Ethics in the Company

ETHICS OFFICERS

The Company has a team of Ethics Officers. Their primary task is to resolve disputes and provide explanations based on the provisions of the Code of Conduct.

Any employee, associate, customer or contractor may report to the Ethics Officer with a request for help if he or she finds that the accepted values, ethical or social standards have been violated. When reporting problems and complaints, and in the course of any investigation procedure, the data of the reporting person may be kept confidential at his/her request. However, PCC EXOL SA does not encourage the use of this method. We hold that a person reporting a complaint or problem when acting in good faith does not have to hide his or her identity. However, the issue of anonymity depends on the decision of the affected or aggrieved.

Furthermore, a very important principle is the guarantee that no retaliatory measures will be taken against persons who report in good faith, problems related to violations of the law and of the enshrined ethical culture principles within the Company. However, it should be remembered that such a person takes full responsibility for his/her words and actions. Therefore, the Ethics Officers, their actions or powers should not be used for retaliation or repression against supervisors or associates.

LIST OF COMPLAINTS REGISTERED BY THE ETHICS OFFICERS 2014/2015/2016

OUR OBLIGATIONS

We strive to maintain the absence of complaints in the area of ethical conduct.

A SCHEME OF REPORTING COMPLAINTS TO THE ETHICS OFFICERS

• Reporting an incident to the Ethics Officer

  The Ethics Officer’s consideration of the incident begins by initiating an open interview with the person making the report. The circumstances of the situation are then analysed (keeping it confidential). Conclusions from such analysis are used to improve ethical standards inside the Company.

• Consideration of the report and feedback

  The consideration of the incident and the giving of feedback to the reporting person is based on the data collected by the Ethics Officer. At the request of the reporting person, the Ethics Officer shall provide a written solution to the case.

• Violation of the law

  In any case that is indicating a breach of legal regulations, the Ethics Officer shall immediately inform the Management Board of the Company about the detected irregularities.

• Reporting a breach to the Management Board of the Company

  The person who made the report has an insight into the results of the conducted proceedings. The Management Board of the Company, based on the collected information and documentation prepared in this respect, has the right of decision to introduce appropriate actions against the person or activity that is the subject of the proceedings.

• Compensation for damage

  If violations of the principles contained in the Code of Conduct are found, recommendations may be made to compensate for the moral damage inflicted on the victim, and to undertake disciplinary interviews with the supervisor. Oral and written warnings and other punishments are also practised.

In 2016, we did not record any reports of discrimination or of human rights violations.

Freedom of association and the right to collective bargaining of employment conditions

Freedom of association is one of the fundamental human freedoms, and it is firmly enshrined in the Polish legal system. Employees of the PCC Group Companies have the right to form and join any trade union and to conduct collective bargaining of wages and working conditions. As we take an open attitude towards trade unions and their organisational activities, trade union representatives shall be free to perform representative functions in the workplace.

In 2016, we did not identify any threats to freedom of association and bargaining.

THE USE OF CHILD LABOUR

In PCC EXOL SA, it is allowed to employ adolescents over 16 years of age. Adolescents, under the labour law, are persons from the age of 16 up to 18. The regulations on adolescents’ employment are primarily of a protective nature. Their purpose is to protect against economic exploitation, work that can be dangerous or harmful to health, physical and mental development, or can limit or even eliminate the possibility of education. Unlike children, adolescents can sign a contract of employment on their own, without the consent of parents or legal guardians and without the need to obtain permission from a labour inspector.

In 2016, we did not identify any child labour abuses.

VOLUNTARY EMPLOYMENT

Voluntary employment is one of the most important features of the employment relationship. We do not benefit from forced, bonded or forced prison labour. All employees of the Company perform their tasks voluntarily and consciously, in accordance with their rights, predispositions and qualifications. The Company’s employees also have the right to terminate employment after the completion of the contract.

All the tasks entrusted to employees are performed by them in a conscious manner, without any form of coercion. Each person employed by the Company has a Work Position Card. Herein, the scope of duties appropriate for a given position has been defined. The proffered wage is considered to be the value that employees must receive for their work, and to be their main source of income, as well as the basis for their financial security.

In 2016, we did not identify any issues regarding forced or compulsory labour.

OCCUPATIONAL HEALTH AND SAFETY

Care for the safety of people and the environment has long been considered as one of our most important priorities. We provide our employees with a safe working environment – one consistent with the standards of the chemical trade that takes into account potential hazards. We put into practice a number of actions aimed at preventing accidents, including reducing various types of hazards in the work environment. We promote best notions of safety, health and environmental protection.

All employees of the Company, or who are connected with outsourcing contracts in the scope of property protection, are bound by the principles resulting from the implemented Code of Conduct in PCC EXOL SA.

THE RIGHTS OF INDIGENOUS PEOPLES

We respect the rights of indigenous peoples, in accordance with the definitions set out in the applicable legal provisions. In order to promote the idea of sustainable palm oil production, initiated by RSPO organisation (Roundtable Sustainable Palm Oil), we operate according to established mechanisms for the extraction and processing of palm oil throughout the supply chain. As a member of the organisation, we respect human rights, including respect for culture, the rights of local communities, the ownership of the lands and of small-scale agricultural producers, by integrating them into a sustainable supply chain.

In 2016, we recorded no violations of the rights of indigenous peoples.

ETHICAL PRINCIPLES IN MARKETING AND ADVERTISING

We recognise the cultural-creative and moral character of marketing actions, seeing the need to eliminate negative phenomena and to stimulate positive ones in this scope. Moreover, we understand the need to align certain standards in the framework of cooperation with our world-wide stakeholders. We also undertake a pledge to make every effort to ensure that the principles and values described in the Code of Conduct for PCC EXOL SA are respected and observed.

Employees involved in marketing actions are obliged to:

• Ensure that advertising messages in the media, the Internet and other electronic media do not contain any pornographic content, elements of violence, hatred, offensive behaviour or any manifestations of human rights violations,
• Ensure that the contents of any promotional and advertising materials of the Company are based on true information,
• Pay attention to presenting the features and properties of products in advertising materials in a reliable and objective manner;
• Apply and respect all provisions contained in the Code of Advertising Ethics, established by the Advertising Council and the Advertising Ethics Committee, which is the source of principles of the ethical conduct for all employees involved in advertising and marketing;
• Respect international ethical principles in advertising and marketing, and to act in accordance with the standards of the European Advertising Ethics Association (EASA) in this scope.

In 2016, we did not record any cases of non-compliance with the stipulated regulations and voluntary codes that we follow.

CODE OF ETHICAL CONDUCT OF SUPPLIERS

We are committed to consciously observe best social, ecological and ethical standards. Our mission in this scope is to promote these standards not only among our employees, but among our clients and cooperators. We expect all our stakeholders to respect the values we have adopted and the principles we have established.