Rawlplug’s Code of Business Ethics

Rawlplug’s Code of Business Ethics

At Rawlplug, we believe that ethical business and profitable business are not mutually exclusive, which is possible because we are fair no matter what we do. We want to be perceived as a partner whom you can trust because integrity really matters to our team. They are people who know that trust is not something you simply hold at hand, and that you win it with your everyday work. People who understand that we are responsible for how we work, and the strength we have today will directly influence our strength in the future. People with whom and owing to whom we consistently pursue our sustainable development strategy, an inherent component of which is Rawlplug’s Code of Business Ethics. And finally, people who are perfectly aware of the fact that our activity, the goals we set, the way in which we prepare our offer, the products we design, the services we render to our customers, and the knowledge we share, which altogether simply boils down to how we run our business – all rely on trust. We have been building this trust for 100 years now, and not just by delivering products of unmatched quality, known to the whole world and conforming to the most stringent safety standards, but also thanks to our everyday conduct, founded on the grounds of integrity. It is integrity that conditions the way we work, how we treat one another, how we care for natural environment and local communities. We want the rules we follow to be completely transparent, and to cause that integrity permeates everything we do, which is precisely why we have developed Rawlplug’s Code of Business Ethics. It defines how we operate on the basis of principles the whole world considers as fair and transparent.

Fair conduct equals ethical conduct. Our desire is not only to make sure our rules of business ethics are applied in practice, but primarily that they are fully understood. This is why we oblige – to the fullest extent of this notion – our personnel and our business partners to become familiar with Rawlplug’s Code of Business Ethics. We consider this to be extremely important, because our overall ethical conduct comprises the behaviour of every employee and business partner. We have identified several dozen most important areas of fair conduct.

Introduction Rawlplug’s Code of Business Ethics

1. Compliance with the law ...................................................................................................................... 6

2. Compliance with the principle of confidentiality and protection of secret information ....... 9

3. Not accepting gifts and favours ....................................................................................................... 10

4. Using Rawlplug’s funds responsibly ................................................................................................ 13

5. Mutual respect, observing human rights and absolute non-discrimination............................ 14

6. Being neutral to any religion ............................................................................................................. 17

7. Respecting privacy of our employees ............................................................................................. 18

8. Ensuring occupational health and safety and respecting their health and life ...................... 21

9. Respect for the environment ............................................................................................................ 22

10. Proper media relations ....................................................................................................................... 25

11. Preventing conflicts of interest ........................................................................................................ 26

12. Observing principles of fair trade and competition ..................................................................... 29

13. Adequate approach to participation in social life ......................................................................... 30

14. Observing regulations on trading in the company’s shares ....................................................... 33

15. Reporting violations of Rawlplug’s Code of Business Ethics ..................................................... 34

32

R AWLPLUG’S CODE OF BUSINESS ETHICSR AWLPLUG’S CODE OF BUSINESS ETHICS

Radosław KoelnerCEO, Rawlplug

We believe that fair conduct is an investment for the future in which the sound foundations of our tradition spanning 100 years give us space to grow and improve continuously. Whatever we do, we want to be trustworthy. We want to showcase our integrity. We want to convince everybody that business can be ethical and profitable at the same time. We want to create. We want to influence. We want to cooperate. We want to support. We want to be role models. We want to be fair. We want to be ethical.

Karol SzczukaBrand Manager

The Rawlplug brand came into being through revolutionary inventions which always responded to the customers’ needs and resulted from their accurate identification. Today, Rawlplug is a globally acclaimed expert in the sector of fixings and fasteners. We have been present in the market for one hundred years, but it would be impossible without the fair attitude to our customers whom we furnish with tailored solutions. In order to face up to this challenge, we never cease to invest in state-of-the-art technologies, we accelerate the prototyping process, we improve and enhance production processes, and we manufacture products conforming with the most stringent global safety standards. And we do it all to make sure our customers trust us and have absolute certainty that they are served only the best solutions.

