§ 1. Introduction

1. The Code of Ethics is a set of principles on which the Employer’s relations with its Employees and all entities in the entity’s environment are based.
2. Its purpose is to:
a) define guidelines for the behavior of people employed by the Employer and cooperating with the entity;
b) indicate the main obligations that the Employer assumes in relation to Employees and vice versa;
c) determine the Employer’s position towards external entities in the Entity’s environment.
3. The Code of Ethics is a tool for employees that is the basis for values ​​and all solutions, as well as creating value with respect for legal provisions.
4. Consultants, suppliers, customers and all other persons having contact with the Entity are also obliged to comply with the provisions of the Code of Ethics.

§ 2. General rules

1. This Code contains ethical principles and values ​​that connect Employees and the Employer and are the basis for their actions.
2. The Code sets standards of conduct resulting from a sense of responsibility for actions towards Employees, third parties and clients/petitioners.
3. The primary goal of the Code is to facilitate making the right choices by identifying
key ethical patterns and standards in professional activities.
4. The Code aims to help eliminate negative phenomena and behaviors that most often result from unawareness of undertaken actions or omissions.
5. The primary goal of the Code is the continuous improvement of Employees in the implementation of assigned tasks.
6. The basic ethical principles that the Unit follows are trust, respect, responsibility, cooperation, reliability, attention to the development of one’s own competences and impartiality.
7. The values ​​indicated in section 6 are always the starting point for every Employee in actions, deeds and words, shaping a culture that allows achieving the goal.
8. Reliability is understood as conscientiousness, creativity, responsibility, impartiality, readiness to admit a mistake and correct it, rationality in management, loyalty, consent to limit the principle of confidentiality of information also from personal life.
9. Attention to the development of one’s own competences is understood as developing professional knowledge, striving to learn legal acts, readiness to use the knowledge of others, and explaining one’s position.
10. Impartiality is understood as preventing suspicions of a conflict of interest, not accepting any material or personal benefits in connection with the matters conducted, and respecting citizens’ right to information.
11. Each Employee is obliged to adhere to a set of common values, thereby promoting a coherent organization that supports Employees.
12. The Workplace complies with applicable legal provisions, including acts, concluded contracts and internal policies and procedures.

§ 3. Employer’s obligations

1. The Employer respects basic human rights. Therefore, any form of forcing to perform work by limiting freedom or threats of physical violence as discipline or control is considered unacceptable.
2. In the employment process, the Employer complies with the minimum age in accordance with national regulations.
3. The Employer considers the right to form trade unions and elect their representatives to be a fundamental right of all Employees.
4. The Employer promotes a policy of equal opportunities and equal treatment. All decisions are made on merits, regardless of skin color, religion, gender, sexual orientation, status, origin or level of ability. This is reflected, among others, in: regarding employment or remuneration of Employees.
5. The Employer considers it unacceptable to discriminate against an Employee on the basis of nationality, race, gender, religion, political affiliation, disability, sexual orientation, or any other reason. Its basic principle is the search, employment and support of employees based on their qualifications and skills. Employees are also prohibited from showing any signs of discrimination (e.g. by harming, harassing, mobbing) and partnership based on mutual respect for others is supported.
6. Harassment includes, among others: verbal harassment, including offensive comments, jokes or slander; physical harassment, including unnecessary or crude touching, obstructing or preventing movement; and visual harassment, including offensive or crude cartoons, drawings, messages, notes, or facial expressions. Sexual harassment includes: requests for sexual favors or other verbal or physical acts of a sexual nature when: submission to such an act is made a condition of an individual’s employment, submission to or rejection of such an act is intended to be the basis of an employment decision, or the purpose or effect of such An act is unreasonably disturbing someone at work or creating an intimidating, hostile or rude atmosphere in the workplace.
7. Any Employee who believes that harassment has occurred by another Employee, a supervisor or a person entering into a transaction with the company or on its behalf should notify his/her immediate supervisor or the human resources department. Complaints will be handled confidentially to ensure that no one experiences any retaliation or reprisal for reporting or filing a complaint. If the complaint concerns the Immediate Supervisor, it should be directed to the person who is his/her superior. Each complaint of harassment will be thoroughly investigated and appropriate action will be taken depending on the results of the investigation. If it turns out that an Employee is responsible for sexual harassment or harassment in any other form contrary to the law, disciplinary proceedings will be initiated against him or her with sanctions, including possible dismissal.
8. The Employer’s primary obligation is to comply with safety standards and regulations, guaranteeing protection and safety at work in accordance with applicable regulations.
9. The employer respects legal requirements regarding the minimum wage. This is manifested, among others, by: providing Employees with detailed information about remuneration or remuneration components and the principles of their calculation, including the payment of additional benefits in accordance with applicable law.
10. The employer respects at least the minimum legal requirements regarding maximum permissible working hours. The number of working hours, including overtime work, is consistent with applicable laws regulating the permissible number of working hours.
11. The employer complies with applicable legal provisions and standards regarding public holidays, maintaining, among other things, a transparent and reliable system of recording working time and remuneration.
12. The Employer undertakes to provide Employees with access to tools for acquiring, updating and developing their knowledge necessary to perform their job duties.

