This Codex has been laid down by the recommendation of the National Chamber of Commerce and “Institute of Democration and Private Business Survey” Foundation based on guidelines of Institute of Business Ethics, London.

PREAMBULE
Building the economy market in Poland and any other country which Nations and Governments express the will to do so is connected with necessity of obeying the rules of ethic and culture of the entrepreneurship. We notice the aim to integrity and honesty in economic service among rising entrepreneurs group for whom obeying the ethical rules and other common known patterns is becoming a fact. Operations which drive to ensure a high quality products and service, integrity between partners, governmental and environmental employees denotes about the responsible way in running a business  and is one of the sources of company’s success. In times of a big competition company cannot exist for a long period of time without the positive mark from surroundings and without obeying the ethical rules.
We claim that in all operations of the enterprises which belong to the Group it is necessary to obey basic ethical rules and recognize the commitments among everyone who is interested in the company’s activity. Honesty is an essential condition to achieve company’s stability and its success. The company’s reputation and its trust are the most important value. Accepting the Codex should be taken as consideration of the values that were mentioned above and the commitment to monitor regularly of obeying those rules.
 
RELATIONSHPS WITH CLIENTS
1. Enterprises which belong to the Group will provide the products and services of a good quality, solid and safe in use. They will also offer the products that are compatible with national and international standards or if those standards will not be defined the enterprise will conduct a safety research. They will not give an incomplete information and bluffing description of the services and products they offer on purpose. They will not hide harmful operation of the products on purpose.
2. In the advertisement and any other form the companies that belong to the Group commit themselves to avoid giving the untrue, overblown or incomplete information.
3. To assure the full satisfaction for the clients the enterprises that belong to the Group will provide the high quality of the services.
4. Employees hired by enterprises of the Group shall not give money or any other gifts to the clients which may be taken as material benefit.
5. Companies of the Group will avoid the practices that will lead to extend the sell by any operations that is against the law.
6. Companies of the Group will keep in secret every withheld information that came from the client.

RELATIONSHIPS WITH STOCKHOLDERS, SHAREHOLDERS AND OTHER INVESTORS
1. Companies of the Group will take care of the stockholders, shareholders and other investors interests as well as they will not do anything to privilege one part of the investors.
2. Companies of the Group will aim to achieve the attractive return of the investment in the long period of time.
3. Companies of the Group will honesty inform about the policy, achievements and a view for the development. 

RELATIONSHPIS WITH EMPLOYEES
1. Relationships between the companies of the Group and their employees will be based on the respect and personal dignity.
2. Companies of the Group will hire and advance employees because of the requirements needed on the specific position. Employees will not be discriminated because of their race, religion, nationality, color of the skin, age, sex, marital status or disability that have no influence for the work’s results.
3. Companies of the Group will seek to assure a stabile workplace and will honestly inform employees about the employment’s outlook.
4. Companies of the Group are committed to assure clean, healthy and safe working environment according to the standard and work regulations. Employees are committed to make an effort to avoid accidents, hurt themselves, colleagues and other people.  
5. Companies of the Group assure the confidentiality of medical data of their employees. Results of the periodic examinations will be share too other employees and outsiders.
6. Companies of the Group will use a clear regulations about the reward policy according to the effort of the employees. Those regulations will be constructed in the way to take into account an individual effort of each employee.
7. Companies of the Group will help their employees in rising their qualifications and they will support their career.
8. Companies of the Group will inform employees about the aims of the company’s activity and tasks on individual workplace.
9. Information obtained from the employees during work will not be used for any other aim than this that those information were obtained for.
10. Companies of the Group committed themselves to reveal direct personal interests of the employees on managerial position and their families if this is connected with the company’s operations. Reveal a potential conflict of the interests may concern chairmen, managers, important shareholders and hiring the members of the family.
11. Companies of the Group will not tolerate sexual harassment and any other form of physical and psychical abuse.
12. Companies of the Group are committed to recognize their special duties according to employees who in a short period of time will retire.
13. Companies of the Group will support relationships between colleagues and retirees.
14. During buying an additional insurance companies of the Group will only have on mind employees avail. Companies will only make an effort to choose the best insurance company or investment fund.
15. Companies of the Group will prepare the regulations of settling disputes and will make everything to settle them without letting this dispute to escalate into the conflict.
16. Companies of the Group will seek to assure the most possible way to contact with the employee. Companies will accept the need to inform and consult employees in the team in which they work. If it is possible employees will be represented in negotiations. If there is an agreement with unions company will assure appropriate solutions which will help to start a constructive dialog.
17. Companies of the Group will honestly inform employees about the dues for the social insurance and about the character of the contracts. Employees will be also informed about contract conclusion. Company will not use the type of contract that is forbidden by the law.
18. In case of firing from job company will help the former employee in finding a new job if it only will be possible.

