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Code of ethics IDE Projekt sp. z o.o.

  1. Purpose of the Code.
    1. The Code of Ethics outlines undertakings regarding the standards of conduct that the Company, its employees, and associates engage in. The Code indicates the most significant values and attitudes, which reinforce the process of shaping an ethical environment and mutual trust.
    2. The Code of Ethics supplements legal regulations which specify the frameworks and standards of employees’ and associates’ behaviour, irrespective of their position in the Company, ensuring that the Company’s activity encourages the Company’s values.
    3. This regulation aims to ensure that the provisions of the Labour Code are observed. This Code is based on: the Universal Declaration of Human Rights proclaimed by the UN, the Declaration on Fundamental Principles and Rights at Work adopted by the International Labour Organisation, the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, and UN Global Compact Principles. The Code is supplemented by other internal regulations. Altogether, they constitute a set of rules adopted by the Company.
  2. Scope of application:
    1. This Code of Ethics applies to all the Company’s employees and associates.
    2. Observance of its provisions will be monitored regularly, whereas any corrective actions deemed necessary will be immediately specified and implemented.
  1. Definitions and abbreviations:
    1. The terms used herein shall have the following meaning:
      1. ‘Company’ – IDE Projekt sp. z o.o., with its main office in Toruń,
      2. ‘Employee’ – an individual performing work or providing services to the Company, irrespective of the basis of establishing an employee relationship, as well as an individual employed under a civil-law contract. To avoid any doubts and for the purposes of this regulation, the Employee shall also mean any individual who performs work or provides services to the Company in the value chain, regardless of the existence or form of a contractual relationship with the Company, i.e., respectively: employees of suppliers, subcontractors and other business partners.
  1. Description of the procedure/contents of the document:
    1. Liability
      1. Employee and human rights
        1. The Company treats human rights as a basic value, respects and promotes human rights in relations with its Employees and expects its Employees and stakeholders to adopt the same approach.
        2. The Company does not tolerate any form of child labour or forced labour. Neither does it allow any practices which limit Employees’ mobility rights.
        3. The Company accepts only those working hours, remuneration and bonuses which comply with applicable regulations. It acknowledges and respects collective labour agreements and the right to unionise. The Company is engaged in a dialogue with its Employees to ensure their rights are respected.
      2. Relations with Employees
        1. The Company employs specialists and bases its activities on their competences, knowledge and experience. The Company allows its Employees to develop professionally and supports them in their drive to develop their competences.
        2. Employee remuneration depends solely on substantive factors, education, experience, and liability.
        3. The Company establishes a friendly working environment.
        4. The Company does not accept any form of discrimination against the Employees. It does not tolerate any form of harassment or abuse, either physical or mental.
        5. The Company responds to any behaviours which do not comply with its values, conduct or internal regulations.
        6. The Company promotes openness and engagement.
        7. The Company strives to achieve a consistent and proper image by presenting its business policy as professional, responsible and oriented to the social and local needs.
      3. Diversity
        1. The Company respects diversity and difference of opinion, ensuring that everyone is treated equally in terms of employment conditions, co-operation, promotion opportunities and access to training. The Employees are treated with honesty, respect and dignity irrespective of their sex, age, religion, sexual orientation, nationality, world view, political beliefs, disabilities or held office.
      4. Sponsorship and social engagement
        1. When taking part in any sponsoring or social events, the Company avoids any content which might offend or discriminate against anyone. The Company acts responsibly, avoiding causing any negative emotions and not abusing the audience’s trust.
        2. The Company does not partake in any events which might inflict environmental or social damage. It refrains from participating in any political projects or projects which violate social norms.
        3. The Company does not fund any political parties or any organisations whose primary activity is a political one.
        4. The Eryk Grzeszczak’s ‘ERBUD – Common Challenges’ Foundation operates under the Company. The Employees take an active part in the life of the Foundation.
      5. Anti-corruption measures
        1. The Company promotes honesty and does not tolerate corruption.
        2. The Company does not demand, accept or propose any form of hospitality or gifts which could influence, or pretend to influence, business decisions of the Company, its Employees or business partners.
        3. The Company has a policy regarding hospitality and gifts. The Company maintains a process of approving and recording any given and received gifts and forms of hospitality which exceed set limits.
        4. The Company abides by all binding regulations regarding money laundering by paying attention to any suspicious transactions or entities that do not disclose reliable information willingly. The Company does not accept, enable or condone any activities which constitute money laundering or terrorist financing.
      6. Transparency
        1. The Company is reliable in conveying information. It meticulously fulfils its information duties and ensures that the information provided is true, complete and clear to its stakeholders.
        2. The Company ensures the integrity and completeness of its business documentation, maintaining timeliness and accuracy in both financial and non-financial reporting as required by law. It ensures that all documents drawn up during its operation are complete, correct and compliant with both legal provisions and the Company’s internal regulations.
