Code of Ethics

Table of contents

    INTRODUCTION AND GENERAL PRINCIPLES

    Why are we introducing a Code of Ethics in our company?

    The Code of Ethics is a guidebook that contains principles, standards and instructions.
    We created it to:

    • help you understand our values;
    • introduce you to the principles and standards of behaviour that guide our day-to-day business, employee and community relations;
    • use it daily in work and actively promote the established principles.

    In developing the Code, we have based it on the values that are the guiding principles of our organisation. It is through them that we can act with integrity and responsibility.

    Our values and purpose

    Both in internal and external relations with stakeholders we are committed to universal values that promote:

    • honesty, diligence and conscientiousness in performing the assigned tasks;
    • striving for high quality and innovation in individual work;
    • open cooperation for the common good;
    • building and maintaining trust among associates and business partners, as well as respect, understanding and assistance, regardless of position or differences of opinion.

    We engage in dialogue with those around us to improve our operations and promote fair and credible behaviour towards all employees. Each of us is responsible towards other employees as well as customers, suppliers and subcontractors for meeting the set standards.

    Our principles reflect the ethical values we uphold. They present a pattern of behaviour towards other employees, superiors, customers, partners and local communities, both in business and business-related dealings.

    The Code of Ethics is a set of principles for all our employees showing how to behave responsibly towards specific stakeholder groups: consumers, shareholders, suppliers, customers and competitors, as well as towards the environment and the communities of the countries where we operate.

    Scope of the application of the Code of Ethics

    The Code of Ethics applies to:

    • partners, managers;
    • all employees;
    • entities providing services to our Company under a contract of mandate or other agreement.

    The Code applies to all activities of our organisation.

    Third party stakeholders, such as consultants, contractors, suppliers, agents or other representatives engaged to work with our organisation, are also required to comply with the Code of Ethics.

    A very important part of our Code of Ethics includes the rules on accepting gifts (as part of our anti-corruption policy).

    Provisions of law

    The Code does not exclude or limit the application of other internal regulations in force in our organisation, as well as the provisions of the law. All employees and other persons obliged to adhere to the Code must comply with the provisions of the law.

    Responsibilities of the management staff

    Executives, i.e. the shareholders and all the managers in the organisation, play an important role in our Company. It has an impact on shaping behaviour in its environment, building and maintaining a work environment, customer relations and promoting principles and values.

    Every executive should:

    • promote behaviour consistent with the values and principles set out in our Code;
    • comply with the provisions of the Code and thus set a good example for other employees;
    • hold discussions with employees to identify problems or situations that may adversely affect performance, relationships within our Company and relations with those around us;
    • be alert to the need to comply with occupational health and safety rules and regulations and respond to any information on potential hazards and occupational health and safety breaches;
    • respond to any information on threats to or breaches of confidentiality of information that constitutes Company and business partners’ secrets and personal data;
    • draw attention to the need to report issues and problems relating to the application of the Code of Ethics;
    • respond to any information that indicates the occurrence or the possibility of the occurrence of behaviour or events not conforming with the provisions of our Code or the law, and report such information promptly to shareholders.

    Employee’s responsibilities

    All employees should familiarise themselves with and comply with our Code.

    Due to the nature and objectives of our Code, every employee should:

    • comply with the provisions of the Code and thus set a good example for other employees;
    • promote behaviour consistent with the values and principles set out in the Code;
    • be aware of the need to comply with occupational health and safety rules and regulations and to respond to any information on potential hazards, breaches of occupational health and safety and threats or breaches of confidentiality of our Company’s secrets and personal data;
    • protect confidential data and secrets;
    • protect personal data and comply with regulations on data processing;
    • report information indicating the occurrence or possible occurrence of behaviour or events inconsistent with the provisions of the Code.