Sławomir JagłaSustainability Officer/ Integrated Management Systems Manager

Rawlplug understands ethics as a set of principles followed daily by every employee. We want to be perceived as the leader of the sector of fixings and fasteners, combining all aspects of business and ethics, observing rules, standards and legal regulations, investing in the development of an innovative offer, supporting employees and local communities, looking after the environment, and communicating with business partners by sharing with them the same ideas and values as well as a similar attitude to ethics. We are honest, objective, trustworthy, respectful, tolerant, and above all socially responsible, ethical and fair.

Magdalena GrzelakChief Communication Officer

To create efficient dialogue, its participants must trust, listen to and understand one another. Building communication at Rawlplug, we make sure that it is transparent to everyone, that it satisfies their needs and provides evidence that we are genuine and fair in everything we do. We seek to establish durable and friendly relationships with employees as well as all stakeholders.

54


At Rawlplug, we believe that the law sets equal standards of conduct for everybody, that it is irrefutable and unquestionable, and that obeying it is the foundation of integrity.

What this entails is that both our and our partners’ actions must always conform with the law as well as its complementary regulations in force, in every country where we operate. We believe that it is our indisputable duty to adhere to the law, to respect it and to follow it on the level of both the organisation and every human being.

Fair conduct equals compliance with the law1.

law, proper conduct, high standards, good practice, integrity

Remember that we don’t tolerate laws being bent and violated – neither in our operations, nor in the actions of our employees or the companies we cooperate with.

7

R AWLPLUG’S CODE OF BUSINESS ETHICS

6

Rawlplug operates in a highly competitive market where information is the most valuable currency which enables us to maintain competitive edge. We have been involved in innovative research on the development of our products and services, we perform advanced analyses of the market and its surrounding, we have been continuously upgrading our manufacturing plants, but it wouldn’t be possible without people with expertise and competencies, who at the same time have access to the unique and confidential know-how we have built for a century.

Keep in mind that there are numerous forms of proprietary information and intellectual property, these including financial information and analyses, forecasts and growth plans, technical documentation, sales data, marketing strategies and plans, recipes and technological processes, production plans and many other instruments and documents. Providing you with access to all of them is an expression of our trust in you. Behaving honestly ourselves, we believe that those with whom we work and share confidential information are also honest, and consequently refrain from disclosing this information and make sure it is duly protected.

This means that our employees and business partners are provided with what is referred to as proprietary information and intellectual property, of which Rawlplug is the sole proprietor, and they are obliged to protect it by not disclosing it to other persons and businesses in any means whatsoever, as well as to observe our confidentiality clauses and to follow the rules of Rawlplug’s information security policy.

Fair conduct equals compliance with the principle of confidentiality and protection of secret information.

2. confidentiality, knowledge, information protection, trust, integrity

98


Fair conduct equals not accepting gifts and favours3.

The scale of our activity at Rawlplug is truly massive. We are globally present; our reference sites can be found all around the world, and the same applies to our customers and business partners. This is precisely why it is so important to make sure that our relationships with them are fair, and that trade-related decisions are supported by market rationale. In order to deploy such a mode of operation, we have defined strict rules on accepting gifts and favours.

Remember that small expressions of business courtesy the purpose of which is to build relationships are not harmful in general, but never accept a gift, a favour or even a meal from a business partner if:

1. the gift, favour or meal are TOO VALUABLE, or in other words they are generally perceived as too expensive,

2. the gift, favour or meal are intended to ENCOURAGE US to make a specific decision, or they even merely make such an impression,

3. the gift, favour or meal are intended as an EXPRESSION OF GRATITUDE for a decision already made, or they even merely make such an impression.

Should you have any doubts in this respect, contact your supervisor or talk to Rawlplug’s HR Director, who will help you make the right decision and explain whatever seems unclear.

This means that NONE OF US IS ALLOWED to accept gifts and favours given to us with an intent to induce specific business decisions, given as an expression of gratitude for having made such decisions, or even merely appearing as such. Neither are we permitted to accept excessively generous gifts or too expensive meals.

objective decisions, rationality, relationships, independence, integrity

11


10

Rawlplug is the people in the first place. Our team is the most valuable resource we have – the engine driving our growth. But Rawlplug also comprises other resources such as assets, movable property or funds. It is extremely important that each of us knows when, to what extent and how these resources can be effectively used.