        3. The Company promotes transparency: it provides information to its stakeholders by informing them of its decisions and provides its Employees with data necessary to duly perform their duties. The Company emphasises the need for regular exchange of information between superiors and workers.
      7. Conflict of interest
        1. The Company avoids a conflict of interest. It remains vigilant about situations in which private interests of Employees might contradict the interests of the Company. Any potential doubts are consulted with a superior or a Compliance Officer.
      8. Fair competition, relations with business partners
        1. Fair competition benefits the Company, its Employees and business partners. The Company abides by the antitrust and competition laws, as well as by any similar regulations.
        2. The Company cares about its relations with partners and ensures they are based on trust, professionalism, mutual respect and liability for one’s actions.
      9. International sanctions and import restrictions
        1. The Company complies with global trade inspections, import restrictions and economic sanctions imposed by the USA, EU and Poland which prohibit conducting business with particular countries, entities and individuals.
        2. Moreover, the Company adheres to binding customs requirements regarding the import and export of goods.
      10. Asset protection
        1. The Company acts responsibly when managing its assets. It protects them against damage, theft, loss or improper use.
        2. The Company protects the assets it was entrusted with by its clients and other stakeholders against damage, theft, loss or improper use.
    2. Innovation
      1. Innovative solutions
        • The Company recognises business and technological trends; it also provides modern products and services, which are based on the best technologies. The Company seeks innovative solutions, which are thoroughly tested before implementation.
      2. Sustainable development
        1. The Company promotes sustainable development. It carries out its construction processes in an ecological, economical and environment-friendly manner, as it remains a part of the environment. It introduces green solutions and building certification systems (LEED and BREEAM).
        2. The Company values energy efficiency and ensures that its approach to designing, constructing and using buildings and structures maintains a balance between environmental, economic and social factors.
        3. When taking decisions, the Company bears in mind the long-term perspective of an investment.
      3. Environmental protection
        1. The Company runs its business activity in a sustainable manner, professionally pursuing its business goals while maintaining a responsible approach to the environment.
        2. Its environmental management system is based on the PDCA cycle. This is a model of continual improvement which encompasses four stages: plan, do, check, and adjust.
        3. When implementing its operations and projects, the company continually strives to improve its results and activities regarding environmental protection. When engaging in specific projects, it looks into any potential hazards to the environment that these projects might entail. The Company endorses those innovations which reduce the negative impact of its activities on the environment.
        4. The Company purchases equipment which has appropriate attestation and meets environmental protection standards.
        5. All the Company’s stakeholders are engaged in environmentally-related activities. This applies to Employees, clients and individuals residing in the direct vicinity of the Company’s operational locations.
        6. The Company cares for the environment while conducting its everyday business duties.
    3. Safety
      1. Occupational Health and Safety
        1. The Company prioritises safety at work. It constantly introduces improvements aiming to minimise hazards. The Company deems health and safety at work a fundamental right of its Employees and the most essential component of the Company’s continuity.
        2. All Employees are liable for proper safety management and must not expose themselves or others to hazards that could potentially result in injury or other damage. All Employees carry out their work in accordance with the OHS regulations, which are reflected in the Company’s legal acts and OHS manuals. It is a Company’s and Employees’ shared interest to eliminate or mitigate hazards.
        3. The Company aims to ensure full safety of all personnel engaged in investment implementation. The goal is to eradicate serious and fatal accidents.
        4. The Company ensures that all Employees undergo both appropriate OHS training and other necessary training.
        5. Any and all work-related accidents and incidents which pose a hazard to health are reported to an OHS specialist.
        6. The Company actively participates in the Agreement for Construction Safety. This is an initiative of the top construction companies, and it aims to eradicate work-related accidents. The initiative and the Company draw up OHS standards and solutions which are binding for Employees. The Agreement is a space for sharing experiences regarding safety at work.
      2. Information security
        1. The Company guarantees that all activities relating to personal data comply with binding regulations. The Company protects Employees’ and stakeholders’ personal information.
        2. The Company exercises the highest level of diligence in protecting all information obtained in the course of its operations, particularly trade secrets, and safeguards it against unauthorised access or use.
        3. The Company ensures that access to personal data is provided solely to those individuals who require it to perform their professional duties. Any and all individuals who gain access to personal data must maintain appropriate means of their protection. Personal data is kept until a goal is reached.
    4. Reporting infringements
      1. The Company provides its Employees and stakeholders with communication channels allowing for reporting infringements, instances of corruption and other malpractice. It is an Employees’ right to immediately report any irregularity.
      2. Failure to conform to this Code of Ethics might lead to disciplinary action.
  2. Final provisions
    1. A Compliance Officer is the highest position in the organisation responsible for the implementation of the Code.
    2. This Code shall be reviewed at least once every two years. If no update is needed, its contents remain unchanged.
    3. The Code shall be shared via dedicated communication channels used in the Company.
  3. Changes
    • The Board is authorised to introduce changes hereto.
