Code of Conduct
Grupa Azoty SA
Code of Ethical Conduct
For Grupa Azoty, the top priority is to conduct its business in a trustworthy and responsible manner. Our ambition is to be an entity that communicates the values and principles it has adopted openly and precisely.
We have decided to set out our desired attitudes and ways of acting in this Grupa Azoty Code of Ethical Conduct. This document defines the priorities of our activities aimed at shaping employee attitudes, as well as influencing how relationships are built with the environment in which our Organization operates.
Above all, however, it is our commitment—one we want to remember every day.
In this document, we emphasize what one should expect from the way Grupa Azoty and its Employees conduct themselves. We treat all declarations contained herein with the utmost seriousness and undertake to ensure that what we do fully aligns with what the Grupa Azoty Code of Ethical Conduct says. We hereby make it available to all our stakeholders.
The Grupa Azoty Code of Ethical Conduct is addressed to all those employed within Grupa Azoty, regardless of position, length of service, type of contract, working hours, or scope of responsibility.
Moreover, the provisions of the Code are also directed to our customers, business partners, shareholders, and other stakeholders operating in the environment of Grupa Azoty. By indicating in the Code the principles by which we are guided, we are also convinced that the external entities cooperating with us will fully respect our commitment to the content and spirit of the Grupa Azoty Code of Ethical Conduct.
The Grupa Azoty Code of Ethical Conduct defines and sets out the values of our Organization. They take the form of general rules of conduct, which in turn give rise to specific requirements outlined in individual parts of this document.
The values of Grupa Azoty serve as our compass whenever a particular situation is not directly reflected in the Code’s provisions.
We also treat these values as a declaration toward our stakeholders, indicating what is important to Grupa Azoty and what we always remember when building relationships with our Employees and our external environment.
They also constitute our commitment to continuous development and the active shaping of our organizational culture, including its ethical dimension.
Efficiency – For us, efficiency means responsible management of Grupa Azoty’s tangible and intangible assets based on economic principles. We manage all assets in a way that maximizes benefits for both the shareholders and other stakeholders.
Professionalism – We ensure that our management approach, operational standards, and control systems are well-designed, effective, and guarantee the implementation of our business strategy. Professionalism is an attitude that implies the highest diligence in applying our knowledge, skills, and business competencies.
Cooperation – By cooperation, we understand shaping mutual relationships so as to maximize Grupa Azoty’s benefits while simultaneously recognizing and respecting the interests of the other party. For us, it means communication aimed at reaching an understanding, building trust, and achieving shared goals.
Respect – Expressed by refraining from actions, decisions, or statements that violate another person’s dignity. It obliges us to protect human rights and dignity, and to respect nationality, race, gender, age, disability, religion, political orientation, and sexual orientation, as well as diverse viewpoints and opinions.
Transparency – For us, this means openly communicating our decisions, activities, and the reasoning behind them, as well as the expectations and requirements set by Grupa Azoty. We maintain this attitude in all areas of our operation, except those that must remain confidential for business reasons or under applicable law.
Responsibility – Means that we act out of concern for the safety and well-being of Employees, customers, and others who may be affected by our actions, as well as for the natural environment and the local communities in which we operate. It also includes caring for entrusted tangible and intangible resources.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
The ethical values and principles of doing business adopted by Grupa Azoty constitute a set of standards governing business and ethical conduct that apply to its key stakeholders: Employees, shareholders, business partners, and local communities.
Grupa Azoty’s ethical values and principles of doing business also define a set of shared values and goals to strengthen Grupa Azoty’s image as a socially responsible company that operates based on professionalism and the high personal culture of its Employees, as well as mutual respect for each other and the entire environment. They also set standards for all partners with whom Grupa Azoty maintains business relations.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
It is a foundation of Grupa Azoty’s operations and part of its strategy to conduct business responsibly—in accordance with the principles of sustainable development and social responsibility.
Grupa Azoty minimizes its environmental impact, improves its management systems, pursues an open information policy, engages in dialogue with local communities, and cares for the safety of Employees and the Company’s surroundings.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
In all areas of its business, Grupa Azoty adheres to statutes, regulations, and all other relevant provisions of national law, EU law, and international law.
We comply with industry regulations and local legal requirements.
We follow decisions issued by authorized offices at national, regional, and local levels.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
We operate on a large scale, so one of our ambitions remains to be regarded as a good partner in relationships with all entities that make up our value chain.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
Our Customers are our most important partners. Together with them, we create the value of our corporate group while enabling them to achieve their own business objectives. Knowing how important they are for our short- and long-term functioning, we require all our Employees to take care of every customer’s best interest.
