ANTI-CORRUPTION POLICY

1. Purpose
The purpose of this policy is to establish controls to ensure compliance with all applicable anti-corruption and corruption laws and to ensure that the company's business is conducted in a socially responsible manner.

2. Policy declaration
Bribery is offering, promising, giving, accepting or soliciting benefits as an incentive to act illegally or to abuse trust. A bribe is an incentive or reward offered, promised or provided to obtain commercial, contractual, regulatory or personal benefits.
Our policy is to conduct our entire business in an honest and ethical manner. We adopt a zero tolerance approach to bribery and corruption. We commit ourselves to act in a professional, honest and honest manner in all our business relations and relationships, wherever we operate, and to implement and enforce effective anti-bribery systems.
We will comply with all anti-bribery and corruption laws in all jurisdictions in which we operate. However, we remain bound by law in Poland and the EU in our conduct both in the country and abroad.
Bribery and corruption are punishable by up to 10 years imprisonment and a fine. If it turns out that we were involved in corruption, we could be punished with an unlimited fine, excluded from public procurement tenders, and damage our reputation. That is why we take our legal obligations very seriously.

3. Scope
3.1 Who is covered by the policy?
In this policy, a third party means any person or organization that you contact while working for us, and includes actual and potential clients, clients, suppliers, distributors, business contacts, agents, advisers as well as government and public institutions, including their advisers , representatives and officials, politicians and political parties.
This policy applies to all persons working at all levels and levels, including senior managers (permanent, temporary or temporary), consultants, contractors, trainees, posted employees, domestic workers, occasional employees and agency employees, volunteers, trainees, agents, sponsors or any other person associated with us, as well as any of our subsidiaries or their employees, regardless of where they are (collectively referred to as employees in this policy).
This policy includes:
• bribes;
• Gifts and hospitality;
• Gratifications;
• political contributions;
• donations for charity.

3.2 Bribes
Employees are not allowed to engage in any form of bribery, directly or through third parties (such as an agent or distributor). In particular, employees may not bribe a foreign public official anywhere in the world.

3.3 Gifts and hospitality
Employees may not offer or give gifts or hospitality:
 
• which may be considered illegal or improper or that violate the recipient's policies; or
• to any public employee, government officials or representatives, politicians or political parties; or
• with a value exceeding PLN 500 for each individual gift or with a value of PLN 2,000 for each guest event (not exceeding the total value of PLN 5,000 in any budget year), unless it is approved in writing by the employee's manager.
Employees may not accept gifts or hospitality from our business partners if:
• exceeds PLN 500 for each individual gift or PLN 2,000 for each guest event (may not exceed a total of PLN 5,000 in any budget year), unless approved in writing by the employee's manager; or
• is in cash; or
• there are suggestions that a return favor will be expected or implied.
If the manager's consent is required above, if the manager is below the director's level, the consent of the relevant director should be obtained.
If the rejection of a gift offer is not appropriate, the gift can be accepted, provided that it is notified to the employee's manager and passed on to charity.
We understand that the practice of giving business gifts varies between countries and regions, and what may be normal and acceptable in one region may not be in another. The test to be used is whether the gift or hospitality is justified and justified under all circumstances. Always consider the intention of the gift.
As part of these parameters, local management may define specific guidelines and policies that reflect local professional and industry standards. If these rules require written consent, the Company Secretary shall introduce a process of keeping a register of all such permits.

3.5 Political donations
We do not donate, in cash or in kind, to political parties or candidates because this can be seen as an attempt to gain the wrong business advantage.

3.6 Charitable donations
Charitable support and donations are allowed (and indeed are encouraged), whether in the form of in-kind services, knowledge, time or direct financial contributions. Employees must, however, ensure that charitable donations are not used as a means of concealing bribery. We make charitable donations that are legal and ethical in accordance with local laws and practices.] No donation may be offered or transferred without prior approval from [Compliance Officer.
All charitable donations should be disclosed publicly.
 
4. Your responsibilities
You must ensure that you read, understand and follow these rules.
Prevention, detection and reporting of bribery and other forms of corruption is the responsibility of all persons working for us or under our control. All employees are required to avoid any action that may lead to or suggest a violation of this policy.
You must notify your manager OR Company Secretary or a confidential helpline as soon as possible if you believe or suspect that there is a conflict or violation of this policy or may occur in the future.
Any employee who violates this policy will be subject to disciplinary action that may result in dismissal because of gross misconduct. We reserve the right to terminate our contractual relations with other employees if they violate these rules.

5. Record keeping
We must maintain financial records and have appropriate internal controls that will prove business justification for making payments to third parties.
You must declare and keep a written record of all hospitality or gifts received or offered that will be subject to management review.
You must ensure that all claims for hospitality expenses, gifts or expenses incurred on behalf of a third party
pages are reported in accordance with our spending policy and clearly state the reason for the spend.
All bills, invoices, memoranda and other documents and records related to contacts with third parties, such as customers, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts should be kept outside the books to facilitate or hide improper payments.

6. How to report a problem
We encourage you to raise concerns about any issues or suspected fraud at an early stage. If you are unsure whether an act is bribery or corruption, or if you have other questions or concerns, please report them to your line manager or company secretary or via a confidential helpline.

7. What to do if you are a victim of bribery or corruption
It is important to notify the Company Secretary or confidential help line as soon as possible if someone offers a bribe by a third party, you are asked to give it, suspect that this may happen in the future, or suspect that you are the victim of another form of illegal activity.

8. Protection
Employees who refuse to accept or pay a bribe, or who report concerns or report someone's deeds, are sometimes concerned about the possible consequences. Our goal is to encourage openness and support anyone who, in good faith, reports genuine fears, even if they turn out to be incorrect.
We make every effort to ensure that no one is harmed by refusing to engage in bribery or corruption or by reporting in good faith suspicions of actual or potential bribery or other corruption offense or that it may occur in the future. Harmful treatment includes dismissal, disciplinary action, threats or other adverse treatment associated with raising concerns. If you think you have suffered from such treatment, immediately inform Mariusz Sokołowski. If the matter is not resolved and you are an employee, you should formally report it using the company's complaint handling procedure.

9. Training and communication
 
Training in this policy is part of the introductory process for all new employees. All current employees will be regularly trained in the implementation and compliance with these principles. In addition, all employees will be asked to formally accept compliance with this policy every year.
Our zero tolerance approach to bribery and corruption must be passed on to all suppliers, contractors and business partners at the beginning of our business relationship with them and then where appropriate.

10. Who is responsible for the policy?
The company's management has overall responsibility for ensuring that this policy complies with our legal and ethical obligations, and for compliance by all those who are under our control.
The company secretary has primary and daily responsibility for implementing these
rules and to monitor its use and effectiveness and to resolve any questions regarding its interpretation. Management at all levels is responsible for ensuring that applicants are aware of and understand this policy and receive appropriate and regular training on it.

11. Monitoring and review
The Agency's secretary will monitor effectiveness and review the implementation of this policy, regularly taking into account its usefulness, relevance and effectiveness. Any improvements identified will be implemented as soon as possible. Internal control systems and procedures will be subject to regular audits to ensure that they are effective in combating bribery and corruption.
All employees are responsible for the success of this policy and should ensure that they use it to disclose any suspected threat or misconduct.
Employees are asked to comment on these principles and suggest ways to improve them. Comments, suggestions and queries should be directed to the Company Secretary.

This policy is not part of the employee's employment contract and may be changed at any time.

Signed January 16, 2019. On behalf of Batory Recruitment
 
Mariusz Sokołowski
Managing director