Code of conduct

  

CODE

OF CONDUCT

PRINCIPLES OF THE CODE OF CONDUCT

INTRODUCTION

The company of SPRING – WAD Roman Książek enjoys the opinion of a trusted company, because it consequently cares for its operations shall be carried out in a fair manner, in compliance with the law and the binding regulations. A success in running a business depends on winning and maintaining of the Client’s trust, as well as the one of the employees, administration and public opinion.

GENERAL PRINCIPLES

The Company of SPRING-WAD Roman Książek.

– respects the law and regulations of every state, in which it operates,

– it implements the rules of the Code in the key processes, decisions and actions.



REQUIREMENTS TOWARDS BUSINESS PARTNERS

The Company of SPRING-WAD Roman Książek prefers to cooperate with suppliers, consultants, distributors and other business partners that also follow the principles described in the Code of Conduct. The Company encourages its business partners to apply the norms of conduct convergent with the rules of the Code.

PRINCIPLES OF RUNNING THE BUSINESS ACTIVITY

ACCOUNTING AND REPORTING

All financial transactions must be reported in accordance with the generally adopted accounting principles, whereas in the accounting documents every transaction has to be described in a proper manner and not misleading, as to its character. The Company of SPRING – WAD Roman Książek presents its reports in a transparent, compliant with the truth manner and punctually, so as they present a true picture of its situation.


CORRUPTION

The Company of SPRING – WAD Roman Książek does not participate in any corruption practices or supports thereof.

Representatives of the Company of SPRING – WAD Roman Książek may not offer the present and potential Clients, suppliers, consultants, governments, government bodies or representatives any awards or benefits that would be an infringement of the binding law and generally accepted, stricter than the binding law, rules of conduct in business, in order to obtain or maintain a contract or winning of other undeserved advantage.

The employees of the company of SPRING – WAD Roman Książek may not accept from a third party any financial benefits, gifts or other type of remunerations, which could really or apparently influence the objectivity of the decisions taken.



CONFLICT OF INTERESTS

All representatives of the Company of SPRING – WAD Roman Książek shall carry out their private activity and any other external activity, as well as financial issues in a way not rising suspicions of occurrence of a conflict with the interest of the company of SPRING – WAD. Private interests of the employees may not influence their decisions or actions undertaken during fulfilling of the role of the Company representative nor arise such suspicions.



THE COMPANY’S RESOURCES AND ASSETS

The Company of SPRING – WAD Roman Książek resources and assets may be used only for the business purposes. The company’s resources and assets may not be used in order to gain personal benefits, for dishonest purposes or in any other improper way.



TAXATION

The company of SPRING – WAD Roman Książek respects the law and tax provisions of every country, where it operates. If the tax provisions do not provide a clear interpretation of conducts, than one shall observe the principles of prudence and financial transparency.



OFFER FOR CUSTOMERS

The company of SPRING – WAD Roman Książek cares so that its products meet all the binding requirements.

The company designs products and provides services, emphasizing the most important values such as: quality, safety and care for the natural environment.



MARKETING AND SALES

The company of SPRING – WAD Roman Książek reliably presents its products and services, while fulfilling all the requirements arising from the binding law and regulations. The company of SPRING – WAD Roman Książek does not make false declarations nor provides misleading information concerning its products or its parameters, including the attributes in the scope of safety and environment protection.



FAIR COMPETITION

The company of SPRING - WAD competes in a fair manner. It does not exchange information nor concludes agreements or arrangements with the competitors, clients or suppliers in a way that would improperly influence the market or tender procedure result. The company SPRING - WAD gathers information about competitors only via legal methods.



ILLEGAL SECURITIES TURNOVER

SPRING - WAD employees, who have access to publicly unknown information that may influence the Company’s debentures rate, may not buy or sell the company of SPRING - WAD debentures and any other financial instruments related with SPRING -WAD debentures. Additionally, such persons may not induce anyone else, giving them advice or in other way, to purchase / sell of these debentures and instruments.



POLITICAL INVOLVEMENT

The company of SPRING – WAD Roman Książek is neutral in relation to political parties and candidates running for a public office. Neither the name nor property of the companies being a part of the company of SPRING – WAD may be used in order to promote the interests of political parties or the candidates running for a public office.

