Nowy Styl Code of Ethics Nowy Styl Code of Ethics Company property Brand protection Protection of personal data and confidential information Customer relations Supplier relations Anti-corruption measures Every Nowy Styl employee is responsible for the welfare and development of the company. Therefore, it is the responsibility of every employee to protect company property from loss, theft, damage, waste or misuse. Nowy Styl employees are required to use the company’s prop- erty for appropriate purposes related to the company’s business. Occasional use of company property for private purposes may be permitted with supervisor’s consent, but it must be lawful and it may not interfere with official duties. Nowy Styl employees are not allowed to: — abuse company property (such as phones, company cars, fax machines, copiers, machinery, equipment and other products), — abuse the Internet and e-mail for private purposes, — perform their private obligations and activities during work- ing time, except extraordinary situations justified by an absolute necessity, which have been notified to immediate supervisors, — use the company’s representation funds for non-business purposes. Where permitted by the law and where relevant statements have beenmade, the companymaymonitor and analyse the use by employees of their devices. Where an employee has witnessed an incident or suspects there has been a theft, fraud or other misconduct or abuse of company property, he or she is required to inform his or her supervisor or Ethics Officer. All employees are required to protect Nowy Styl’s intangible assets such as brand, reputation and confidential information. Nowy Styl’s image and reputation are affected by its employees’ statements and behaviour. Any instance of social media use by a Nowy Styl employee (particularly LinkedIn and Twitter), even for private purposes, can be linked to the company and can negatively affect its image and reputation. Therefore, all employees using social media must use them responsibly. Only authorised persons can speak on behalf of Nowy Styl in the media. Any unauthorised logo use as well as any doubts in that respect must be reported by email to
[email protected] . Nowy Styl attaches great importance to the protection of personal data in accordance with applicable laws, includ- ing regulations concerning the collection, use, transfer and disclosure of personal data. Nowy Styl employees are obliged to take all necessary meas- ures to protect the information and data they deal with in the course of their duties. Employees are required to comply with the law and personal data protection procedures in place at Nowy Styl, including to comply with technical and organisational requirements to protect against unauthorised disclosure of personal data. All employees are required to keep in confidence all aspects of production, sales and marketing activities, as well as the com- pany’s results, and to ensure security of information in the course of their cooperation with the company’s partners. Particular care shall be taken of information protected by the law and relevant clauses in contracts with the company’s business partners, as well as the company’s internal organisational documents issued on their basis. Under no circumstances are Nowy Styl employees allowed to disclose data to any unauthorised person whose job description does not justify the need to have such data. A supervisor may not issue instructions to his or her subordi- nates which might result in a breach of information security of the company, its employees or companies and persons cooperating with it. In acquiring customers, Nowy Styl relies on the strengths of its commercial offer, ensuring the veracity of product information and compliance with the principles of honest marketing and advertising. The Code of Ethics sets out general ethical policies applicable to relations with Nowy Styl’s suppliers. Detailed principles of cooperation shall be set out in a separate document Nowy Styl Supplier Code of Conduct and General Terms and Conditions of Purchase for Nowy Styl Suppliers . Relations between Nowy Styl employees and suppliers shall be based on mutual trust and the striving for long-term positive cooperation. Nowy Styl selects business partners based on accurate analysis of facts such as quality, safety, ethical standards, technical capa- bilities, experience, reliability, cost, schedule and availability. All contacts with suppliers should follow generally accepted standards to ensure appropriate business relations are main- tained. Any informal contacts between an employee and a supplier must not affect the terms of cooperation. An employee may not, without the company’s consent, work as an employee of or provide services to a Nowy Styl supplier company at the same time. In conducting its business, Nowy Styl is committed to com- bating all forms of corruption. The quality of products and services is the only criterion for cooperation with customers and suppliers. Nowy Styl will not accept any actions impairing impartial business decisions. Nowy Styl employees may not accept any material benefits resulting from functions held or tasks performed. Nowy Styl recognises that accepting gifts or any other benefits by employees may lead to situations perceived as an attempt to persuade a person receiving such gifts or benefits to offer certain benefits to the giving party in return. The following are considered material benefits: — financial payments, — performance of a service free of charge or at a reduced, non-market price, — a high-value gift in kind, in particular where its acceptance incurs a tax obligation on the part of the employee. A gift can be accepted if: — it is of negligible material value, — it has no impact on the tasks performed and decisions taken, — it does not oblige reciprocity, — it is an advertising, corporate gift which has been presented officially, in public, at a ceremony. Employees are not allowed to offer material benefits to the company’s business partners. To maintain a good business relationship with a customer or partner, an employee can hand in a corporate gift with a gross value of up to PLN 200* (not constituting a material benefit as defined above). Handing in modest gifts or signs of hospitality as a reasonable form of appreciating business contacts is generally allowed. Gifts must be presented in a way ensuring that the customer realises that he/she is receiving a gift from the company, not from a specific employee. Participation in a sponsored event should be reported to a direct supervisor each time. If in doubt, you should consult your supervisor, the Legal Department or the Ethics Officer before taking any decision *Gift value depends on specific local laws in the affiliate’s country. Nowy Styl provides its customers with full information about the company’s products, services and activities, except for information constituting technical, technological, commercial or organisational secrets of the company, the disclosure of which could expose the company to damage. In discharging their duties, Nowy Styl employees are required to use truthful and accurate messages. No company employee can in any event make false, unverified or misleading statements about the quality or availability of Nowy Styl products, or about the company’s competitors. Nowy Styl meets all of its obligations to customers, never abuses a customer’s trust and never takes advantage of any ignorance or inexperience on the part of a customer. Nowy Styl delivers orders in compliance with applicable regula- tions and the terms and conditions of bilateral contracts. Nowy Styl honestly informs its customers about any extra costs, difficulties and delays in the performance of scheduled deliveries. 12 13 Table of contents