  1. Related documents and attachments
    • Not applicable
  2. Introduced changes
    • Not applicable
  3. Withdrawn editions
    • Not applicable



Code of conduct for suppliers of IDE Projekt sp. z o.o.

  1. Purpose of the Code.
    1. This Code of Conduct for Suppliers outlines commitments regarding IDE PROJEKT sp. z o.o. standards concerning suppliers of materials and equipment, subcontractors, service providers, intermediaries, and consultants, as well as expectations towards these entities. The Code indicates the most significant values and attitudes that cultivate the process of shaping an ethical environment, mutual trust, and effective cooperation.
    2. This Code complements legal regulations by defining the framework and standards of conduct in a relationship between IDE PROJEKT sp. z o.o. and suppliers, and aims to ensure co-operation that contributes to building value and promoting sustainable development for both the Company and its suppliers.
    3. This Code is based on the Universal Declaration of Human Rights proclaimed by the UN, the Declaration on Fundamental Principles and Rights at Work adopted by the International Labour Organization, the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, and the UN Global Compact Principles.
  2. Scope of application:
    1. This Code of Conduct for Suppliers applies to suppliers of goods and service providers, as well as to their employees, during their co-operation with IDE PROJEKT sp. z o.o. under executed contracts.
  3. Definitions and abbreviations:
    • The terms used herein shall have the following meaning:
      1. ‘Company’ – IDE Projekt sp. z o.o., with its main office in Toruń,
      2. ‘Supplier’ – suppliers of materials, equipment and devices, subcontractors and service providers,
      3. ‘Employee’ – an individual performing work or providing services to the Company, as well as an individual employed under a civil-law contract. To avoid any doubts, the Employee shall also mean any individual who performs work or provides services to the Supplier in the value chain, regardless of the existence or form of a contractual relationship with the Supplier, i.e., employees of suppliers, subcontractors and other business partners.
  1. Description of the procedure/contents of the document:
    1. General remarks
      1. The Code of Conduct for Suppliers constitutes a set of rules that the Company follows and expects that its Suppliers will also follow.
      2. The Company implements optimal solutions to achieve the highest standards of running a business activity. In its operation, the Company adheres to the OECD Guidelines for Responsible Business Conduct, the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, and the Universal Declaration of Human Rights. It observes and complies with the standards proclaimed by the International Labour Organization, the United Nations Convention Against Corruption, international trade sanctions and embargoes–including the sanctions binding as a result of a resolution adopted under Chapter VII of the United Nations Convention by the United Nations Security Council–sanctions imposed by the European Union, domestic legislation implementing the abovementioned provisions, as well as provisions of other regulations, particularly those whose aim is to eliminate a conflict of interest.
      3. When co-operating with Suppliers, the Company abides by the principles of responsible business conduct and sustainable development.
      4. The Company builds a culture of joint liability for business dealings as regards occupational health and safety, human rights, business ethics, and care for Employees and the environment at all stages and within all areas of its activity. The joint liability also applies to the chain of supply and co-operation with Suppliers.
      5. The Company endorses the development and improvement of business practices in accordance with this Code. The aim is to co-operate with those Suppliers who understand and share the approach to responsible business conduct and sustainable development, and whose goals align with the values represented by the Company.
      6. In the event of a confirmed violation of this Code by the Supplier, a mitigation and corrective measures plan shall be established in co-operation with the Supplier. In justified cases, the Company reserves the right to suspend co-operation with the Supplier until a noncompliance is remedied or, in extreme cases, to cease co-operation if the Supplier decides that adherence to the provisions of this Code is impossible, and its activities contradict the Company’s values.
      7. The Company reserves the right to monitor and conduct compliance audits of Suppliers to verify whether the requirements included herein are observed. The Supplier is obligated to co-operate by providing necessary information, as indicated by the Company, enabling access to particular individuals, documentation or rooms, thus facilitating conducting a thorough audit.
      8. The Supplier is obligated to ensure that the rules stipulated herein are observed by all entities in its supply chain, to carry out audits of its supply chain at the Company’s request and in the scope specified by the Company, as well as to share the results of such audits with the Company. Any instances of noncompliance by the Supplier or its supply chain must be corrected effectively within appropriate time, ensuring that the Company or its clients do not incur any additional costs.
