11.2. The Company cares about environmental protection and uses natural resources in a responsible manner. Therefore:

          - makes every effort to ensure that the production cycle, wastewater management, waste disposal, exhaust gas and noise emissions are within the set standards,

          - analyzes the effects of each new project on the environment,

          - conducts regular reviews of the Company's environmental impact,

          - has a special regard for the protection of animals and plants living in nature

          - informs the community in which the Company operates about its environmental protection program.


12.1. The President of the Management Board, acting with the support of the legal team, is personally responsible for the implementation and management of the Ethics and Anti-Corruption Policy.

12.2. Implementation of this Policy is combined with ongoing monitoring of its observance, in particular, the Company monitors the compliance of decisions and methods of operation with the principles adopted in the Policy.

12.3. Strict application of the Policy should be the result of ongoing education of employees in the field of adopted ethical and anti-corruption principles, carried out by qualified entities.

12.4. The Company's goal is to create a favorable working climate and opportunities for employees and to honestly explain all issues regarding behavior and decisions considered ethically reprehensible and that may be conducive to corruption.

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