§ 4. Responsibilities of management

1. Persons holding positions in which they manage or supervise employees’ work or manage cooperation with third parties are obliged to set a good example in the scope of the tasks they perform, including by acting appropriately and giving no one reason to doubt the motives of their behavior. or actions taken.
2. These people are also obliged to promote a positive work environment without behavior that could be considered violence, mobbing or discrimination.
3. Persons holding positions in which they manage Employees or supervise their work or manage cooperation with third parties are obliged to inform Employees about the importance of complying with this Code and implementing its provisions.
4. It is prohibited to require or ask Employees to take actions or behaviors that are inconsistent with applicable laws or internal regulations as part of the employment relationship between the Employee and the Employer.
5. Persons holding positions in which they manage employees or supervise their work or manage cooperation with third parties are obliged to support and promote activities consistent with applicable laws and internal regulations.
6. It is prohibited to undertake or promote any retaliatory actions.

§ 5. Counteracting corruption

1. Activities undertaken by Employees and the Employer are conducted in an open, direct and honest manner, in compliance with antitrust law and fair competition standards.
2. Employees have no right to offer any financial benefits to their current or potential clients/petitioners.
3. It is also prohibited to provoke customers or suppliers to offer gifts or favors to Employees.
4. Any actions that may constitute corruption and may give the impression of an attempt to commit bribery are prohibited.
5. Employees undertake to counteract corruption and are also responsible for actively communicating the assumptions of the anti-corruption policy while performing their official duties.
6. Employees are obliged to inform about circumstances that may affect the impartial performance of their official duties. If they receive information about the occurrence of corrupt behavior, Employees are obliged to secure any evidence and notify the Employer through their Direct Supervisor, and if the above applies to the Direct Supervisor, to notify the Employer directly.

§ 6. Proscription of unfair competition

1. Each Employee is obliged to comply with the principles of competition law and antitrust law. This means, among others: a ban on conducting talks with competitors during which prices, commercial terms and know-how of the Employer/Client are discussed.
2. Favoring or excluding business partners is considered unacceptable.
3. Partners take full responsibility for their own conduct to ensure fair competition.
4. Infringing the intellectual property of others through unauthorized use, copying, distribution, or making changes is considered unacceptable.
5. Intellectual and industrial property and confidential information must be subject to special protection by Employees, who are to strive to protect it and use it only to the extent consistent with legal provisions, and in the case of protection enjoyed by the Employer/Client – Employees are obliged to take actions related to with controlling their use by third parties in accordance with the adopted rules.
6. Using for personal purposes, without the Employer’s consent, the Employer’s position or information obtained by Employees in connection with the performance of their duties arising from the employment relationship is prohibited.
7. An Employee may not use the Employer’s property, information or position for improper personal gain or compete with the Employer, directly or indirectly. The Employee’s obligation is to support the legitimate interests of the Employer.
8. The basic goal of the Employer is to strengthen the attitude of Employees to perform their professional duties in a way that does not allow entering into relationships with clients/external suppliers that may result in biased choices and lack of objectivity.
9. Any case of conflict of interest with clients/external suppliers identified by the Employee should be immediately reported in writing to the Human Resources Department. If a conflict of interests arises, the Employee’s activity must be terminated.
§ 7. Attitude towards entities, people, alcohol and drugs
1. We treat all employees with dignity and respect, verbal abuse of employees, mental and physical coercion is not tolerated.
2. Treating others with respect and dignity is a basic behavior towards all partners, both in cooperation and in relationships with other entities or people.
3. It is prohibited to be in the workplace under the influence of alcohol or drugs. If an Employee comes to work under the influence of drugs or has a level of alcohol or other chemical substances in his or her body that may limit his or her ability to perform work, disciplinary proceedings will be initiated against him or her, including possible dismissal. Employees who have significant problems maintaining the quality of work or cause serious incidents or accidents will be subject to dismissal if medical tests show the presence of drugs in their system. Employees who, while working or staying on the premises of the workplace, distribute, sell, buy, produce, distribute, possess or consume drugs may also be exempt..

