Code Of Business Conduct And Ethics

This Code of Business Conduct and Ethics is intended to document the principles of conduct and ethics by Polcreative Group Sp. z o.o. (the Company) and its employees and directors. Its purpose is to promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest.

Conflicts of interest

Employees and directors of the Company shall avoid situations where their personal interest could conflict with the interests of the Company. If any potential conflict of interest arises involving an employee, the individual must immediately notify the director in writing and no further action may be taken unless authorized by the director.

Dealing with suppliers and service suppliers

All purchases of goods and services by the Company will be made exclusively on the basis price, quality, service, and suitability to the Company´s needs. Employees or directors are prohibited from accepting gifts of money or receive any type of personal kickbacks, rebates or other “under-the-table” payments. Employees and directors may accept unsolicited non-monetary gifts provided they are appropriate and customary client development gifts for the industry.

Dealing with public officials

No employee shall make any form of payment, direct or indirect, to any public official as inducement to procuring or keeping business or having a law or regulation enacted, defeated, or violated.

Equal opportunity

There shall be no discrimination against any employee or applicant because of race, religion, colour, sex, sexual orientation or ethnic origin or physical handicap (unless demands of the position are prohibitive). The Company will maintain a work environment free of discrimination practice of any kind.

Health, safety, and environmental protection

It is the Company´s policy to pay due regard to the health and safety of its employees and director and others and to the state of the environment.

Use of agents

Agents or other non-employees cannot be used to circumvent the law or to engage in practices that run contrary to this Code.

International operations and business practices

Employees and directors operating outside of Poland have a special responsibility to know and obey laws and regulations of countries where they act for the Company and to conduct themselves in accordance with local business practices. The Company recognizes that laws, regulations, business practices and customs vary throughout the world and that, in certain cases, may be different from laws, regulations, business practices and customs in Poland. The Company and its employees shall comply with applicable laws relating to corrupt practices.

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