    2. Areas of business activity regulated by the Code of Conduct for Suppliers
      1. Observance of human rights
        1. The Supplier shall not tolerate discrimination on the grounds of sex, age, ethnic background, nationality, religion, disability, political beliefs or sexual orientation;
        2. The Supplier acknowledges the right to unionise and the right to enter into collective labour agreements;
        3. The Supplier ensures that human rights are observed in its operations;
        4. The Supplier shall not employ any individuals below the age of completion of compulsory education or under the age of 15, unless permitted by local regulations and in accordance with the acts issued by the International Labour Organization;
        5. The Supplier ensures that working conditions, working hours, remuneration and bonuses comply with national and local legislation and applied International Labour Organization conventions;
        6. The Supplier does not allow any practices which limit Employees’ mobility rights. These include withholding identity cards, passports or work permits as a condition of employment;
        7. In the scope imposed by legal regulations, the Supplier shall not limit Employees’ rights to report infringements. It ensures that whistleblowers are anonymous, receive feedback and are protected against retaliation;
        8. The Supplier shall not use any form of contemporary slavery or forced labour and shall allow its employees to freely terminate an employment relationship in accordance with applicable legal regulations;
        9. The Supplier ensures that overtime occurs only when absolutely necessary and when permitted under local legislation.
      2. Ensuring proper and non-discriminatory working conditions:
        1. The Supplier abides by all the provisions of the labour code applicable to the Supplier’s country of origin and type of activity;
        2. The Supplier does not accept any form of mobbing in the workplace;
        3. The Supplier ensures equal access to working conditions irrespective of the form of employment as permitted by legal regulations;
        4. The Supplier manages its Employees and workplace in a responsible manner, ensuring personnel safety at the workplace;
        5. The Supplier treats all its Employees with honesty, respect and dignity irrespective of their sex, age, religion, sexual orientation, education, nationality, world view, political beliefs, disabilities or held office;
        6. If, during the implementation of a task, the Employees need to be provided with accommodation, the Supplier ensures that the living and housing conditions are safe and sanitary.
      3. Anti-corruption measures:
        1. The Supplier counteracts any forms of corruption within its organisation;
        2. If any instances of corruption are identified, the Supplier introduces corrective and preventive measures.
      4. Conflict of interest:
        1. The Supplier avoids any situations in which, during co-operation with the Company, there might be a conflict or overlap of personal and professional interests;
        2. The Supplier informs the Company of any information on a conflict of interest or situations which might pose a conflict of interest.
      5. Fair competition:
        1. The Supplier is obligated to abide by national and international competition law and not to partake in price fixing or division of market or customers.
        2. The Supplier is obligated to respect intellectual property.
      6. Hospitality and gifts:
        1. The Supplier shall not propose or accept any forms of hospitality or gifts which might have an improper impact on the Company’s or Supplier’s business decisions;
        2. The Supplier complies with the Company’s policy regarding hospitality and gifts;
      7. Tax fairness:
        1. The Supplier is obligated to pay all due taxes on transactions arising from the co-operation with the Company;
        2. The Supplier shall purchase goods and services from entities which guarantee that the value-added tax indicated in invoices is reported and paid in accordance with the provisions of the fiscal law.
      8. Prevention of money laundering and terrorist financing:
        1. The Supplier observes binding legal provisions regarding the prevention of money laundering. The Supplier pays close attention to any suspicious transactions and entities which refrain from disclosing credible information willingly. The Supplier does not accept, enable or condone any activities which constitute money laundering or terrorist financing.
      9. Sanctions:
        1. The Supplier undertakes to disclose to the Company its real beneficiaries and any entities with whom it co-operates;
        2. The Supplier acknowledges that the Company does not tolerate any co-operation with partners from the list of sanctioned entities or those having their affiliates in countries targeted by international sanctions;
      10. Ethical standards of business activity:
        1. The Supplier applies the rules of ethical conduct in each area of its operation;
        2. The Supplier implements the solutions which build and raise the awareness of the rules of ethical conduct among its Employees, Associates, and senior management.
      11. Environmental impact management:
        1. The Supplier observes all binding regulations and other requirements regarding the impact of its activity on the environment;
        2. Within the scope imposed by binding regulations, including European law, the Supplier assesses its activity regarding potential negative impact on the environment and strives to prevent that negative impact.
      12. Acquisition and use of resources:
        1. The Supplier strives to acquire resources and take environmental criteria into account when making business decisions;
        2. The Supplier aims to reduce the use of and, above all, reasonably maintain natural resources, including water.
      13. Responsible management of the impact of business activity on society and the environment:
        1. Within the scope imposed by binding regulations, including EU laws, the Supplier undertakes measures aiming to specify the goals of responsible business and sustainable development, whether in the form of a policy, strategy, declaration or any other document.
      14. Minimization of pollutant emissions into the environment:
        1. The Supplier guarantees that the methods of pollutant emission (to air, water and soil) management ensure that the emissions are constantly monitored and minimized, and the management processes are constantly improved;
        2. The Supplier aims to limit negative impact on the climate and the environment by implementing effective preventive measures whose scope corresponds to the scale and type of its business activity.