Building our relationships on a partnership basis is our duty. This should guide our discussions about the customer’s expectations regarding the products offered to them, the quality of service, as well as the goals they set for themselves and the directions of their development.
We act in such a way as to understand these to the greatest extent possible, to adapt to continually changing market conditions, and to earn and strengthen their trust.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
Our relationships with customers are reflected in the following principles:
• We honor mutual arrangements.
• We adhere to market rules and standards.
• We provide customers with access to products meeting the highest quality standards, with pricing that ensures benefits for both parties.
• We actively seek to understand our customers’ needs and strive to meet them, adapting our offerings accordingly and working to support customers in overcoming problems they may face in their businesses.
• We focus on building transparent and professional relationships with our Employees—especially sales representatives—and with customers.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
• We provide complete information about our products, their properties, and their intended uses, except for information constituting trade secrets or subject to legal protection under applicable law.
• We provide reliable, truthful, and complete information about our products.
• We educate and actively build our customers’ knowledge and awareness about our products, particularly concerning their economically optimal and safe use.
• We ensure efficient and timely service to our customers worldwide.
• We always address customer complaints and comments in good faith, taking their legitimate interests into account; we thoroughly analyze their causes and initiate and implement solutions aimed at preventing similar situations in the future.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
We are fully aware of the importance of continuously meeting the highest standards for products and services delivered to our customers.
To achieve this, our relationships with suppliers and other business partners must be based on honesty, transparency, professionalism, and mutual respect.
We believe that cooperation built on these principles will enable all entities in the value chain to develop sustainably while ensuring we meet the expectations of the consumers of all our products.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
We base our cooperation with business partners, including suppliers, on the following principles:
• When selecting a partner with whom we intend to cooperate, we comply with all applicable laws, internal regulations, and the need to meet our customers’ expectations.
• We enable potential suppliers to familiarize themselves with our adopted supplier selection principles, cooperation rules, and conditions, as well as provide information on the procurement process.
• We exercise the highest diligence to protect information provided to us by our suppliers and other business partners.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
• We act responsibly in making commitments; we fulfill them on time and in accordance with the agreed commercial terms, expecting the same from our partners.
• We evaluate business partners solely on substantive and business criteria, and we only provide feedback about our cooperation in good faith.
• We expect our business partners to adopt the same approach. We communicate our detailed expectations toward partners in the Code for Business Partners.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
We conduct our activities in numerous locations and in the midst of many diverse communities. We form an integral part of their reality.
We want our relationships to be based on a mutual understanding of the conditions under which we operate and on full trust in each other’s intentions.
We value open and honest communication. We strive to reduce the extent of any negative impact while simultaneously increasing the positive effects of our activities.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
As a member of local communities, we follow these principles:
• We present an attitude that is open and geared toward cooperation.
• In our contacts with local community representatives, we respect their dignity and good name.
• In conflict situations, we seek solutions that protect the legitimate interests of each party.
• We stay attuned to the needs of our environment.
• We do not allow political views to influence our actions.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
Caring for the state of the natural environment is our duty. It is our commitment to shareholders, Employees, local communities, and future generations. With this in mind, we strive to develop sustainably, in full respect for the environment.
As an entity that considers the natural environment a significant value, we are guided by the following principles in our operations:
• We comply with all applicable laws regarding environmental protection.
• We have established and continually improve our management systems related to environmental protection.
• We analyze potential environmental risks related to our operations and, where justified, undertake preventive measures.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
• We prioritize rational management of the resources used in production processes.
• We make every effort and implement and use environmentally friendly technological solutions.
• We care for the natural environment in the workplace.
• We engage in educational activities aimed at enhancing environmental awareness both within the Organization and in our social environment.
• We optimize our processes with regard to energy efficiency.
• We take intensive measures to significantly reduce our carbon footprint.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
4.1. LEGAL RESPONSIBILITY
We actively manage the risk of noncompliance with legal requirements applicable to Grupa Azoty’s operations.
The decisions of Grupa Azoty’s corporate authorities or any initiatives undertaken within or outside our Organization are preceded by legal consultations.
We operate on markets around the world, so we remain mindful of the need to comply with legal requirements in force in individual markets.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
As a responsible organization and a participant in social life, Grupa Azoty also observes applicable laws and ethical standards in the area of human rights protection and respect.
As Employees of Grupa Azoty, we are all obliged to protect and respect human rights, regardless of our position or function. We expect our business partners to adopt similar commitments.
We are systematically building Employee awareness and continuously refining our practices concerning human rights protection in internal and external relationships.
