Social Responsibility

CODE OF ETHICS OF ETILAB SP. Z O.O.

1. INTRODUCTION

Nowadays, running a company is a huge ethical commitment. An obligation to shape responsible and ethical patterns of behaviour. ETILAB wishes to join the world's leading companies in terms of business responsibility, respect for human rights and environmental protection. The responsibility for achieving this goal rests with all Employees of Etilab Sp. z o.o., regardless of their position or seniority.

We expect our customers, suppliers, subcontractors, temporary employees and other third parties with whom we work to apply the principles of this Code or to develop similar standards of their own.

ETILAB is convinced of the importance of complying with applicable regulations, legislation and acting in accordance with the ethical standards it has set for itself as part of its business practices.

The Code reflects the ethical values ETILAB upholds and wishes to uphold. It provides ETILAB Employees with a benchmark of behaviour towards colleagues, superiors and customers, partners and local communities, both in business and non-business relations.

This Code is disseminated and popularised through the actions of ETILAB's Management Board and Human Resources Department.

2. OUR VALUES

Commitment to the highest labour standards

We are convinced that the foundation of running a modern and stable company is people. Together, we create the workplace. As a company, we respect and comply with international human rights and international labour standards, treating them as fundamental and universal.

Customer relations

The most important principles of our company in customer relations are: responsibility for the success of our customers and respect and openness to their needs. We provide our clients with the highest quality product, which is the result of people with unique competencies skills and experience. We cooperate with leading research and scientific centres both in Poland and abroad. We make every effort to ensure that the product delivered meets the highest standards and expectations of our customers.

Ecological awareness

We draw on the natural resources that are our common heritage, keeping in mind to minimise our negative impact on the environment. We also promote a green lifestyle among our employees and business partners. Caring for the environment is one of the most important criteria of Etilab Sp. z o.o.'s social responsibility.

Effective management

We want to effectively manage all the company's activities in order to best meet the expectations of our partners. We have implemented a quality, health and safety and information security management system. Applying the principles contained therein contributes to increasing trust between the company and its customers and suppliers. It also strengthens our image in the eyes of all those interested in the effects of our company's activities in the areas of the quality of our products and services, environmental impact, ensuring occupational health and safety, as well as information security and personal data protection.

Relationships based on transparent principles

Our priority is to build relationships with partners that are based on fair competition principles. Our decisions have a business justification. We apply the principle of transparency in the selection of subcontractors and suppliers.

Relations with public sector entities

We attach importance to good relations with the local authorities where we operate.

3. WHAT IS THE CODE OF ETHICS AND TO WHOM IS IT ADDRESSED?

This Code of Ethics has been created to define the types of behaviour unacceptable to ETILAB and to describe how to behave in situations where a particular decision may raise ethical dilemmas. It provides guidance on the conduct of day-to-day interpersonal collaboration and cooperation with other entities. No document can anticipate all eventualities in which ethical issues may arise. This Code has been created to help resolve such dilemmas and to create mechanisms to provide answers. This document incorporates the Company's ethics, anti-discrimination and anti-corruption policies, as well as rules on reporting violations and irregularities, non-compliance with legal obligations, risks to health and safety at work, health of customers and bystanders, environmental safety, unfair competition practices and attempts to cover up any of the above. It provides opportunities for all employees, regardless of their position, to report problems at a high level and to protect themselves from possible reprisals from their superiors.

4. HOW DO YOU RECOGNISE UNETHICAL BEHAVIOUR OR AN ETHICAL DILEMMA?

Answer some of the following questions:

1) Am I being treated equally with other colleagues?

2) Am I made uncomfortable by the actions of other co-workers?

3) Do I act in accordance with generally accepted moral standards?

4) Do I get assigned tasks by my supervisor that violate work discipline?

5) Have I witnessed or have I myself been involved in corrupt situations?

6) Are my actions or those of my colleagues legal, fair and honest?

7) How would this problem look if it were publicised in the media?

8) How would I feel if my family and friends found out about my actions?

