While the practice of giving and accepting gifts may help foster relations with our business partners, in some cases it may be considered a form of corruption or may damage the reputation of Grupa Azoty Zakłady Chemiczne Police S.A. and the Grupa Azoty Group. Therefore, the Company has put in place the Gift Policy of Grupa Azoty Zakłady Chemiczne Police S.A., comprising the applicable rules for its employees and associates.

The Gift Policy clarifies the general principles and rules included in the Code of Ethical Conduct and the Anti-Corruption Code, providing employees with more detailed guidance on the types of gifts they may give or receive, as well as conditions under which giving or receiving gifts is allowed at Grupa Azoty Zakłady Chemiczne Police S.A. and rules that must be observed in such cases. In accordance with the ‘Zero Tolerance for Corruption’ principle, the rules of conduct described in the policy reduce the risk of corruption being alleged against Grupa Azoty Zakłady Chemiczne Police S.A. in all jurisdictions where it operates.

The procedure to be followed depends on the value of gifts received or given. For gifts with a gross unit value in excess of PLN 200 it is necessary:

• where such gifts are given – to notify the relevant department/organisational unit, which is then required to generate appropriate tax returns;
• where such gifts are received – to prepare a monthly register, which must then be provided to the relevant department/organisational unit to be recognised in the Company’s tax accounts.

It is forbidden for one person to be handed gifts with a gross value in excess of PLN 400 within one year.

The acceptance of gifts, financial benefits or personal gains by an employee who:

• is involved in a procurement procedure, or
• is directly involved in the selection of suppliers or service providers, or
• supervises the performance of contracts, or
• certifies the completion of works,

 is forbidden.

Gifts in the form of cash or cash equivalents (e.g. gift vouchers or shares) are forbidden.

Furthermore, to promote moderation among our employees at business meetings, Grupa Azoty Zakłady Chemiczne Police S.A. has introduced rules concerning the one-time cost of a meal (including drinks). Such cost should not exceed (on average per person):

• in the case of breakfast – PLN 100 gross in Poland and the equivalent of EUR 50 gross abroad;
• in the case of lunch – PLN 150 gross in Poland and the equivalent of EUR 75 gross abroad;
• in the case of dinner – PLN 200 gross in Poland and the equivalent of EUR 100 gross abroad.

The cost of tips, if any, given during business meetings should be covered by the inviting party out of their private money.

Any suspected breaches of Grupa Azoty Zakłady Chemiczne Police S.A.’s Gift Policy should be reported to:

Whistleblowers Reports Representative
Email: ##hnvcpaxhip.edaxrt#at#vgjeppodin.rdb##
Phone: +48 519 501 543

or by mail to the Company’s address:

Grupa Azoty POLICE
ul. Kuźnicka 1
72-010 Police, Poland