Code of Ethics

The Code of Ethics of e-point S.A. (the “Code”) describes the principles that guide e-point S.A. (“e-point”) in its business activity. Our goal is to do business in a fair, transparent and responsible manner with respect for the environment we operate in, in particular with respect for labour rights and our business partners.

The principles indicated in the Code apply to all employees and associates of e-point regardless of their job position or function. Every employee and associate is obligated to comply with the principles indicated in the Code and take proper actions to fulfil the obligations that arise from it.

We also expect the external entities that cooperate with e-point to respect and observe the values described in the Code.

I.    Lawfulness

e-point complies with national and international regulations as well as the regulations of the European Union. We also comply with sector-specific regulations and observe the decisions issued by authorised bodies.

II.     Business activities

1.      Fair competition

We respect and support the principles of fair competition. We ensure to maintain fair competition in relations with other enterprises. We comply with all applicable laws on the protection of competition and protection against unfair competition. We do not take any actions designed to limit consumer rights or free competition.

We present our products in a truthful manner and do not share any misleading information about our products or services.

When cooperating with customers and business partners, we act in accordance with the concluded agreements, adopted regulations and principles of fairness.

2.      Confidentiality of information

We gather and process information about our employees, associates, customers, suppliers and other business partners while ensuring due care and security of the processed data. Every one of us is responsible for protecting the data and using them only for intended and lawful purposes. We are obliged to ensure that all confidential information, including trade secrets, personal data and other information protected by the law, is properly secured and is not disclosed to unauthorised persons. It is forbidden to use the acquired confidential information to perform actions related to trading in financial instruments.

Only authorised persons have the right to share information about the company with the public, the media and third parties.

3.     Care of the company’s assets, intellectual property rights

We manage the physical and intangible assets of the company in a proper manner, and we secure them against loss, theft or fraud. We use the assets only for business purposes.

We protect our intellectual property as well as the property rights, designs, trademarks and know-how that belong both to e-point and its business partners.

4.     Anti-corruption principles, money laundering prevention

We comply with anti-corruption regulations, and we do not participate in any corrupt business practices. We take actions and make decisions that are reasonably justified, irrespectively of private interests. We do not tolerate any form of corruption, and we take all necessary and adequate measures to prevent it.

We observe the principles of loyalty, impartiality and fairness in our relations with customers and suppliers. We do not offer or accept any gifts or other additional benefits of more than nominal value. We do not accept offering or receiving any financial benefits, gifts or other kinds of remuneration that could have a real or apparent impact on the objectivity of the process of decision making.

We do not accept, enable or support money laundering.

5.     Prevention of conflict of interest

It is our duty to avoid situations that can lead to the conflict of interest. We avoid situations in which our private, family or financial interests would contradict the interests of e-point. In case of such conflict of interest, we reveal it and require the approval of an appropriate member of the management. Private activities or financial affairs should be conducted in a manner that does not give rise to suspicion of conflict of interest with e-point and should not influence the decisions or actions taken while performing the function or business duties.

6.     Accounting

All financial transactions are reported in accordance with the adopted accounting regulations. Every transaction is described in accounting documents in a correct and non-misleading manner.

7.     Export control laws

We comply with all export control laws and export restrictions related to our business activity on the international market.

8.     Corporate social responsibility

We acknowledge our responsibility for the consequences of our business activity towards the society and natural environment. We support social engagement by organising different kinds of social, environmental and cultural initiatives. We promote charity and social events.

III.     Human rights, relations with employees

1.      Compliance with human rights

e-point complies with national and international regulations on the protection of human rights. We observe the laws and support their enforcement, and we use our capabilities to prevent human rights violations.

2.     Compliance with labour rights

We are committed to comply with the provisions of the Labour Code and respect the personal dignity and privacy of our associates. We observe labour rights and support their enforcement. In relations with our employees and associates, we respect the applicable law, agreements and accepted professional standards related to working hours and remuneration.

We make all efforts to enable our employees to maintain work-life balance. We try to help them reconcile their work with their family life.

3.     Respect, equal opportunities and non-discrimination

We respect and try to understand each other in our everyday work. We do not accept any form of discrimination, verbal or physical assault, sexual harassment, violence or mobbing. We do not discriminate against people on grounds of race, nationality, country of origin, religion, disabilities, gender, sexual orientation or political views.

We care about a good working environment and ensure that it contributes to the creative and effective functioning of our entire organisation. We are against any behaviours that lead to conflicts and do not contribute to a friendly working environment. We do not use our position in a manner that violates good practices or the personal rights of our associates. We do not spread false information about our associates.

4.     Health and safety

We provide safe and healthy working conditions and monitor safety in the workplace. We strictly obey all OHS rules and standards. In situations dangerous to health and safety, we follow the adopted instructions. We care about the safety of third parties staying on the premises of e-point. We report all incidents that can put human health and safety in the workplace at risk.

We support our employees in maintaining or developing a healthy lifestyle.

5.     Child labour, forced labour

We respect the rights of children and adolescents and do not tolerate any form of exploitation. We do not engage in any forced or slave labour practices and we do not derive any benefits from such practices.

6.     Freedom of association

We ensure that all employees have a right of membership in legal associations. We respect the right of all employees to join organisations that represent their interests, the right to organise and the right to collective or individual bargaining.

IV.     Protection of the environment

We acknowledge our responsibility to use natural resources in a reasonable manner and we promote environmentally friendly technologies. We undertake to comply with the laws and regulations related to the protection of the climate and natural environment.

In our everyday work, we use resources (e.g. electricity, heat, water, raw materials, tools and consumables) in a cost-effective manner, and we prevent or reduce the production of waste.

Our goal is to reduce our environmental burden.

V.     Final provisions

Our employees and business partners have the right to receive explanations if any provisions of the Code are incomprehensible to them or if they have doubts regarding the applicability of the Code. Our employees and associates have the right to report their suggestions and propose amendments to the Code.

Violations of the Code, depending on the circumstances, may be treated as misconduct or breaches of contractual duties.

All employees of e-point should report any violations of the Code to their immediate supervisors, supervisors of their supervisors or the designated representative of the employees. The identity of a person reporting the violation is treated as confidential information.

The members of the management of e-point are particularly obliged to implement the rights and obligations indicated in the Code and inform the employees about them as well as to ensure that these principles are respected.

e-point aims at creating a stable culture based on the principles indicated in the Code, takes necessary actions to eliminate or reduce the risk of Code violations, carries on regular exchange of information and also monitors the implementation of these actions and improves them continuously.

Any questions or doubts regarding the Code and its application should be addressed to: compliance@e-point.pl.

The Code may be periodically reviewed and modified. Employees and associates are informed about all modifications.