5. TO WHOM SHOULD I ADDRESS MY QUESTIONS AND CONCERNS?

If you have questions or concerns, the first person to contact is your supervisor. If you feel you cannot speak to your supervisor or do not know where to go for help, you can contact the Ethics Officer by email etyka@etilab.pl or by phone: 607 640 612.

You can also seek advice from an expert, such as Human Resources, Legal or Health and Safety.

6. WORKPLACE RELATIONS

Respect for others

Regardless of their position, all employees, co-workers and partners have the right to be respected, to have their personal dignity respected and to have their privacy and the privacy of their family life protected.

Diversity and tolerance

We are convinced that the foundation of running a modern and stable company is people. Together, we create the workplace. As a company, we respect and comply with international human rights standards and international labour standards, treating them as fundamental and universal. We respect the prohibition of discrimination on the basis of: race, social status, ethnic origin, religion, disability, gender, sexual orientation, union or political affiliation, age or marital status. We guarantee freedom of opinion, conscience and religion and freedom of belief and expression. The ETILAB Company is a place free from any practice that insults the dignity of another person. It is forbidden to discriminate, judge, mock others on the basis of their sex, race, disability, nationality, origin, sexual orientation, age, religion, political and philosophical beliefs, financial situation or cultural difference. Any form of discrimination, intimidation, bullying or sexual harassment of co-workers is not accepted and will be explicitly stigmatised and combated.

Health and safety at work

Safety has been a priority at ETILAB for many years. We prevent dangerous situations by uncompromisingly applying the Company's internal regulations as well as external regulations in force in Poland. We carry out extensive risk monitoring and apply risk-appropriate prevention so that work is safe. At the same time we require our co-workers, as well as subcontractors and companies cooperating with ETILAB, to comply with the rules in force in the ETILAB Company. The safety of people is a priority at the ETILAB Company. Each employee is obliged to comply with safety and hygiene rules defined by law and internal regulations in force in the ETILAB Company, moreover to inform his/her superiors about perceived threats to safety and hygiene at work and observed irregularities in this scope, including those of subcontractors and suppliers of Etilab Sp. z o.o.

THE EMPLOYEE IS OBLIGED TO TAKE CARE OF THE TANGIBLE AND INTANGIBLE ASSETS OF ETILAB SP. Z O.O., BUT ALSO HAS THE RIGHT TO EXPECT FROM ETILAB SP. Z O.O:

- the provision of optimal health and safety measures,

- support in his personal and professional development (according to his position and the assessments of his superiors),

- a balance between family and professional life,

- respect and protection from discrimination by third parties.

7. REPRESENTING THE COMPANY

Avoiding unethical behaviour

Employees should be guided by integrity and avoid behaviour that would put ETILAB in an unfavourable light. In particular, this means acting in accordance with the principles of social coexistence and respecting the applicable law.

Competitive actions towards Etilab Sp. z o.o.

Employees should refrain from undertaking, on their own or in cooperation with third parties, actions that would be competitive or detrimental to Etilab Sp. z o.o..

Appearing to act on behalf of Etilab Sp. z o.o.

Employees will not create the appearance of acting on behalf of Etilab Sp. z o.o. in order to achieve objectives that are not those of the Company. They will also not invoke their influence in the ETILAB Company for private gain.

Presenting their own opinions as those of Etilab Sp. z o.o.

Employees will strictly avoid presenting opinions that are personal beliefs as the position of Etilab Sp. z o.o., including, for example, publicly engaging in political disputes from the position of the Company's representative and expressing opinions that may carry the appearance of slander.

Protection of information

Each employee undertakes to unconditionally protect confidential information, constituting a company secret, to notify his/her superiors and the Information Security Administrator of any attempt to obtain such information by third parties or of situations in which there is a suspicion of information leakage.

Communication with the media

Communication with the media is the responsibility of ETILAB's Management. An employee must not undertake such contacts on his/her own, without consulting the above-mentioned persons. In the event of attempted contact by the media, he/she should immediately contact the Company's Management.

8. POTENTIAL CONFLICT OF INTEREST

Conflict of interest

All employees must avoid situations in which their personal interests, or the interests of persons with whom they are related or associated, would be in conflict with the interests of the Company or could potentially give rise to a third party suggesting the existence of such a conflict.