    Asking questions and raising concerns

    It is understandable that there may be doubts about assessing a situation or making a particular decision. In such an event it is worth asking yourself some questions:

    • Do I know all the facts and information needed to make this decision?
    • Is this action in line with the law?
    • Does this action comply with the provisions of the Code?
    • What would a colleague or superior think and what behaviour would they expect from me?
    • If my decision is made public, can I explain it honestly?
    • How will my decision affect the company, employees, customers and those around me?
    • Could the decision entail risks for the Company?

    The employee can always turn to their supervisor or associate for assistance in difficult or ambiguous situations.

    Reporting breaches

    Option to report to superiors or others in the Company

    Any employee who has information on the occurrence or the possibility of the occurrence of behaviour or events contrary to the provisions of the Code can inform their superior.

    Option to report via e-mail or via a box located at our organisation’s headquarters.

    In addition to the option of reporting to specific persons, there is also the option of reporting information on the occurrence or the possibility of the occurrence of behaviour or events contrary to the provisions of the Code to the following e-mail address: antykorupcja@orplast.pl In addition, there is a box located at our Company’s headquarters in Gdańsk where you can leave your reports on paper. Both systems ensure the protection and confidentiality of the notifying person. The box is emptied once a week on Fridays by one of the HR Department employees. We then read and analyse the message. If the sender details are provided, we reply within 2 weeks of opening the box. Please be advised that it may be difficult to process the report in the absence of evidence or detailed information relating to it.

    RELATIONS IN BUSINESS DEALINGS

    Integrity and avoiding conflicts of interest

    We are committed to integrity in our business dealings. Integrity means that employees will not try to influence business partners or allow partners to influence them in an unlawful manner.

    We are making a positive contribution to improving business standards regarding integrity, transparency and accountability in all areas of our operations

    Anti-corruption system and avoiding conflicts of interest

    We do not tolerate corruption or bribery. We do not conduct joint business if it involves breaking laws or corporate rules.

    To emphasise the importance of integrity, our Company has developed and implemented an Anti-Corruption Management System that includes the guidelines and measures set out in the Anti-Corruption Policy and the Procedure for Offering and Accepting Business Gifts.

    Accepting and providing benefits

    The acceptance or provision of benefits must always comply with the law and internal rules. We recognise any kind of support, even indirect, as benefit.

    To define the rules governing the conditions for accepting and giving gifts, we have developed the Procedure for Offering and Accepting Business Gifts in the Company. Every employee should follow the Procedure.

    We separate official and private matters and avoid conflicts of interest.

    Business decisions and actions must be carried out in the best interests of our Company and must not be influenced by personal interests or relations. Relations with current or future suppliers, customers, contractors, competitors or other employees must not influence independent and well-established decisions taken in the interests of our organisation.

    Fair competition

    Fair competition is at the heart of our operations.

    Despite the competition, we always comply with the laws connected with it as our success depends largely on offering high-quality products.

    We do not tolerate pricing arrangements and agreements, mutual disclosure of pricing information, violations of public procurement regulations, market sharing or other forms of unfair restrictions of competition.

    A breach of antitrust law can cause enormous damage to our Company, both in material terms and in relation to the image. A breach of antitrust law is not limited to cases where a written contract has been concluded. Inferring it from the behaviour of the parties involved is sufficient.

    Exercise caution during discussions with competitors or potential competitors. Refuse to participate in the conversation if such a party wants to discuss a topic that you believe may raise questions or concerns about compliance with antitrust and competition law.

    Products and services advertising

    High-quality, functional products that you can rely on are the basis of our business. We strive not only to meet our customers’ needs, but also to exceed their expectations by implementing technological innovations.

    We should only share verified and factually correct information about our products and services, as well as their quality, capabilities and suitability.

    When we compare our products and services with our competitors, we must not diminish their value. We should always be guided by objective, proven factors.

    Conclusion of contracts

    Every employee should bear in mind that it is only possible to conclude contracts on behalf of our Company on the basis of the authorisation we have given and only within the limits of this authorisation.

    When concluding contracts, always take into account the current legal situation and use our Company’s contract templates and general terms of contract.

