CODE OF ETHICS - SINTUR sp. z o.o.

Introduction:

The purpose of the Code of Ethics is to shape the right culture of life, especially the culture of work within the Company and between the Company and its environment.

The Code covers the main rules of conduct for employees of SINTUR sp.z o.o. in the field of broadly understood professional and social ethics, ensuring the fulfillment of the company's mission and implementation of its development strategy, as well as customer satisfaction. This Code has been developed on the basis of generally accepted principles of social coexistence.

The recommendations contained in the Code cannot foresee all issues and problems that may arise in everyday work, therefore, in the Code regulations, only general and basic principles of conduct in all fields of professional activity are defined.

The Code principles apply to every person employed at SINTUR sp.z o.o., at every level of the company's organizational hierarchy.

We all have a special duty to respect the Code of Ethics, and any violations will result in disciplinary measures in accordance with applicable law.

Our mision:

The mission of SINTUR sp.z o.o. is to ensure continuous development of the enterprise and meet customer requirements by maintaining a high level of quality of manufactured and sold: components for refrigeration products and products for the power industry.

Our vision:

Our vision is to strengthen our good position on the market as a reliable business partner caring for its customers. Among the companies operating in our industry, we want to be a leader with the reputation of a specialized manufacturer and supplier.

Our values:

  • Customer satisfaction and personal development
  • Honesty and reliability
  • Professionalism
  • Trust and cooperation

I. General ethical principles in force in SINTUR sp.z o.o.

Honesty in business

Management and employees of SINTUR sp.z o.o. they realize that ethical values have an important place among the elements that make up the image of an enterprise. That is why we do not use unethical and illegal business practices.

We believe that compliance with business ethics provides a competitive advantage and strengthens the Company's reputation. We strive to ensure that relations that connect us with Contractors, Customers, but also with numerous competitors are based on fairness and the principles of fair play competition. We also expect our Partners to be with us

support fair competition and condemn all forms of unfair practices in order to obtain undue advantage.

II. Obligations to Customers and Business Partners

Customer satisfaction is our top priority. We are characterized by:

High quality customer service

1. We strive to meet the expectations of customers and strive to provide them with maximum satisfaction with the products and services offered.

2. We are committed to efficient and courteous customer service, maintaining a dialogue attitude and looking for opportunities to interact with the customer and to avoid words and tactless behaviors that are uncultural and contrary to decency.

3. We treat all clients equally, we undertake orders that we can duly and timely fulfill.

4. We keep both commitments written in the agreements and oral promises, we meet the dates of meetings which we always arrive on time, we pass our offers on the agreed date.

5. We admit our mistakes and strive to correct them. We react immediately to errors so that they can be corrected as soon as possible.

6. Our clients have the right to full information about the products and services on offer, their prices and terms of sale as well as all circumstances affecting the performance of the order and mutual relations.

Reliability

1. We care about informing clients about their products and services that do not abuse their trust or take advantage of a lack of experience or knowledge.

2. SWe make promises to the client in accordance with our current capabilities and accepted standards.

Confidentiality of information:

1. We do not provide third parties with information on the scope of cooperation with the client.

2. We comply with the principle of confidentiality of information from clients or contractors.

III. Obligations to employees

SINTUR employs employees in accordance with the provisions of labor law in force in Poland, it also adheres to the Basic Social Principles contained in the International Labor Organization Conventions, in particular with regard to issues such as:

• children's work

- there is a ban on child labor, young workers are protected under general law;

• forced labor

- there is a prohibition on forced labor, a restriction on freedom of movement and a ban on all identity documents;

- any behavior that is contrary to the law, ethics, principles of social coexistence, and in particular behaviors aimed at inhuman treatment are prohibited, not accepted,

• no discrimination;

• the right to associate and to collective disputes between employers and employees;

• Occupational Health and Safety;

• working time, in particular working time standards, schedules, records, settlement of working time and rest due to the employee

• remuneration for work, including the employee's right to full information on the calculation method and components of remuneration, presented in name paper form (the so-called "pay slips"),

Compliance with ethical standards in the workplace and accepted behavior patterns is one of the basic sources of stability and success of the Company. We are aware that creating a favorable atmosphere in the workplace leads to strengthening of employees' ties with the Company and promotes the efficiency of their activities.

Equal opportunities for all employees

1. All employees are treated equally in terms of employment conditions and have equal access to promotion and training improving their professional qualifications - in accordance with objective criteria of employee evaluation.

2. The employment conditions, access to promotion and training are the same for all employees regardless of age, sex, marital status, nationality, race, sexual orientation, religion, disability, political beliefs.

Employee development and remuneration

1. Employees should strive for continuous self-improvement and achieve the best results at work, in line with their knowledge, experience, qualifications and abilities.

2. SINTUR encourages employees to personal and professional development. One of its goals is to provide everyone with equal access to vocational training so that every employee can maintain and develop their skills.

Discrimination and Harassment

1. Relations between employees, regardless of their positions, are a model of good morals, honesty, loyalty, mutual trust and respect as well as respect for personal dignity.