Notification of conflicts of interest

If the risk of such a situation arises, the employee must immediately notify his/her immediate superior of the potential conflict.

Resolving doubts

Every employee has the right to expect a clear resolution of his or her doubts about a potential conflict of interest and thus to be relieved of the risk of potential accusations of unethical behaviour. The most important principles of our company in dealing with customers and suppliers are honesty and transparency. We comply with all applicable laws regarding the acceptance of material benefits and corruption.

9. RELATIONS WITH RELATED PARTIES AND EXTERNAL PARTNERS

Transparency of operations and dissemination of ethical principles

All employees, especially those in managerial positions, are obliged to:

- reliably inform their superiors and the Company's Board of Directors of the actual performance of their subordinate unit and the existing risks, including the social and environmental risks involved in their performance and that of their subcontractors,

- disclose to his/her superiors any information in his/her possession that may indicate unethical behaviour on the part of the employees of Etilab Sp. z o.o. and of persons cooperating with the Company ETILAB,

- act in a transparent manner, making it possible to determine the motives behind decisions taken.

10. RELATIONS WITH SUPPLIERS

Employees who are responsible for relations with suppliers are obliged to:

- select suppliers based on objective criteria for evaluating their offers and the quality of their services; ensure that all offers are compared and considered fairly and impartially and that the entire process is appropriately and transparently documented,

- ensure that tender selections are made in an open atmosphere and that unsuccessful tenderers receive a fair, honest and tactful response,

- give suppliers feedback on their performance based on objective, transparent and consistently applied indicators,

- give preference to working with suppliers that honour their commitments, behave ethically, respect the environment, health and safety and human rights, and avoid working with suppliers that do not respect these principles,

- disclose any information in their possession that may affect the Company's cooperation with a supplier, including in terms of possible unethical behaviour on the part of the supplier.

11. CUSTOMER RELATIONS

Employees who participate in the sales processes of Etilab Sp. z o.o. products are obliged to:

- select contractors based on objective criteria,

- not use unethical actions to gain a customer or discredit a competitor,

- not to disclose to third parties any information obtained from a contracting party during negotiations, to respect trade secrets and business secrets,

- treat both strategic customers and smaller customers in the same professional manner,

- take the utmost care to ensure that commercial agreements are implemented,

- develop and deepen the knowledge of Etilab Sp. z o.o. products in order to be able to present the products to customers in a professional way,

- prefer cooperation with contractors who reliably fulfil their obligations, behave in an ethical manner, comply with environmental, safety and human rights regulations, avoid cooperation with suppliers who do not

avoid doing business with suppliers who do not respect these principles,

- disclose to their superiors any information in their possession that may affect the Company's cooperation with a client, including in terms of its possible unethical behaviour.

12. CORRUPT ACTIVITIES

Avoiding ambiguous situations

Avoid any behaviour that could be perceived as an expectation or demand for bribes or other benefits. Refrain from offering or accepting gifts or other extra benefits, favours and acts of hospitality, except for those of symbolic value, the refusal of which could be perceived as an insult and a violation of prevailing cultural norms. Gifts in the form of cash, regardless of amount, should never be given or accepted.

Child and forced labour

The use of child labour, slave labour or any other form of forced labour (i.e. any form of forced labour) by ETILAB and third parties acting on behalf of Etilab Sp. z o.o. is not accepted under any circumstances.

13. LOCAL COMMUNITIES AND THE ENVIRONMENT

We attach importance to good relations with the local governments of the municipalities, towns and cities where we conduct our business. We nurture good relations and maintain a dialogue with local communities based on transparency and respect. We do this on the basis of ETILAB's Sustainable Development Strategy.

Dialogue with the local community

The Company's management is committed to good relations and dialogue with local communities based on transparency and respect for their dignity and rights, including their heritage and traditions.

Minimising the impact on the environment

All employees are required to act in a way that minimises the negative impact on the environment and the local surroundings and to respect all materials, raw materials and energy.

Actions by subcontractors or other employees

Employees are obliged to notify their superiors of potential environmental hazards and of violations of the above principles by other employees or employees of subcontractors.