Fair conduct equals using Rawlplug’s funds responsibly4. assets, goods,

resources, reason, integrity

Keep in mind that in terms of responsible use of Rawlplug’s funds, the supervisor’s consent is always required, and you are obliged to abide by the following rules:

1. YOU ARE NOT allowed to transfer the company’s assets (e.g. as gifts) or financial resources to any governmental agency or public servant. The only exception to this rule is acting in accordance with a written consent issued by Rawlplug’s HR Director.

2. YOU ARE NOT allowed to use the company’s financial resources or grant any gifts to encourage any person to make specific decisions or to receive preferential treatment. There are no exceptions to this rule, since any infringement thereof will always be considered as bribery, and so it is strictly forbidden.

3. YOU ARE NOT allowed to use the company’s financial resources or any other assets for unethical or illegal purposes.

Should you have any doubts in this respect, contact your supervisor or discuss it with Rawlplug’s HR Director, who can explain whatever seems unclear.

This means that we can only make use of the company’s resources when pursuing a specific business objective, and never for private purposes. Consider the following simple examples: you should only use a computer or a car owned by the company for official purposes, i.e. to perform your duties and professional tasks. When using a company credit card, buy what is necessary for your daily activities or the projects you are involved in. When on a business trip, settle the costs fairly, and keep in mind that no expenses incurred in your free time (e.g. a museum ticket) are recognised as eligible business trip costs. Making use of the company’s resources, and financial resources in particular, always requires your supervisor’s prior consent.

1312


Rawlplug stands for 100 years of market presence, which involves 100 years of experience in managing human resources. The company is a melting pot of personalities and cultures, running its divisions in more than a dozen countries on several continents. It forms a magnificent mixture of diverse characters and personalities, which gives us strength and makes us all the more creative and open to new perspectives. It is the people who must feel well to be able to work well. This is precisely why we are all bound by the principle of equality, the strict prohibition against discrimination and violation of human rights, as well as the rule of equal opportunities in employment.

Keep in mind that all members of the Rawlplug team enjoy identical rights and are remunerated in recognition of their work and its outcomes exclusively. Don’t forget as well that, by any means whatsoever, you are not obliged to like everyone equally; it will suffice if you just treat every colleague like you yourself would like to be treated.

Remember that if anyone makes you feel bad at work, you should report it immediately to your supervisor and Rawlplug’s HR Director.

Consequently, any manifestation of discrimination is strictly forbidden, and each member of the Rawlplug team, regardless of the position occupied in the company, is treated with equal respect, affection and openness, irrespective of one’s sex, skin colour, denomination, age, sexual orienta-tion, beliefs, health condition or social affiliation. It is also absolutely impermissible to violate one’s personal dignity through such malpractices as mobbing, harassment, sexual abuse, or psychological and physical violence.

We also guarantee equal employment opportunities at Rawlplug, meaning that everyone is employed on the basis of one’s skills and experience, as required at the given position, and that no other aspects matter to us.

Fair conduct equals mutual respect, observing human rights and absolute non-discrimination

5. tolerance, respect, equal opportunities, collaboration, integrity

15


14

As an international company, we have a very diverse team. We are a group of people from all over the world who, though sharing a great passion for work, differ in their cultural and religious heritage. We believe that the differences between us give us unlimited levels of creativity and we make sure that everyone, regardless of their faith, feels good with us.

Remember! Our neutrality towards all religions means that you have freedom of religion and religious commitment and the obligation to respect this freedom for others. If someone makes you feel discriminated because of your religion or violates the principle of religious neutrality in any way, please report it to your supervisor or HR Director.

This means that we remain neutral towards all faiths, and every member of our international team has the freedom of religion. We do not support or impose any religious worldview, nor do we have any religious symbols, because we believe that this is the only way we are able to express respect for all faiths and religions.

