Compliance

Compliance Management System

A Compliance Department has been established at PKP CARGO, which is responsible for coordinating the compliance policy at PKP CARGO S.A. and for managing the ethics and anti-corruption areas.

The Department includes the position of Compliance Officer, reporting directly to the President of the Management Board, with the possibility of reporting to the Audit Committee of the Supervisory Board, in accordance with the Best Practices for WSE Listed Companies.

Code of ethics

Ethics is the cornerstone of an effective compliance risk management system and a system to prevent and detect fraud in this area. The code of ethics adopted by PKP CARGO S.A. is based on the values shared by employees, i.e. reliability, cooperation, sound management, safety, professionalism, innovation, transparency, responsibility and respect.

The principles contained therein apply to every employee, regardless of his or her position and the nature of their duties, as well as to customers, suppliers, competitors Code of Ethics.

PKP CARGO S.A.’s anti-corruption and gift policy

Preventing and addressing fraud and corruption are one of the Company’s key activities in its relations with the business community. PKP CARGO has adopted a “zero tolerance for corruption” policy. No corrupt behaviour will be tolerated, regardless of the aspect of operations it applies to.

The purpose of this Policy is to define the handling of corruption risks existing at PKP CARGO, including the ways of reacting to and documenting cases of actual or potential corruption and creating awareness among Employees.

The rules of the Policy are binding both for the Company’s employees and all persons cooperating with us under civil-law contracts and other persons performing any activities on behalf of or for the benefit of PKP CARGO S.A.

The rules for accepting and giving gifts supplement the relevant provisions of the PKP CARGO S.A. anti-corruption policy. The purpose of these rules is to establish uniform standards for employees in offering and accepting Gifts, which may take the form of a gift or entertainment. A gift is an item of a specific value, e.g. leather goods, a food basket, and its value must not exceed PLN 200.00 gross. Entertainment is understood as invitations to entertainment events, i.e. sports events, theatre performances, concerts or other cultural events, up to a value of PLN 500.00 gross.

Implementation and compliance with the aforementioned rules ensure that there is no situation in which accepting gifts could affect business decisions at PKP CARGO S.A.

If corrupt activities or other violations are confirmed, the Company shall take appropriate corrective actions to prevent future events of a similar nature PKP CARGO S.A.’s anti-corruption and presentation policy.

Code of Conduct for Business Partners of the PKP  CARGO S.A. Group

The Code of Conduct for Business Partners of the PKP CARGO Capital Group specifies the requirements of the PKP CARGO Capital Group towards competitors in the scope of universal human rights, including respect for human rights, working conditions, protection and honesty in the principles of business activities, also establishing the principles of mutual cooperation.

The introduction of the Code aims to promote honest and ethical conduct in accordance with the regulations specified and to define values ​​that are based on mutual partnership. The PKP CARGO Capital Group considers it necessary to observe the honesty of market activities. The basic goal of the Code is to shape ethics and moral patterns of behavior. Basic information published in the regulations, which constitute the basis for legal, lawful, responsible and honest actions, taking into account cooperation with Business Partners.

The Business Partners of the PKP CARGO Capital Group include, among others: Suppliers Contractors Subcontractors Customers who have cooperated with the PKP CARGO Capital Group in order to obtain mutual benefits The PKP CARGO Capital Group may detect that Business Partners will cooperate with the standards in the Code of Conduct for Business Partners of the PKP CARGO Capital Group in the field of ethical conduct.

Speaking up

The notification system in place at the Company is designed to prevent fraud and violations, protect the Company’s image and support operational risk management. Customers, Business Partners and persons outside the Company can report any irregularities via dedicated communication channels, i.e.:

• web platform: https://cargo.liniaetyki.pl
• email address: [email protected]
• phone number: 22 290 69 13; any person reporting the suspicion or irregularity is referred to as a whistleblower.

PKP CARGO respects the right of whistleblowers to remain anonymous and to safeguard their personal data and to protect them from any retaliation.

The reporting channels in place at PKP CARGO S.A. are in line with good whistleblowing practices and the requirements set out in the Act on public offering and the conditions for introducing financial instruments to the organised trading system and on public companies and Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of whistleblowers.

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