2. The company guarantees trade union organizations operating on its territory all rights arising from the Act on trade unions and other generally applicable provisions, including in particular the provisions on non-discrimination of labor union members and the right to associate.

3. At SINTUR sp. z o.o. all forms of harassment or humiliation of employees are not accepted, and every company Employee is obliged to brand and report any mobbing or discrimination in the company.

4. It is forbidden to:

using mobbing in any form, in particular: humiliation, insulting and intimidation of other employees, using your position in the company to achieve personal benefits or violating the personal rights of other employees, disseminating untrue information, gossip, libel regarding other company employees.

Examples of employee behavior

During the performance of our duties, we build partnership relations together. We are open and friendly to colleagues. We care about our credibility by keeping our promises. We help each other effectively sharing knowledge and information.

1. We create an atmosphere of open and direct expression of your opinions.

2. We treat others as we would like to be treated.

3. In every situation when we compete with each other (e.g. internal competitions) we follow the principles of fair play.

4. We promote actual authors of successes and achievements, we don't take credit for the merits of other people.

5. We strive for amicable settlement of disputes in an atmosphere of camaraderie and respect for different views. Our likes and dislikes cannot affect the performance of tasks.

6. We are happy to share knowledge and professional experience with other employees.

7. We value and respect the knowledge, experience, qualifications and views of other employees.

8. Together, we care for a good working atmosphere based on the principles of ethics and a high personal culture conducive to the efficiency of operations.

9. We care for good interpersonal relations by observing generally accepted principles of proper behavior and respect for human rights.

10. Respecting the religious feelings of employees, the employer declares the creation of a place for worship (place for prayer) immediately, not later than within 14 days from the date of such request.

11. Working in a team, we strive for concerted cooperation and elimination of conflict situations.

12. At times of stress, we control our emotions and follow the principle of professionalism.

13. We are not afraid of expressing and accepting criticism, seeing it as an opportunity for improvement.

Our company considers itself an integral and responsible part of the society and community in which it operates, which is why we unconditionally devote ourselves to the principle of respect for law and social principles as well as recognition and observance of Fundamental Human Rights contained in the „Declaration of Human Rights”. Relations between employees, regardless of their positions, are a model of good manners, honesty, loyalty, mutual trust and respect for personal dignity. Each employee is obliged to observe the highest level of personal culture, to present high ethical and moral values, neatness, cleanliness, being aware of the generally applicable principles of social coexistence and the awareness of representing the image of the company.

IV. Obligations of the parties to an employment relationship

Compliance with laws, rules and regulations

1. Employees operate in accordance with the rule of law, apply procedures resulting from generally applicable provisions and internal regulations of the company.

2. Employees perform their duties with particular diligence, in accordance with applicable law, guided by the company's interest.

3. Employees shall not disclose information which is its property if disclosure of the information could endanger the interests of the employer or would be contrary to applicable law.

4. The company is prohibited from using fines except as permitted by generally applicable labor law.

Information Protection

1. The employees of the company are obliged to use the highest diligence in the protection of all information obtained as part of performing their official duties.

2. Employees respect the confidentiality of information regarding prices, terms of cooperation and any other data that would violate the good of SINTUR sp. z o.o., the good of our customers and suppliers or applicable legal provisions.

3. Employees during employment, as well as after its termination, are obliged to keep secret all classified information obtained while performing work at SINTUR sp. z o.o., and to secure this information against unauthorized access or use.

Competition and fair conduct, anti-corruption rules.

1. The company prohibits competitive activities, in particular cooperation with competitors, i.e. those whose interests conflict with those of SINTUR Sp. z o.o.

2. It is forbidden to personally receive from any persons or companies that have established or are trying to establish cooperation with the company

  • any rebates, commissions or other forms of remuneration,
  • loans or advances other than those obtained from banking or financial institutions on market conditions, goods,
  • equipment, services, repair and modernization works without payment or with an invoice price not reflecting market rates and
  • invitations, gifts in any form (in the form of an object or intangible form) or benefits (financial or legal) of excessive value or reserved for one employee or for a very limited group of employees.

3. In case of any doubts, the employee consults his supervisor.

Abuse of company equipment, assets and time

Employees use entrusted company property (cars, telephones, computers,

office space, commercial software, etc.) solely for the purpose and in the performance of their official duties - on the terms specified in the company.

Professionalism

Employees may use their rights only to achieve the purposes for which they were entrusted.

Loyalty

Employees care for the property, image and good name of the company and its employees, showing due diligence and economy.

Appearance

Employees at SINTUR sp. z o.o. are obliged to take care of the right: neat and dignified appearance and remember that appearance at work has a great impact on the opinion of customers about the employee and the represented company.

V. Obligations to Partners and Suppliers

1. SINTUR sp. z o.o. strives to maintain and develop good relations with its Contractors, Suppliers and Business Partners.

2. When choosing goods or services, employees are guided primarily by price and quality criteria and opt for allowing the widest range of competing companies.

3. Employees base mutual relations on trust.

4. Employees respect integrity in settling their obligations.

President of the Board, Romuald Zajdel-Pawlak

Vice-President of the Board Ryszard Ścibior

Szadów Pański, 01/06/2019