PRINCIPLES OF THE HUMAN RIGHTS AND SOCIAL JUSTNESS

HUMAN RIGHTS

The company of SPRING – WAD supports and respects the rule ordering protection of the human rights recognized by the international community and ensures a lack of participation in the acts constituting a violation of the human rights.



NON-DISCRIMINATION OF EMPLOYEES

All employees have equal chances adequate to their competencies, experience and results and regardless of sex, race, religion, age, disability, sexual orientation, nationality, political views, membership in labour unions, social or ethnic origin.

All employees are treated with respect. Discrimination, physical or verbal abuse will not be tolerated nor any punishable threats.



CONDITIONS AT THE WORK PLACE

The company of SPRING - WAD ensures all the employees work conditions are compliant with the safety and work hygiene principles.



FORCED LABOUR

The company of SPRING - WAD does not engage in any practices of forced labour, obligatory or slave, and does not derive benefits thereof and it does not demand from employees any money deposit or keeping identity cards.

The employees may, of their own volition, resign from the employment on the condition of filing of a notice on the date and by the method stipulated by the regulations and the concluded agreement.



CHILD WORK

Child work will not be tolerated. Persons that due to their age are subject to school obligation, may not be employed, and in any way children of less than 15 years of age.



FREEDOM OF ASSOCIATIONS

The company of SPRING – WAD Roman Książek respects the right of all its employees to joint associations representing their interest as employees, organizing themselves and negotiating of collective agreements and individual ones. The company respects the recognized labour unions. At the same time the employee right not to join any labour union is respected.



PRINCIPLES OF THE CODE OF CONDUCT

The company of SPRING - WAD informs employee representatives and competent public administration bodies about major changes in its operations in the scope required by the law.



WORKING HOURS AND REMUNERATION

The company SPRING – WAD Roman Książek respects the binding law, agreements and the adopted customs concerning the working hours and remuneration.

ENVIRONMENTAL PRINCIPLES

EFFECTIVE USE OF RESOURCES

The products and processes of the company of SPRING – WAD Roman Książek are designed in the way ensuring effective consumption of energy, natural sources and raw materials as well as minimizing of waste and by-products.



PREVENTION PRINCIPLE

The company of SPRING - WAD avoids materials and methods being a source of risk to the natural environment and health, when there are available possible to use alternative solutions.



REACH – Statement

SPRING – WAD Roman Książek while observing the obligations arising from the contents of the European Parliament and Council Regulation No. 1907/2006 of 18.12.2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), carries out the assessment of the substances and chemicals in the goods. In order to guarantee a high level of safety of our products, we supervise meeting of the REACH requirements by our suppliers.

We draw a particular attention to assessment of the potential risk related with the existing and future substances and running the operations in such a way so as it would damage the environment as little as possible.



RESPONSIBILITY FOR COMPLIANCE

The management officers in the company of SPRING – WAD Roman Książek are obliged to implement the principles and inform their employees about the rights, obligations and liabilities and to care about that in the subordinated organisation units they shall proceed in accordance with both the contents and the spirit of the document. The employees are obliged to observe the local law and principles of the company of SPRING - WAD. Overt or covert acceptance of the deeds that are contradictory with the Code, will not be tolerated and may lead to undertaking of disciplinary procedure with sanctions, inclusive of dismissal and the court ones.



DEPARTURES

Only the Management Board of the company of SPRING-WAD Roman Książek may consent for departures from these principles.



LANGUAGE

The original version of the document was written in Polish. If the document is translated into other languages, in case of disputes the Polish version shall be prevailing.



REGULAR REVIEW

The document issuer is obliged to ensure that every year it is going to be reviewed.



REPORTING OF THE CASE OF VIOLATING THE CODE OF CONDUCT

All employees of the Company shall report the alleged cases of violating of the Code of Conduct to their direct supervisors or the supervisors of their supervisors. If such a report will not be treated seriously or it is awkward for the employee to report such issue to his / her supervisor, he / she shall notify the higher level of competence about the matter, pursuant to the adequate procedure of reporting irregularities.

Also anonymous reporting of infringement of the principles included in the Code is allowed, by placing of the information in the open-access reporting boxes. The reports placed in the boxes will be considered directly by the Management Board of the Company.

Prepared by                                                                                            Approved by

Wojciech Odrobina                                                                               Roman Książek

 

Prepared 12.05.2022

rev.01