        3. The Supplier measures and monitors the emissions of the greenhouse gases (scopes 1, 2, 3) produced during its operation;
        4. The Supplier shares data on carbon footprint emissions of products delivered to the Company.
      15. Responsible waste management:
        1. The Supplier complies with the waste management regulations;
        2. The Supplier strives to minimize the production of waste connected with its business activity;
        3. The Supplier maintains proper waste management by promoting the circular economy;
        4. The Supplier maintains proper waste management, including co-operation with an authorised waste disposal contractor to minimize the risk of negative impact waste might have on the environment.
      16. Procedure regarding hazardous material:
        1. The Supplier who uses substances (materials, preparations, and products) classified as hazardous to the environment ensures their safe procurement, labelling, handling, transportation, storage and disposal, and complies with information disclosure obligations.
      17. Safety at workplace and Employee health:
        1. The Supplier observes all regulations regarding occupational health and safety applicable to the country and type of its business activity;
        2. The Supplier abides by the Company’s guidelines regarding the OHS management system;
        3. The Supplier ensures safe and healthy working conditions by managing OHS and implementing procedures, solutions and practices whose aim is to eradicate work-related accidents and to avoid work-related injuries and illnesses among the Employees;
        4. The Supplier aims to set safety goals of minimizing hazards; monitors, analyses and documents the implementation of those goals and aims to improve safety at work;
        5. The Supplier declares that its workplace is free of harassment, violence, corporal punishment, mental or physical duress, verbal or sexual abuse, threats of violence as a disciplinary action or such means of control as withholding Employees’ identity cards, passports, work permits or collecting deposits as a condition of employment.
      18. Confidentiality:
        1. The Supplier maintains protection of confidential information it was entrusted with by the Company, its clients or any other individuals.
      19. Data protection:
        1. The Supplier ensures that all activities regarding personal data (including data collection, recording, storing and deleting) comply with binding legal provisions.
    3. If any infringement or misconduct regarding the matters stipulated in Section 4.2 hereof is identified, the Supplier shall inform the Company thereof and apply appropriate preventive and corrective measures.
    4. Reporting misconduct
      1. Any misconduct related to the Regulations might be reported via a dedicated platform used to report concerns, questions or doubts relating to the company’s negative impact on its surroundings. The platform is available at: https://onde.pl/pl/dialog/.
      2. This procedure allows for reporting information regarding misconduct, complaints or concerns, and for expressing doubts and asking questions regarding the Company’s activities.
      3. A report should include:
        1. date;
        2. data of an individual who files a report; it is possible to file a report anonymously, yet such an individual will not be informed of the actions undertaken in a given matter.
        3. e-mail address or phone number used for feedback;
        4. area the information/report concerns;
        5. data of individuals the report concerns;
        6. approximate date of the incident outlined in the report;
        7. description of misconduct including:
          1. detailed description of the case with all important facts;
          2. information on how the reporting individual learnt about the case;
          3. potential information on individuals whom the reporting individual contacted as regards that matter.
    5. Final provisions
      1. Entering into an agreement with the Company or placing an order by the Company means that the Supplier must carry out the commissioned task in accordance with the provisions stipulated herein.
    6. Organisational provisions
      1. A Compliance Officer is the highest position in the organisation responsible for the implementation of the Code.
      2. This Code shall be reviewed at least once every two years. If no update is needed, its contents remain unchanged.
      3. The Code is shared with the Employees in a manner adopted by the Company.
      4. Failure to conform to this Code will lead to disciplinary action.
  1. Code archiving:
    • The Board is liable for the archiving of this Code.
  2. Changes
    • The Board is authorised to introduce changes hereto.
  3. Related documents and attachments
    • Not applicable
  4. Introduced changes
    • Not applicable
  5. Withdrawn editions
    • Not applicable



Anti-corruption policy of IDE Projekt Sp. Z o.o.

  1. Purpose of the Policy
    1. This Policy outlines the standards of conduct applied by IDE PROJEKT sp. z o.o., its employees and associates regarding the prevention of corruption and a conflict of interest.
    2. Its aim is to ensure transparency of the Company’s actions towards its stakeholders and to prevent corrupt conduct by individuals acting on behalf of or for the benefit of IDE PROJEKT sp. z o.o., and additionally to:
      1. shape employees’ and associates’ awareness regarding the identification of corruption or a conflict of interest, as well as prevention thereof,
      2. specify the methods of reporting suspected corrupt conduct,
      3. specify the rules of avoiding a conflict of interest,
      4. specify transparent rules of giving and receiving gifts in the Company.
    3. This Policy supplements binding legislation regarding anti-corruption practices and the provisions of the Company’s Code of Ethics. The provisions included herein are inspired by international conventions, particularly by: The United Nations Convention against Corruption, adopted by the United Nations General Assembly on 31 October 2003, and the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, signed in Paris on 17 December 1997.
  1. Scope of application:
    1. This Policy applies to all the Company’s employees and associates.
    2. The observance of its provisions will be monitored regularly, whereas any corrective actions deemed necessary will be immediately specified and implemented.