§ 8. Personal data protection

1. Each Employee is obliged to guarantee a quick and uninterrupted flow of information, thus supporting cooperation and ensuring that information is provided immediately, comprehensively and without falsification.
2. Each Employee uses only legal communication tools that comply with the law.
3. Each Employee is obliged to comply with data protection requirements, as well as legal provisions relating to information protection and protection against misuse of confidential, secret and personal data.
4. Personal data means any information that can be used to identify an individual, directly or indirectly (e.g. name, date of birth, social security number, photograph, email address, computer identification number). They must be used fairly and for a specific, clear and legal purpose for the period necessary to achieve that purpose. It should be ensured that persons whose data are collected are informed about this fact.
5. Each Employee is obliged to keep trade and business secrets due to performing specific functions in the company.
6. All information that is not in public circulation is subject to protection, even if no formal confidentiality obligation has been formulated towards it. This principle applies equally to information about the Employer and its Employees, as well as information about third parties.
7. Employees may not disclose confidential information without authorization to third parties who do not have access to the information. Confidentiality may cover various types of information, including all internal, confidential, proprietary or secret information related to the Employer’s activities. Confidential information also includes, among others: production processes and methods, product recipes and compositions, computer software and passwords, financial data, financial forecasts, plans and strategies, customer price lists, profits and production costs, as well as other information about the business, customers and suppliers. Unauthorized disclosure of trade secrets may result in loss, which may constitute a criminal offense or amount to a breach of contract. The prohibition on disclosing trade secrets applies to Employees both during and after their employment.
8. You should take all necessary steps to protect confidential information and place it in a safe place. Disclosure of such information may constitute a breach of confidentiality obligations, including to third parties.
9. Regulations must be complied with and the hierarchy of responsibilities related to the dissemination of information, including confidential information, must be maintained.
10. Before disclosing confidential/secret information to third parties, you should consult with Human Resources to determine whether a confidentiality obligation or other appropriate data protection measures are necessary.

§ 9. Reporting complaints

1. Each employee and stakeholder has the right to report a suspicion that there has been a violation of the law and the Code of Ethics. Violations must be reported in the manner chosen by the Employee, including, but not limited to: anonymously to the posted boxes “Complaints, requests and grievances” or by e-mail to the following address: zgloszenia@kpg.org.pl
2. In the case of the notification referred to in section 1, which is not anonymous, the name of the reporting person is disclosed only after his/her consent. For this reason, contact is made confidentially.
3. Each reported problem is forwarded to the Management Board, Production Director or Human Resources Manager, who decides on how to solve it within 7 days.
4. In connection with a report, it is prohibited to take retaliatory actions against an Employee who reports a suspected violation of the law or the Code. If retaliation occurs, it must be reported immediately so that appropriate remedial measures can be taken.

§ 10. Final Provisions

1. All Employees, regardless of their position in the organizational structure, have the opportunity to become familiar with the values ​​and principles set out in the Code of Ethics.
2. Each direct superior ensures that the employees subordinate to him know and apply the Code of Ethics.
3. If there are any questions or ambiguities regarding the application of the Code of Ethics, the first person to contact is the Direct Supervisor. The employee may also report this matter to the Human Resources Department.
4. The Code of Ethics is available from your immediate superior and from the Human Resources Department.