14. PRINCIPLES OF REPORTING IRREGULARITIES

Whistleblowing

This policy applies to whistleblowing that would constitute a violation of the Code or would constitute:

- irregularities, fraud and abuse,

- non-compliance with obligations arising from laws or statutes in force in the ETILAB Company

- a threat to health and safety at work or to the environment,

- violations of company confidentiality

- criminal activities,

- attempts to conceal any of the above.

Suspected rule-breaking

In the event of suspicion that any of the above rules are being breached or any doubts about potential conflicts of interest or ethical dilemmas, the employee must notify his/her immediate supervisor or, if this is not possible, the Company's Board of Directors (this can be done using e-mail by sending a message to: etyka@etilab.pl)

Reporting irregularities

Disclosure of information about perceived irregularities will be treated as an action to protect the principles of social coexistence and the interests of Etilab Sp. z o.o., and consequently no employee may be held liable or stigmatised in any way for providing information, provided that he or she does so in good faith, recognising that the disclosure of irregularities will help expose misconduct and abuse. Observations of wrongdoing will be investigated by the Company's Board of Directors.

Anonymous reporting of observations of wrongdoing

It is possible to report irregularities anonymously via etyka@etilab.pl, but anonymous reports are always less credible. In deciding whether to investigate a particular report, the Board will take into account factors such as the seriousness of the problem, the credibility of the report and the likelihood of corroboration of the allegations from identified sources.

Any ambiguities or problems related to the interpretation of the content of the Code of Ethics are resolved by the Ethics Officer appointed by the Board. Employees of Etilab Sp. z o.o. are encouraged to submit any comments and modifications related to the content of this Code of Ethics.

The duties of the Ethics Officer include:

- supporting employees in complying with the Code of Ethics,

- promoting the idea of the code within the company,

- updating the content of the Code,

- interpreting the provisions of the Code of Ethics.

15. HOW ARE THE PROVISIONS OF THE CODE IMPLEMENTED AND ENFORCED?

The Code of Ethics has been approved for implementation and enforcement in the Company by the Board of Directors.

16. IF YOU HAVE CONCERNS

You may find answers to your problem here....

My brother is the owner of a company that wants to participate in a tender announced by the Company. Should I admit to a family relationship with a possible future contractor?

Yes. You are obliged to notify your manager of any possible or existing conflict of interest even if, as in this case, you would have no influence on the outcome of the tender.

A regular customer of the Company brings me gifts (e.g. a packet of good coffee, chocolates, wine, a set of company gadgets) in the run-up to Christmas. Can I accept such gifts?

If the gift given, according to the rules of life experience, appears to be symbolic, does not oblige you to reciprocate and does not have any influence on your business decisions, you can accept it without fear.

The workshop servicing our car fleet has offered to service my private car for free. The owner of the workshop knows that I have influence in the company, among other things, when awarding tenders, but the next tender is still many months away. Can I take up the offer of free repairs at the garage?

No. It does not matter that the next tender has not yet been issued. As a person with influence on the outcome of tenders, you must not accept any benefits that could oblige you to reciprocate or distort the criterion of impartiality in future decisions. In the situation you describe, there is a potential conflict of interest.

My son is graduating from college soon. Can I print his thesis on a company printer so that he doesn't have to spend money at the print shop?

No. It is unethical to use Company property for nonbusiness purposes. It is not allowed to both print private materials, to use company funds for private purposes or to take home Etilab Sp. z o.o. property such as office supplies.

I have a lot of work to do. The weekend is approaching and I thought I would 'take work home'. Can I save documents on a USB stick and work on them at home on my own computer?

No. All materials and information at your disposal while fulfilling your professional duties are the property of Etilab Ltd. Classified documents are not allowed to be 'taken out' of the workplace under any circumstances. In other cases, it is best to ask your supervisor.

I was called by a person introducing himself as an employee of the Prime Minister's Office and asked a question about some confidential Company data. I know I am not allowed to disclose this information, but I suppose I am entitled to tell such an important person?

In a telephone conversation, we cannot verify who is actually calling us. However, it makes no difference whether it would be the head of the Prime Minister's office or not. If you are unsure whether you will be revealing official secrets when answering a question, ask for the question to be e-mailed to your supervisor or addressed in writing.