  1. Definitions and abbreviations:
    1. The terms used herein shall have the following meaning:
      1. ‘Company’ – IDE Projekt sp. z o.o., with its main office in Toruń,
      2. ‘Employee’ – an individual performing work or providing services to the Company, irrespective of the basis of establishing an employee relationship, including an individual employed under a civil-law contract. To avoid any doubts, the Employee shall also mean any individual who performs work or provides services to the Company in the value chain, regardless of the existence or form of a contractual relationship with the Company, i.e., employees/associates of suppliers, subcontractors, and other business partners.
      3. ‘Policy’ – this Anti-corruption Policy.
      4. ‘Financial benefit’ – a material benefit which can be expressed in pecuniary terms, obtained through corrupt activities, in particular, ones that are unlawful or contrary to ethical standards and good practices; also includes benefits to a third party.
      5. ‘Personal benefit’ – a non-material benefit improving a recipient’s or third party’s situation, obtained through corrupt activities, in particular, ones that are unlawful or contrary to ethical standards and good practices; includes a promise of promotion or expedition of a matter.
      6. ‘Corruption’ – promising, offering, giving, demanding and accepting, both directly and indirectly, of any Financial benefit, Personal benefit or any other benefit by any person, for themselves or any third party, or accepting proposals or promises of such actions in exchange for acting or refraining from acting in performing one’s public, professional or employment duties.
  1. Description of the procedure/contents of the document:
    1. General provisions
      1. By accepting this Policy, the Board declares that it will not tolerate any form of Corruption and expresses its belief that any Corrupt conduct hinders economic development, violates rules of competition, lowers the safety and quality of services and poses a threat to the interests and reputation of both the Company and its stakeholders.
      2. The Company conducts its business activities responsibly and transparently, as well as with respect for ethical standards. The Company does not tolerate or accept any Corruption, whether in its internal or external relations.
    2. Employees’, Senior management’s and Company’s obligations to prevent Corruption
      1. The Employees are obligated to take any necessary measures to combat Corruption. In particular, the Employees are obligated:
        1. not to accept Personal or Financial benefits, or any promise thereof, nor to make the performance of their professional duties conditional upon receiving Personal or Financial benefits,
        2. not to accept Personal or Financial benefits, or any promise thereof, nor to demand them in return for abuse of their authority or non-performance of duties,
        3. not to grant Personal or Financial benefits to any individual due to their public role, nor to undertake any activities whose purpose is to persuade that individual to violate legal regulations or to make promises of granting Personal or Financial benefits in return for violating legal regulations,
        4. not to invoke Company’s influence and position, nor to create an impression in another individual of Company’s influence with an aim of acting as an intermediary in handling a matter in exchange for receiving Personal or Financial benefits, or a promise thereof,
        5. not to grant or promise Personal or Financial benefits in exchange for acting as an intermediary in handling a matter in a state or local government institution, national or multinational organisation, or a domestic or foreign organisational unit with access to public finances, including State Treasury-controlled companies, by unlawfully influencing a decision, action or omission of an individual holding a public office in relation to their role,
        6. not to commit any activity against the Company’s assets which contradicts the provisions of law, internal regulations or ethical standards, including, in particular, theft, appropriation, and destruction and damage to property,
        7. to familiarise themselves with this Policy, to observe its provisions, and to immediately report any violations of this Policy pursuant to the provisions of Article 4.6. hereinbelow.
      2. In the event an Employee receives a corrupt proposal from any entity or individual, they are obligated to immediately refuse such a proposal and to inform their Superior, a Compliance Officer or a Board Member thereof.
      3. Heads and Managers of organisational units are obligated to take any and all actions necessary to ensure that the provisions of this Policy are followed, in particular, to familiarise all their Employees with the anti-corruption practices stipulated herein and to supervise their observance by their Employees.
      4. Heads and Managers of organisational units are obligated to adopt ethical attitudes which ensure that the goals of the Policy are achieved.
      5. The Company is obligated to exercise due care in order to maintain transparent relations with third parties so as to exclude any opportunities for Corruption.
      6. The Company takes measures to include clauses in its agreements with contractors which prohibit Corrupt activities, particularly stating that no part of the remuneration arising from an agreement shall be allocated to cover the costs of providing Financial benefits and/or Personal benefits.
      7. The Company carries out a verification and acceptance of costs and expenses, and maintains transparent co-operation with third parties to prevent any mechanisms of offering Financial benefits by using the Company’s assets.