Fair conduct equals being neutral to any religion.6. neutrality, faith,

religion, freedom, respect, integrity

1716


Rawlplug employs more than 1,500 people all over the world, and that involves processing massive amounts of information about our workers. We respect the privacy of every member of our team, also making sure that it is not breached by anyone else.

Remember that your privacy matters to us, which is why we respect and protect it, so that you can feel at ease and be sure that no one violates it. Should you have any doubts in this respect or feel that someone fails to respect your privacy, inform your supervisor or Rawlplug’s HR Director about it.

This means that we have been limiting the access to confidential information concerning our employees. It has only been granted to those who require it for HR management and legal purposes. They take care of adequate protection and archiving of such information, being ethically and legally obliged to maintain their confidentiality, which simply boils down to not disclosing them to any other parties.

The respect towards the privacy of our employees also manifests itself in the respect towards their workplaces and the personal belongings stored there. This means that one is forbidden to search through someone else’s workplace (including the computer) or take whatever belongs to another employee who occupies the given workplace.

Fair conduct equals respecting privacy of our employees7. privacy, data protection,

employee, reliability, integrity

19


18

At Rawlplug, we truly care about safety and health of our employees. And since production is in fact our core business, the profiles of individual positions and the threats associated with them differ significantly, and so they require diverse OH&S rules to be implemented for each of them.

It is important that whenever you notice any noncompliance with the applicable OH&S rules, and not just at your position but also among other colleagues, don’t hesitate to report it to Rawlplug’s occupational health and safety specialist.

This means that depending on whether you work at the desk, warehouse or shop floor, you are obliged to attend the OH&S training dedicated to your specific work profile held on a cyclic basis, where you are instructed about the occupational health and safety principles that apply to you specifically, about your rights as well as about the person to whom to turn for help. You can also learn how your workplace should be arranged to ensure safety and comfort.

We are all obliged to be familiar with and abide by the OH&S rules in force at Rawlplug, as they provide the grounds to ensure safe working conditions for all of us and to minimise the negative impact of work on our physical and mental health.

Fair conduct equals ensuring occupational health and safety and respecting their health and life

8. health, occupational safety, protection, comfort, integrity

2120


At Rawlplug, we are perfectly aware of the carbon footprint we leave as a heavy industry enterprise. For that reason, the concern about the environment is one of the foundations of the sustainable development strategy we have been consistently implementing. Our environmental efforts are based on world-class standards, and we never limit ourselves merely to what is imposed upon us by the law. The endeavours we have been constantly undertaking prove just that. We strive to build the awareness of the role natural environment plays in every person’s life. We create and disseminate best practices for the sake of respect towards our planet. At every stage of our operations, we promote high environmental awareness.

Remember that if you are environmentally concerned about any aspect our operations or if you come up with an idea of new eco-friendly actions we might be able to deploy, contact the competent environmental protection specialists or report it to your supervisor.

Consequently, as a means to showcase our concern for the environment, we operationally rely on an environmental management system, and this involves our attention to and diligent pursuit of all the relevant standards. We respect the applicable legal regulations pertaining to environmental protection, and therefore we comply with all environmental requirements. We are focused on efficiency, both in qualitative and quantitative terms, as well as on the effectiveness of the solutions deployed under all our actions related to environmental protection. We monitor environmental metrics on an ongoing basis and, based on the results thus obtained, we constantly work towards improving actions that minimise potentially negative environmental impacts. Our products are packed in eco-friendly containers. We participate in environmental protection campaigns of both local and global reach, thus seeking to improve the awareness of this problem among our employees and business partners as well as local communities.

Fair conduct equals respect for the environment9. environmental

protection, care, sustainable development, awareness, integrity

23


22

We believe in transparent communication at Rawlplug. But it requires proper media relations, consistency as well as efficient and balanced information sharing.

So if you have been contacted by a representative of the media, requesting specific information, refer them to Rawlplug’s Communication Department by providing their e-mail address: [email protected]. Don’t share any information, even if you are perfectly familiar with the matters to which the media refer.