We also shape a working environment free from practices infringing human rights. We demand similar commitments from our business partners.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
When conducting our business, Grupa Azoty respects and protects human rights in accordance with legal regulations, in particular:
• The OECD Guidelines for Multinational Enterprises
• The UN Guiding Principles on Business and Human Rights
• The principles and rights contained in the eight fundamental conventions indicated in the ILO Declaration on Fundamental Principles and Rights at Work
• The principles and rights contained in the International Bill of Human Rights
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
We uphold human rights in every area of our business activity. We build our relationships with our business partners primarily on equal treatment and mutual respect.
In our relations with Employees, Grupa Azoty applies the highest standards of respect for human rights, with a particular emphasis on ensuring privacy, the right to social security, and high-quality health protection.
We combat all forms of modern slavery, forced labor, or torture. We strictly observe the prohibition on employing minors. We act for the welfare of underage individuals and in their best interest in situations arising from our operations (e.g., apprenticeships, internships). Respecting all rights connected to personal dignity, we also respect, protect, and promote family and parental values (the right to family life). We regard the protection of human rights as strategically important.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
We apply due diligence principles to identify and reduce the risk of human rights violations.
We implement programs and procedures aimed at minimizing the negative impact of our activities on Employees, customers, suppliers, and local communities.
We ensure that our business relationships—including those with business partners, suppliers, and subcontractors—align with our human rights commitments.
We support diversity in the supply chain by collaborating with large, medium, and small enterprises.
We undertake to cooperate with our business partners in all efforts to promote the observance of human rights.
With the aim of guaranteeing full protection of all human rights, we continuously monitor their observance in relationships with all entities that form our value chain.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
The business activity pursued by Grupa Azoty requires collecting and storing information about Employees, customers, suppliers, and other business partners.
Each of us has a fundamental duty to protect this information at all costs and to use it only for clearly defined and legitimate purposes.
Failure to maintain the confidentiality of information entrusted to Grupa Azoty Employees not only leads to internal disciplinary consequences but may also pose a risk of legal action being taken against the entities within Grupa Azoty.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
Our approach to privacy protection and information confidentiality is expressed through the following principles:
• We comply with all regulations and rules related to protecting the privacy of Employees and business partners.
• We share confidential information only with authorized individuals.
• We immediately report any noticed weaknesses in the confidentiality protection system.
• If we come into possession of sensitive data accidentally or due to an Employee’s mistake, we secure it immediately.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
In external communication, we emphasize providing information that is reliable and credible.
We apply this approach in our relations with shareholders, the media, potential investors, financial analysts, and other stakeholders.
Contact with the market environment takes place solely through authorized Employees.
In all communication, we keep in mind the interests of the Company, its shareholders, all Employees, and business partners.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
The fundamental principles we follow in communicating with the market environment are:
• We disseminate only information that is factual, provided in a timely manner and with the principle of equal access to information in mind.
• We communicate professionally, maintaining an attitude focused on substantive cooperation and building positive relationships.
• We maintain contact with the media solely through organizational units responsible for communication.
• We present current and forecasted financial results in accordance with the specific requirements applicable to public companies.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
The effective integration of tangible and intangible values determines a company’s value, contributing to the building and continuous development of competencies. Therefore, in our relations with shareholders, Grupa Azoty focuses on:
• Building informed, united, and stable relationships with institutional investors and brokers.
• Providing shareholders and the market with reliable information about our strategy and financial position.
• Communicating information professionally and factually, with particular emphasis on regulations applicable to public companies.
Grupa Azoty supports fair and open trading in financial instruments, and our Employees do not use inside information obtained in the course of their work for capital transactions.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
We respect our Employees’ right to make their own independent decisions in personal, financial, or political matters. Employees, however, are required to avoid situations that may result in a conflict of interest. A conflict of interest arises when an Employee, by taking actions that benefit them or another person or entity to whom they have family, professional, or business obligations, simultaneously harms Grupa Azoty’s interests.
Each Employee must perform their assigned tasks with due regard for Grupa Azoty’s interests and in compliance with the rules and procedures established within our Organization. We make business decisions impartially, always keeping the Company’s welfare and interests in mind. This means that all forms of corrupt behavior are strictly prohibited.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
Employee health and safety is our priority.
We constantly strive to improve the level of health protection for all individuals employed within our Organization.
We shape Employee attitudes through training, by sharing best practices, and by monitoring workplace safety conditions.
We want each one of us to serve as a model of safe conduct for others, and we want any observed behavior suggesting disregard for health and safety regulations to receive an immediate response.
GRUPA AZOTY’S ETHICAL VALUES AND PRINCIPLES OF DOING BUSINESS
In taking care of health and safety in the workplace, we observe the following principles:
• We strictly comply with all established health and safety standards and regulations.