    3. Corrupt conduct
      1. Below are the most prevalent and easiest to identify forms of conduct which might be considered corrupt:
        1. bribery, including its two forms – passive bribery, i.e., solicitation, coercion, consent to receive benefits and acceptance of benefits; active bribery, i.e., offering, promising or giving benefits;
        2. using the Company’s funds and assets for private purposes or personal benefits,
        3. Paid protection/influence peddling – understood as referring to one’s influence within an institution having access to public funds or claiming to have influence or asserting somebody of having influence, including offering (active paid protection) or seeking (passive paid protection) intermediation in handling a matter in exchange for a financial or personal benefit, or a promise thereof,
        4. irregularities regarding public procurement procedure (bid manipulation), winning contracts, obtaining concessions, permits, decisions issued by courts or public administration bodies,
        5. deliberate and unlawful management of public funds,
        6. favouritism, nepotism, cronyism and other unlawful practices in employee relations.
      2. Corrupt conduct might take other forms, however, it is essential to be able to identify which behaviours should raise suspicions.
    4. Areas particularly susceptible to corruption
      1. Employees, particularly heads of the Company’s organisational units, are obligated to an ongoing identification of corruption risks within the scope of their activities, thorough and regular internal audits, ensuring transparency of processes and actions as regards preventing corruption, and promoting ethical conduct among the Employees.
      2. The following areas are particularly susceptible to corruption:
        1. Giving and receiving business gifts and any other material and non-material benefits to develop and foster business relations;
        2. Selecting suppliers of goods and service providers;
        3. Preparing and partaking in public tenders;
        4. Incurring liabilities and making purchases on behalf of and for the Company;
        5. Entering into contracts which are vital due to their nature, terms and conditions or a party with whom a contract is entered into;
        6. Making payments on behalf of the Company;
        7. Maintaining relations with business partners, including suppliers;
        8. Obtaining permits and positive decisions of national officials;
        9. Inspections carried out by national institutions and regulatory authorities;
        10. External audits.
    5. Gifts and hospitality
      1. The Company admits that gifts and invitations might have a positive influence on establishing and fostering business relations, yet they should not be considered the primary means of establishing and maintaining positive business relations and giving and receiving thereof shall comply with the limitations imposed by this Policy. The Company does not tolerate excessive gifts or forms of hospitality.
      2. Prior to giving or receiving a gift or an invitation, an Employee shall ascertain that the nature of their actions and the value of a gift or an invitation do not contradict the provisions hereof.
      3. A gift is understood as any material or non-material thing which has pecuniary value and for which a recipient does not pay.
      4. Giving or receiving of a gift or an invitation shall not violate the rules outlined below:
        1. The value of a gift or an invitation shall not exceed 200 zlotys (gift of ‘insignificant value’),
        2. A gift shall not take the form of cash or its equivalent (e.g., shares, vouchers, coupons, prepaid payment cards),
        3. A gift or an invitation does not mean that the giver expects anything in return; they are particularly not given when expecting a decision which is positive for the giver (e.g., choice of offer, conclusion of a contract),
        4. A gift or an invitation is not given upon an Employee’s demand,
        5. Giving or receiving of a gift or an invitation cannot damage the Company’s good name or reputation,
        6. A gift or an invitation shall be given only to an Employee and not to their close families or any third parties.
      5. An Employee who gives or receives a gift or an invitation whose value exceeds 200 zlotys is obligated to report this to their superior or to receive a superior’s consent to keep or give a gift or an invitation and to file such a gift into the Register of Benefits, kept by a Compliance Officer.
      6. In the event of any doubts regarding the nature of a gift or an invitation, or the giver’s intentions behind giving a gift or an invitation, it is necessary to contact a Compliance Officer, a Superior or the Legal Department.
      7. Gifts or invitations which do not conform to the Policy and which were received against an Employee’s will might be disposed of or transferred to the Eryk Grzeszczak’s ‘ERBUD – Common Challenges’ Foundation.
      8. The Company’s Employees cannot promise or give public officers any financial amounts or other goods, irrespective of their value, in exchange for handling matters or favouring the Company’s interests. The aforesaid does not apply to small gifts given during presentations, parties and other events organised by the Company.
    6. Avoiding conflict of interest
      1. A conflict of interest is understood as a situation in which an Employee or a member of the Company’s governing body takes decisions or deliberate actions on behalf of the Company in a manner that provides or might provide benefits (both financial or personal) to themselves or affiliated individuals. This also includes situations in which the interests of an Employee or a member of the Company’s governing body impact or might impact their judgment, decision-making or performance of duties.
      2. The Company undertakes actions to identify and avoid conflicts of interest, and in the event any conflicts of interest are identified, to handle them appropriately.
    7. Conflict of interest areas
      1. A conflict of interest might appear between:
        1. Company’s business partners and an Employee, particularly when:
          1. An Employee might make a gain or avoid a loss due to a Company’s business partner making a loss or not making a gain if related to a contract between a business partner and the Company;
          2. An Employee has financial or personal grounds to treat a given business partner with preference;
          3. An Employee gives or receives a financial benefit whose aim is to influence the recipient’s decisions and which invokes or might invoke a recipient’s sense of obligation;
        2. An Employee and the Company, particularly when:
          1. an Employee’s activity outside the Company cannot be reconciled with their activity in the Company’s interest. In particular, a conflict of interest might stem from a business, professional and political activity, employment of affiliated individuals, as well as from using the Company’s business potential and information, know-how and experience gained while working for the Company in a manner which damages the Company;
          2. While acting in their name, an Employee makes a gain or avoids a loss by utilising knowledge and tools provided by the Company and causes a loss or failure to make a gain by the Company;
        3. Company’s business partners, particularly when contracts or investments of two business partners have contradicting goals.