    Be sure to include provisions regarding your obligation to read and act in accordance with the provisions of our Code of Ethics when submitting an offer or concluding contracts.

    WORK ENVIRONMENT

    Occupational health and safety

    Our employees’ health is very important to us. It goes without saying that complying with the relevant safety regulations is one of the Company’s priorities.

    We cannot allow behaviour that jeopardises the safety of our employees, which is why we provide appropriate training, the necessary protective measures and promote the safe performance of tasks. In addition to this, we have also created a procedure for reporting and analysing near misses to prevent risks.

    For every employee, the implementation of occupational health and safety principles shall mean the following:

    • the right to a safe workplace;
    • an obligation to carry out tasks while complying with all OHS principles and requirements, including the use of personal protective equipment;
    • an obligation to follow the OHS instructions and procedures and applying best practice in the safe performance of tasks;
    • an obligation for other employees, visitors and other persons to observe the OHS principles on our Company premises;
    • the requirement to report and provide assistance in the event of an accident;
    • immediately report near misses, in accordance with internal regulations.

    Every employee can put forward ideas to improve safety to their superior or to the employees responsible for OHS matters.

    Everyone should react to unacceptable behaviour, as supporting each other in complying with OHS rules and regulations will result in an even greater sense of safety. There shall be no tolerance for unacceptable behaviour such as:

    • failure to report a potentially hazardous incident in accordance with internal procedures;
    • failure to respond to another employee’s or other persons’ non-compliance with OHS rules and regulations, including failure to report such incidents to a superior;
    • working while intoxicated, after use of or under the influence of psychotropic, narcotic or similar substances;
    • carrying or bringing alcohol, narcotic or psychotropic substances, weapons, ammunition, explosives, etc. onto Company premises.

    The list does not cover all prohibited behaviours, but shows those that are particularly dangerous to working conditions and proper official relations.

    Shaping employee relations

    We care for fair working conditions and are committed to treating each other with respect.

    Relations between employees should be based in particular on:

    • mutual respect and trust;
    • respect for dignity and the prohibition of discrimination;
    • cooperation in the pursuit of jointly defined and agreed goals;
    • the efficiency of performed work.

    The prohibition of discrimination is important in mutual relations. No one shall be favoured, discriminated against, disregarded or singled out because of their race, ethnic origin, nationality, sex, religion, creed, belief, political opinion, union membership, disability, age or sexual identity or for any other objectively unjustifiable reason.

    Personal data protection

    Data protection is about safeguarding the employee’s privacy rights in relation to data processing.

    Data protection is of great importance in today’s world and all employees can have an impact on the level of data security. Employees should comply with data protection regulations.

    Keeping documentation

    Our Company’s records are properly maintained and our financial statements are clear and transparent.

    The underlying business processes are adequately documented, and information and financial reports on business activities are prepared in a complete and correct manner.

    INFORMATION AND DATA PROTECTION

    We protect the intellectual property of our corporation and respect the protection-related rights of third parties.

    Confidential information and trade secrets are protected from access by third parties. This also applies to information entrusted to us by customers or suppliers. We take reasonable measures to safeguard information to prevent its unauthorised use or disclosure.

    This means that every employee should:

    • handle information and data with care, in particular ensuring that it is securely stored, used and protected against unauthorised access or loss;
    • comply with all regulations relating to the use of and securing IT equipment, electronic data storage media and the safeguarding of otherwise recorded information;
    • use only the information to which they have access and which they are authorised to access;
    • not access, use, store or share confidential information without proper authorisation;
    • ask their superior when unsure whether they can share or use the information in question.

    Where contracts with customers or suppliers are concluded under which such information will be obtained or transmitted, care should be taken to ensure that adequate measures are in place to protect it.

    ENVIRONMENTAL PROTECTION

    Protecting the environment is of vital importance to us, therefore we strive to use materials as efficiently as possible and to conduct business in an environmentally friendly manner in every area of our operations.

    The Orplast Code of Ethics is effective as of 2019-01-16.