This means that we want to furnish the media with transparent, comprehensible and reliable information, but we must always mind the obligation to protect confidential information, which entails due diligence in this respect. What we also consider extremely important is the coherence of our communication. Hence the rule we have been following at Rawlplug that only members of the Management and competent spokespeople, i.e. persons authorised to speak on behalf of the Management, can actually contact the media. Only they can share information on what has been happening inside the Rawlplug Group with the media, and inform them about our achievements, results and plans, comment upon matters related to the personnel, customers, shareholders or creditors, and speak about the company’s growth and offering. No one else is authorised to furnish the media with information concerning the company’s daily matters.

media, information, communication, diligence, integrity

Fair conduct equals proper media relations10.

2524


One may speak of a conflict of interest when an employee’s private interest collides with that of the employer, or when an employee illegally obtains benefits thanks to the position held at the company. Rawlplug’s personnel is very numerous, which is why it is so important to avoid any situations potentially leading to a conflict of interest or bearing its risk.

Fair conduct equals preventing conflicts of interest11.

We are perfectly aware that each of us may face a potential situation where some of our loved ones (e.g. a spouse or partner, children, siblings, parents, parents-in-law, friends) work for Rawlplug’s competitor, supplier or business partner (or even run such an activity themselves), which obviously poses a risk of evoking conflict of interests. This is why IT IS VITAL that you inform Rawlplug’s HR Director about any such case, and discuss the optimum solutions to be applied. Never forget that a conflict of interest arises when your personal relationships or your actions compromise your ability to act in Rawlplug’s interest.

This means that, when performing one’s official duties, every single one of us must act to the best interest of the company. No decisions made at work should be substantiated by an intent to gain private advantage. Neither are we allowed to make use of our knowledge of business opportunities, investments and plans made by Rawlplug to pursue our own goals or draw personal benefits – both for us and people we know. We are forbidden to become involved in undertakings whose nature is competitive towards Rawlplug’s operations. There is also a rule at Rawlplug that we refrain from any favouritism while selecting business partners, while only relying on the advantages and benefits which can be derived from collaboration with them. Consequently, we should also avoid any situations where one could question the impartiality and objectivism of our decisions in this respect.

honesty, objective decisions, shared goals, credibility, integrity

27


26

We have been operating in a very competitive market, where we actively seek to win customers from all over the world, successfully selling our products for 100 years. Our customers have put their faith in us because ever since Rawlplug was founded we have been building the reputation of a fair market player, who not only cares for the customers, but also respects competitors, suppliers and business partners.

Keep in mind that each of us must be particularly precautious and sensitive when contacting competitors. Regardless of how harmless it may seem just to talk to a representative of the competition, it always involves a risk that it may legitimise being accused of improper or even illegal conduct. So try to avoid any such situations, and in the event of doubts, contact the Legal Department of Rawlplug.

This means that, whatever we do in the market, in whichever country we are present, we always observe the antitrust laws and the principles of fair competition. We never enter into any agreements with the competition, including ones which restrict trade or limit the effectiveness of operations, such as those that comprise price fixing, production restrictions as well as quality control and market sharing. All these practices are illegal, and hence strictly forbidden. Rawlplug admits no exceptions to this rule. We are independent in action, and we enable the same to other market participants.

Fair conduct equals observing principles of fair trade and competition

12. reputation, trust, transparency, care for customers, integrity

2928


Rawlplug supports no political grouping. At the same time, all our employees have the right to express their opinions and support any organisations of their choosing (e.g. political, charity, public utility ones) as well as to be involved in social life. However, we must see to it that such an activity is not associated with Rawlplug by any means whatsoever.

Remember that at Rawlplug we respect your beliefs and refrain from limiting your involvement in social life outside the workplace, but make sure to always separate your activity in this domain from the professional life at Rawlplug. Should you have any doubts in this respect, contact Rawlplug’s HR Director.

In other words, you have the right to support any organisation or idea in your free time. What matters is that your actions must not be interpreted as those of Rawlplug.