A trade association has asked me to give a talk at a conference they are organising. Can I attend?

Yes, as long as you get your supervisor's approval and agree on the scope of the information to be presented.

I am in the process of recruiting for a responsible office position. One of the top candidates admits in passing that she is married. Can I ask her about the number of children she has and/or any family plans (e.g. pregnancy)?

No. A recruit's family situation and plans are a private matter, must not be asked about and cannot affect the outcome of the recruitment. As the person deciding whether to employ the candidate, you should be guided solely by an objective assessment of the candidate's qualifications and suitability for the indicated position. Data on the number of children you have can only be requested from an existing employee when it is related to access to entitlements, e.g. insurance, health care, etc.

A company has just advertised for a new position in my business unit. My daughter has great qualifications for the position. Could we work together? I could use a trusted subordinate.

Circumstances where you would influence the outcome of a recruitment process involving a member of your family and having a 'subordinate-supervisor' relationship with immediate family members should not arise.

I have instructed an employee to perform an urgent task overtime, as I believe he will perform it best. The employee protested, claiming that another person could do the task and that I had chosen him because I did not like him. He threatened to accuse me of discrimination and bullying. Should I be afraid of being accused?

Ordering an employee to work overtime is, in principle, not discrimination or bullying. Discrimination could only occur if you were guided by discriminatory criteria (rather than the employee's merit competence) when selecting an employee to perform a task. However, in the above case, none of this occurred. It is the employee's duty to carry out an order to work overtime if there are specific circumstances defined by the Labour Code, e.g. special needs of the employer. Refusal to carry out a task ordered by a superior may be grounds for disciplinary measures against the employee.

A work colleague often tells uncensored jokes, calls me 'darling' and gives me bold 'compliments', and sometimes even sends erotic videos. Can a colleague's behaviour be considered a form of harassment, even if there is no physical contact?

If you feel offended, humiliated or disgusted by a colleague's behaviour, such behaviour may constitute sexual harassment. You should report the situation to the Ethics Officer as soon as possible.

A colleague wears jewellery with a religious symbol on a daily basis. According to the Code of Ethics, is this practice an ostentatious display of her views and should I bring it to her attention?

No. The use of small symbols (jewellery, key ring, small sticker on the car, etc.) is generally accepted in our culture and is not considered to be imposing one's views. For example, promoting a religion or ideology in the workplace, wearing T-shirts with controversial prints, decorating a room with a poster expressing one's beliefs or leaving a car in the company car park clearly marked with ideological symbols, e.g. religious, political, anti-globalisation, etc., can all be considered ostentatious display of one's worldview.

I have noticed that my colleague at work does not always follow health and safety rules. He claims that it is his business because everyone is responsible for themselves. Should I bring it to his attention or report the matter to my supervisor?

Definitely yes. We work as a team and we need to keep ourselves and our colleagues safe. If one person breaks health and safety rules, it can put not only that person at risk, but also the rest of the team. It is also worth remembering that the costs associated with incidents caused by non-compliance with health and safety rules are borne by all of us.

A colleague, who has a personal profile on a social networking site linked to the ETILAB brand, posts controversial photos and very often uses profanity in his posts and comments.

and comments. How should I react if I know that this negatively affects the image of our company?

You should report the situation to the Ethics Officer. The obligation to behave with dignity outside the workplace in situations where it may affect the company's image refers to any circumstances that may affect the image of Etilab Sp. z o.o., including those related to employees' activity in the virtual sphere.

The company has issued a tender for the type of services my friend provides. Can I tell him or her about the tender and encourage him or her to participate?

You can only encourage your friend if you do not divulge any confidential information about the tender and thereby influence its outcome. Simply informing a friend that a tender has been announced and sending them back to read the tender published on the website is perfectly ethical.

I have just got a job at ETILAB. Am I obliged to give my superior such information that was covered by professional secrecy at my previous place of employment? I think I owe loyalty to my current employer?

Do not answer any questions from co-workers that, in response, would require you to disclose information owned by your former employer. Do not disclose such information on your own initiative either. Our Company respects the principles of fair competition and respects the confidentiality of data.