• In situations that pose a threat to health or safety, we act in accordance with accepted instructions and procedures.
• We participate in training and other forms of knowledge-sharing regarding health and safety at work.
• We ensure the safety of third parties present in locations occupied by Grupa Azoty.
• We report any observed situations that may pose a threat to health and safety in the workplace.
GRUPA AZOTY EMPLOYEES’ ETHICAL VALUES AND PRINCIPLES OF CONDUCT
Aside from ensuring the highest quality of products and services, our success also stems from honesty toward stakeholders, transparency in action, and care for Employees and the environment. These principles reflect our responsible approach to managing Grupa Azoty. The introduction and operation of the Grupa Azoty Code of Ethical Conduct testify to our sense of accountability for the business we run.
Grupa Azoty Employees’ ethical values and principles of conduct indicate the desired and undesired attitudes and behaviors of Employees. These values and principles apply to all Employees, regardless of their position, the type of work they perform, or the form of employment.
GRUPA AZOTY EMPLOYEES’ ETHICAL VALUES AND PRINCIPLES OF CONDUCT
Company property is available to each of us to carry out our assigned tasks, and for Grupa Azoty it is a resource used to achieve its business objectives. We are obliged to protect it and use it properly.
Carelessness, wastefulness, or theft of our resources have a direct impact on the Company’s performance. Intellectual property is also an important asset of our Company. Its protection is critical for building and maintaining our market advantage.
Our inventions and patents, trademarks, our scientific and technical knowledge, and the expertise gained through our business activities constitute a key factor for long-term market presence.
GRUPA AZOTY EMPLOYEES’ ETHICAL VALUES AND PRINCIPLES OF CONDUCT
Recognizing the importance of the Company’s property and its related intellectual property, we follow these principles:
• We protect the Company’s property, safeguarding it from damage, loss of value, or theft.
• When using the Company’s resources entrusted to us, we take the greatest possible care of them.
• We use Company property for work-related purposes. We do not use Company assets for personal gain.
• We protect our Company’s intellectual property.
• We only use the Company’s logo and trademarks in an authorized manner.
• We respect the intellectual property rights of other entities; we do not use any third party’s intellectual property in an unauthorized or unfair manner.
• We only use licensed software on our business computers.
GRUPA AZOTY EMPLOYEES’ ETHICAL VALUES AND PRINCIPLES OF CONDUCT
3.1 WE ACT ETHICALLY
In our mutual relations, all Grupa Azoty Employees undertake to observe the following principles of ethical conduct:
• We keep our word.
• We are honest; what we say is consistent with how we act.
• We treat everyone with full respect for their dignity.
• We only use entrusted assets and information in a legitimate way.
GRUPA AZOTY EMPLOYEES’ ETHICAL VALUES AND PRINCIPLES OF CONDUCT
3.2 WORKPLACE ATMOSPHERE
GRUPA AZOTY EMPLOYEES’ ETHICAL VALUES AND PRINCIPLES OF CONDUCT
3.2 WORKPLACE ATMOSPHERE
Aware of the importance of a positive work environment, we are guided by the following principles:
• We build internal relationships based on mutual respect and a high level of personal culture.
• We oppose behaviors that lead to conflicts disturbing the work atmosphere.
• We do not engage in behavior that constitutes discrimination based on race, ethnicity, religion, sexual orientation, age, or gender.
• We oppose and do not engage in any form of harassment or mobbing.
• We do not use our position in a way or for a purpose that violates the personal rights of other Employees.
• We do not spread false information about other Employees or about Grupa Azoty.
GRUPA AZOTY EMPLOYEES’ ETHICAL VALUES AND PRINCIPLES OF CONDUCT
3.3 EQUAL OPPORTUNITIES FOR EMPLOYMENT, PROMOTION, DEVELOPMENT, AND PROFESSIONAL ADVANCEMENT
One of the key means of ensuring our Organization achieves its business goals is to guarantee equal opportunities in recruitment processes, employee evaluations, determining professional development paths, and making decisions about promotions or pay adjustments.
Our aim is to apply transparent employee-related criteria based on their experience, performance, potential, and the values they uphold in the workplace.
GRUPA AZOTY EMPLOYEES’ ETHICAL VALUES AND PRINCIPLES OF CONDUCT
3.3 EQUAL OPPORTUNITIES FOR EMPLOYMENT, PROMOTION, DEVELOPMENT, AND PROFESSIONAL ADVANCEMENT
At Grupa Azoty, we adhere to the following principles:
• Individuals employed and those applying for employment are judged fairly, considering only substantive criteria.