    8. Duties of Employees and members of bodies
      1. In order to minimise the risk of conflicts of interest, Employees are obligated to:
        1. identify conflicts of interest and avoid them while performing their professional duties;
        2. report an identified conflict of interest to their superiors, who might decide that the Company’s Board or a Compliance Officer must be informed thereof;
        3. refrain from taking actions which might lead to a conflict of interest between the Company and such Employees, particularly when a conflict of interest leads to obtaining personal benefits or engaging in activities which are competitive to the Company;
        4. ensure that their personal interests do not interfere with their duties to the Company or with the Company’s duties to its clients or business partners;
        5. be loyal to the Company in their actions and to take decisions which align with the Company’s interests;
        6. when engaged in a decision-making procedure, not to exert unlawful influence on entities which are considered for an investment or on any individuals related to that entity;
        7. familiarise themselves with and observe binding procedures on conflict of interest management and take part in training organised by the Company;
        8. if in doubt, act in accordance with the provisions hereof.
    9. Means of conflict of interest management
      1. To each identified type of conflict, the Company applies an adjusted solution whose aim is to manage and monitor a conflict and to prevent possible adverse impact a conflict might have on the Company and its surroundings. In particular, the aforesaid might include an Employee’s obligation to:
        1. special surveillance – to ensure rational conflict of interest management, the Company might introduce non-standard monitoring and special surveillance over a co-operation with one or more co-operating parties;
        2. refrain from engaging in professional duties related to a specific contract, project or order. A member of the Company’s Board who supervises a particular area of activity is liable for deciding on transferring professional duties related to the provision of services.
    10. Reporting infringements
      1. In the event of an event which violates this Policy, a suspicion that such an event might have occurred or might, with high probability, occur, an Employee is obligated to inform the Company thereof via dedicated channels.
      2. A report can be submitted via the following channels for reporting misconduct. These channels were created and are managed in a manner which ensures Whistleblowers’ protection and anonymity of the Individual whom the report concerns:
        • Via e-mail, at: naruszenia@onde.pl; if a report concerns a Board Member, at: radanaruszenia@onde.pl; if a report concerns a Compliance Officer, at: zarzadnaruszenia@onde.pl.
        • Via letter, at: ONDE S.A. Wapienna 40, 87-100 Toruń; reports submitted in that manner should contain an inscription on the envelope saying ‘Report on violation of law – deliver personally to a Compliance Officer’; if a report concerns a Board Member: ‘Report on violation of law – deliver personally to a Supervisory Board Member’; and if a report concerns a Compliance Officer: ‘Report on violation of law – deliver personally to the Board Chair’.
        • In person or via telephone to an Individual receiving the reports, phone no.: 539-092-510.
    11. Final provisions
      1. A Compliance Officer is the highest position in the organisation responsible for the implementation of the Policy.
      2. This Policy shall be reviewed at least once every two years. If no update is needed, its contents remain unchanged.
      3. An Employee’s failure to observe the rules set out herein shall constitute an infringement of basic employee duties.
      4. The Policy is shared with the Employees in a manner adopted by the Company.
      5. Any violation of this Policy by a Business partner might result in termination of a co-operation with a Business partner who acted in contravention of the principles stipulated herein.
  2. Policy archiving:
    • The Board is liable for the archiving of this Policy.
  3. Changes
    • The Board is authorised to introduce changes hereto.
  1. Related documents and attachments
    • Attachment 1 – Template of the Register of Benefits.
    • Code of Ethics
  2. Introduced changes
    • Not applicable.
  1. Withdrawn editions
    • Not applicable
  2. Attachment 1 – Template of the Register of Benefits.

TEMPLATE OF THE REGISTER OF BENEFITS

No.Date of making entry

Data on entity where incident took place IN WHICH COMPANY?Data on individual who gave or received benefit WHO?Data on entity to whom benefit was given or from whom it was received TO WHOM? FROM WHOM?Date of giving or receiving of benefit WHEN?Description of benefit, including estimated value WHAT? HOW MUCH?Description of circumstances of giving or receiving benefit HOW? WHERE?Decision on handling of received benefit WHAT NOW?Data on individual making entryRemarks






















































































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