Anti-corruption policy

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In accordance with business principles, Elektryk Sp. Ltd. does not tolerate manifestations of corruption that contradict its efforts to be a responsible and trustworthy company. The Anti-Corruption Policy will be promoted to the company's employees, with the support of training initiatives.

  1. Target

The purpose of the Policy is to oppose corruption among colleagues, business partners and to apply measures to ensure compliance with applicable laws. The Anti-Corruption Policy is treated consistently with the Code of Ethics.

  • Definition of corruption

Corruption is the abuse of official position, power or influence to obtain unofficial and unwarranted benefits personally or for others. Offering, giving or receiving in any form, regardless of the value of any goods. A "benefit" is considered not only profit of a tangible nature, but also intangible mi.n. donation, employment contract, classified information, preferential treatment, gifts, rewards, invitations.

  • Principles of Anti-Corruption Policy

Transparency through fair, friendly, honest, and open and transparent operation. Striving to build the image of a responsible, trustworthy company. Proceeding in accordance with applicable laws. According to the adopted Policy, prohibited activities in relations with stakeholders are:

- bribery

- extortion or inducement

- revenue trading

- Legalizing proceeds from corrupt activities.

  • Corruption risk areas (corruption risks)

Gifts and invitations (meals, parties, entertainment) are warranted in situations where significant business relationships are established, maintained and developed. Then, in order for employees not to feel vulnerable to accusations of sustaining business relationships by engaging in behavior that does not comply with current norms and regulations, it is necessary to make sure that the action is in line with the company's policies.


- Accepting or offering modest gifts, the value of which, as a rule, does not exceed the value equivalent to PLN 100. Gifts may not include cash or cash equivalents (e.g., gift cards, vouchers, etc.),

- Accepting and offering small Christmas gifts, which are part of the culture and customs of Poland.

  • Responsibilities Employees

The prevention, detection and reporting of bribery, as well as other forms of corruption, is the responsibility of all those working under the supervision of Elektryk Sp. z o.o.

  • Reporting abuse

Employees of Elektryk Sp. z o.o. may raise their concerns or seek advice when there is a suspected violation of the Anti-Corruption Policy or other laws directly to the Chairman of the Board. Submissions are treated confidentially and investigated with due diligence.

  • Recordkeeping, transparency and control procedures.

The above rules oblige Elektryk Sp. Ltd. to demonstrate compliance with applicable regulations and relevant procedures designed to ensure the accuracy of accounting books and records. Therefore, Elektryk Sp. z o.o. is guided by the principle of full transparency in its operations and applies adequate control processes.

  • Final provisions

Employees of the company are required to familiarize themselves with the Anti-Corruption Policy, to strictly adhere to its contents. Failure to comply with the Anti-Corruption Policy will result in admonishment, reprimand, disciplinary dismissal, financial penalty and notification of law enforcement agencies, inclusive. Each case of non-compliance with this procedure will be dealt with separately.

Kalisz, 29.04.2021.

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