RELATIONSHIPS WITH PARTNERS
1. Relationships between the companies of the Group and they partners should be based on reciprocal trust.
2. The pay for the service or provided product will be paid in the term definited in the Contract.
3. The financial means of the enterprises which belong to the Group will be used moderately.
4. Companies of the Group accept that taking the gifts and any other financial benefit by the employees of the company that is the part of the Group may cause situations perceived as the attempt to dispose an offer of the financial profits for the donor. This following rules must be obeyed:
       - it is forbidden to set someone to accept the gift,
       - it is forbidden to give financial gifts
       - reasonable, small gifts and expressions of the hospitality may be accepted if they do not cause any commitment for the person for whom the gift was given
       - supervisors should be informed about any received gift and done favor connected with the company with which the collaboration is provided
5. Information that affects the relations between the companies of the Group  and their partners should be taken as confidential.

RELATIONSHIPS WITH COMPETITORS
1. Companies of the Group will honesty compete with competitors and will not discredit they reputation.
2. In the contacts with competitors employees will avoid situations designed to transfer confidential information about the companies of the Group.
3. Companies of the Group will not try to get information about the competition in the way that is against the law. Those methods are: economic espionage, hiring employees of the competitors in the aim to get confidential information, setting the crew of the competitors of their clients to divulge the information they have or any other behavior.
4. Companies of the Group will not use restrictive economic practice that are against the law. 

CONNECTIONS WITH THE GOVERNMENTS AND LOCAL COMMUINITIES
1. Companies of the Group will use best efforts to be socially sensitive business entity, they will attend to the community by the positive operations for the companies that are the part of the Group and the community  and will assure advantageous possibilities of hiring and good working conditions.
2. Companies of the Group will have on mind the interests of the surroundings – for both local and national interests.
3. Companies of the Group should support the local community. Eventual dotation for the charity purpose will be awarded by the rules determined by the owners. 

NATURAL ENVIRONMENT
1. Companies of the Group in they operations will be responsible for the natural environment.
2. Companies of the Group are committed to take about the condition of natural environment. They will use natural resources in responsible way. According to that:
-          the production cycle, wastewater management, removing litter, emissions and noise will be in designated standards;
-          companies will make the analysis of the effects of each new enterprise;
-          they will take a special care about the animals and plants that exist on the territory were the company’s working
-          they will inform local community about the program of environment protection.

BUSINESS-POLITICS CONNECTIONS
1. Operations of the companies of the Group will be characterized by obeying the law, realized by democratically chosen local, regional and national governments.
2. Companies of the Group will not support political operations connected with inculcating hate, prejudice and discrimination aimed to specified group of people or chosen person.
3. Policy of companies of the Group in the range of supporting social and political activity should be transparent.
4. Companies of the Group will not treat chosen politicians or the representatives of the government in a privileged way.

PUBLIC PROCUREMENT
 Companies of the Group will obey the law regulations about the public procurements that take effect in the country of residency, especially:
1. They will not try to make an influence on people by giving them gifts, promising them advantages or giving them financial gratifications.
2. In their offers there will be only those substantive conditions that are actually possible to fulfill.
3. They will show their achievements and experiences honestly.
4. They will not undertake operations that lead to discredit their competitors.

ISSUES CONNECTED WITH THE INTERNATIONAL BUSINESS
1. Companies of the Group will commit themselves to obey legal regulations in the other countries.
2. Companies of the Group will respect traditions and culture of any country in which they undertake actions.
3. Companies of the Group will act responsibly in the range of international trade according to the national and international agreements.

CODEX IMPLEMENTATION
1. Codex implementation should be linked with monitoring of obeying the ethical program.
2. Using the Codex should be the effect of the employees education in the range of accepted rules.
3. Companies of the Group should monitor the compatibility of the undertaken decisions and methods with the rules accepted in the Codex.
4. The aim of the companies of the Group should be to create a positive work climate and possibilities for the employees. All the operations and decisions taken as ethically reprehensible should be explain as fast as it is possible.

This Codex has been written in three languages versions: Polish, Russian and English and takes effect from 1stOctober 2016. It is confirmed by the signatures below made by shareholders, managers, members of the board, proxies and plenipotentiaries of the companies of the Group.