Fair conduct equals adequate approach to participation in social life

13. image, social life, values, involvement, integrity

31


30

Remember that insider trading, dealing and advice is prohibited with regard to the shares of both Rawlplug as well as our affiliates and subsidiaries, and that making use of non-public information to which Rawlplug’s employees and partners have exclusive access is forbidden. In order for information to become public, it must first be duly disclosed, i.e. made known to the general public via authorised persons representing the company. Then, sufficiently long time must pass to enable everyone to become familiar with the information in question. Some examples of authorised information disclosure may include press releases, meetings with journalists and representatives of the general public, as well as furnishing specific information to bodies in charge of trade in securities (e.g. the Financial Supervision Authority).

This means that any party interested in purchasing Rawlplug’s shares should have access to identical publically available information about the company. Therefore, both our internal policy and the applicable law clearly stipulate that one cannot buy or sell Rawlplug’s shares in the event of having access to non-public information concerning the company (an exception to this rule being shares sold or purchased in accordance with a pre-established trading plan). This is referred to as insider trading, and it is considered illegal, impermissible and unethical. Such a transfer of non-public information concerning Rawlplug to parties who can either buy or sell the company’s shares, referred to as insider advice, is also impermissible and legally prohibited.

Rawlplug is a listed company, which means that we are bound by certain specific rules on buying and selling our shares. What matters particularly in this respect is the information disclosure obligation, aimed to ensure that the present and future owners of financial instruments (e.g. Rawlplug’s shares) are provided access to information concerning Rawlplug, and to eliminate the information asymmetry between market participants.

Fair conduct equals observing regulations on trading in the company’s shares

14. shares, supervision, information disclosure, transparency, integrity

33


32

We see to it that the ethical standards of Rawlplug are followed on every level of the organisation and in every country where we operate. If you have an impression that the actual actions depart from these standards, or if you need additional explanations concerning the matters of ethics at Rawlplug, let us know about it.

And should you notice any violations of Rawlplug’s Code of Business Ethics, don’t hesitate to report it. No matter if the given violation concerns you directly or not – report it immediately. There are several ways to do it anonymously:

Fair conduct equals reporting violations of Rawlplug’s Code of Business Ethics

15.

by sending a written report to the following postal address:RawlplugDyrektor HRul. Kwidzyńska 6, 51-416 Wrocław

by submitting a report to the following e-mail address: [email protected]

by contacting our special call centre: +48 71 326 01 00

ethics, standards, contact, sense of security, integrity

35


34

If, having answered these questions, you still have doubts, you can always talk to your supervisor or the HR Director, who will both come to your aid by explaining the rules of ethics we follow at Rawlplug.

Remember that your judgements and actions matter, and that they exert influence on how Rawlplug functions.

Rawlplug’s Code of Business Ethics is intended to help you understand the principles of ethical conduct at Rawlplug and to provide you with the guidance you may need to follow these principles on a daily basis. We know life shows a tendency to surprise us, and everyone may sometimes have ethical doubts in situations not covered by Rawlplug’s Code of Business Ethics. Where this is the case, before you proceed with an intended action, please ask yourself the following questions:

Things worth remembering It’s good to work in an ethical company because:

Does it comply with the law?

Does it correspond to how we work at Rawlplug on a daily basis?

Does it conform with my personal beliefs and values?

Will I feel good about it if I proceed with the intended action?

Will I not breach any professional regulations or generally acceptable rules of conduct by doing so?

Can I openly tell others about what I have done?

YOU ARE AWARE of the fact that all your actions matter

YOU HELP in creating good business practices

YOU ACT with integrity, taking care of the environment, your colleagues and the local community

YOU WORK in good and friendly atmosphere

YOU ARE SURE of not being exposed to discrimination

YOU ARE PROVIDED with identical development

opportunities as your co-workers

YOU WILL always receive HELP and advice when facing ethical dilemmas

3736


Rawlplug S.A.ul. Kwidzyńska 651-416 Wrocław

tel. +48 71 32 60 100fax +48 71 37 26 111

www.rawlplug.com

Documents

Rawlplug’s Code of Business Ethics