• We communicate clearly and transparently about duties and expectations related to each position.
• We give all Employees the opportunity to grow and enhance their professional skills.
• Decisions regarding Employees’ professional advancement are justified objectively and taken with particular care.
• We treat each other with respect, irrespective of position, seniority, age, or experience.
GRUPA AZOTY EMPLOYEES’ ETHICAL VALUES AND PRINCIPLES OF CONDUCT
4.1 WE MANAGE THE ISSUE OF CONFLICT OF INTEREST
Every Grupa Azoty Employee is required to comply with the following rules:
• Avoid any situations that could cause or create the possibility of a conflict of interest.
• Critically assess each situation to determine if it may affect the objectivity of our actions or decisions.
• Promptly inform one’s immediate superior or the unit responsible for compliance management about situations that constitute or might lead to a conflict of interest.
GRUPA AZOTY EMPLOYEES’ ETHICAL VALUES AND PRINCIPLES OF CONDUCT
4.2. RISK OF CORRUPTION
The principles we follow in response to the risk of corruption are:
• We do not offer, provide, or promise customers or business partners gifts, financial benefits, or services aimed at influencing their business decisions.
• We ourselves do not accept any material benefits from business partners that could create doubt as to their influence on our decisions.
• We report any suspicions of corrupt behavior to our immediate supervisor, the compliance management unit, or the security unit at Grupa Azoty.
GRUPA AZOTY EMPLOYEES’ ETHICAL VALUES AND PRINCIPLES OF CONDUCT
As Employees of Grupa Azoty, we are required to observe high standards of environmentally responsible conduct and to be accountable for protecting the natural environment. We understand social responsibility broadly—as accountability for all our actions that may affect the surrounding environment.
Given the nature of our operations, we primarily:
• Undertake initiatives that protect the environment and participate in activities benefiting the local community.
• Use only environmentally friendly technologies that do not exceed prevailing environmental standards.
• Exercise our civic rights, engaging in social and political activities in a private capacity; it is prohibited to act under the banner of the Group or a Grupa Azoty company in such matters.
We have prepared this Code with all Employees in mind, as well as external entities who may wish to learn about our adopted principles of conduct. This Code applies to all companies belonging to Grupa Azoty and is communicated in a manner adopted by each Company, so as to ensure that every Employee can familiarize themselves with its content. Every Employee is obliged to become acquainted with it and to abide by its rules.
Grupa Azoty’s stakeholders and Employees have the right to request explanations if any provisions of the Code seem unclear or if they have doubts regarding its scope of application. In Grupa Azoty, it is established practice that they also have the right to submit comments and propose amendments to the Code.
For individuals employed in Grupa Azoty, the Code’s provisions impose the following obligations:
• To act in accordance with the Code’s provisions.
• To consult with a superior or the unit responsible for compliance management in case of doubts about the Code’s requirements.
• To report any breaches of the Code to a superior or the unit responsible for compliance management.
• We are all obliged to positively influence, through our attitudes and actions, the shape of our Organization’s ethical culture; if we notice a need for the Code to regulate specific issues or for actions that strengthen Grupa Azoty’s organizational culture, we should discuss it with our superior or the compliance management unit.
The Code imposes special obligations on managerial and supervisory staff, as they serve as role models for all individuals employed at Grupa Azoty.
Therefore, they are obliged to:
• Promote the Code’s provisions.
• Set an example of proper behaviors and conduct.
• Inform subordinates and newly hired Employees about the rules of conduct that have been put in place.
• Initiate measures to prevent breaches of the Code.
Every Grupa Azoty Employee has the option to report an observed event or behavior suspected to violate the Code’s provisions. If the violation is not serious, the Employee may undertake corrective measures on their own.
However, if the matter requires the involvement of individuals with relevant knowledge or competencies, suspected violations of the Code’s provisions should be reported to the immediate supervisor or the unit responsible for compliance management.
Grupa Azoty Employees may request anonymity when reporting any violation of the principles set out in this Code.
Employees who violate the provisions of this Code may be subject to consequences defined in a separate internal regulation.
Oversight of the Code’s implementation and resolution of any arising issues is entrusted to the Compliance Management Coordinator at REMZAP.
The Code is available on the website www.grupaazoty.com and at www.remzap.pl/etyczny, as well as from immediate supervisors and the Compliance Management Coordinator at REMZAP.
The Code is available in Polish, English, and German.
All reports of ethical violations will be reviewed with due diligence.
Any breach of this Code by Grupa Azoty Employees (including REMZAP) is treated as a breach of their duties and may result in sanctions provided for in the Work Regulations, the Labor Code, and other regulations.
