Code of Ethics

CODE OF ETHICS

OF THE DELTA TRANS COMPANY GROUP

REVISION V

01.06.2020

INTRODUCTION

1. The term Company Group shall be understood as the following companies:

- Delta Trans Transporte sp. z o.o. with its registered office in Świętochłowice, ul. Chorzowska 134B,

- Delta Trans Logistik sp. z o.o. with its registered office in Świętochłowice, ul. Chorzowska 118 – 120.

2. The aim of this Code of Ethics is to create a proper work culture within the Company Group and between the Company Group and its environment.

3. This Code of Ethics is a commitment of the company and its employees/associates to the highest ethical standards.

4. We also require our customers and suppliers to comply with the provisions of this Code.

5. We comply with applicable laws in the countries in which we conduct our business, as well as international regulations affecting our activities.

THE MOST IMPORTANT STANDARDS OF CONDUCT:

1. EMPLOYMENT

1.1. We inform all employees clearly in writing about terms of employment.

1.2 We do not use child labour or forced labour.

1.3. We respect employees' freedom of association and their right to representation in accordance with the Labour Code.

2. WORK TIME

2.1 We guarantee work and leisure time as required by law

2.2 We do not apply mandatory overtime.

3. REMUNERATION

3.1 We guarantee fair wages as required by law.

3.2 We inform all employees clearly in writing about remuneration-related terms of employment.

3.3 We apply deductions from payments only in accordance with the Labour Code.

3.4 We do not use deductions from payments to discipline our employees.

4. OCCUPATIONAL HEALTH AND SAFETY

4.1 Our goal is to ensure safe work conditions to all employees (permanent and temporary), while complying with all applicable regulations.

4.2. We take actions to recognize and prevent health and safety risks:

- employees (permanent and temporary),

- employees of our clients

- employees (permanent and temporary) of our sub-suppliers,

- people living near our workplace.

4.3 We monitor dangerous occurrences - we analyze them and take corrective actions to prevent them in the future.

4.4 We provide safe and healthy work conditions for all employees, in compliance with all regulations in force.

4.5 We employ a person in charge of OHS/fire safety compliance.

4.6 We organise regular OHS/fire safety training courses for all employees.

4.7 The consumption of alcohol and drug use are strictly prohibited for all employees who are on duty.

4.8 Delta Trans Group has a separate policy of OHS/fire safety.

5. ENVIRONMENT PROTECTION AND QUALITY

5.1 The Delta Trans Group has a separate Environment Protection and Quality Management Policy.

5.2 We comply with legal requirements related to environmental protection and we constantly monitor the companies' impact on the surrounding environment as well as carry out pro-environmental activities indicated in annual environmental programmes.

5.3 We run actions that affect:

- optimization of the consumption of natural resources and energy,

- reducing own pollution emission to the environment,

- reducing the amount of waste generated

- the quality of services rendered.

5.4 We implement solutions in the field of recycling and recovery of raw materials.

5.5 We identify and monitor the environmental aspects of our business.

5.6 We employ people who are responsible:

- for making sure that the Company Group operates in accordance with environmental protection regulations,

- for ensuring that the Company Group meets the requirements of the Integrated Management System.

5.7 We organise systematic training courses in environmental protection, work conditions and human rights as well as OHS/fire safety.

5.8 We inspect our services / products to ensure that they meets the customer's requirements.

5.9 We provide traceability of raw materials, materials necessary for the supply of products and services.

6. MUTUAL RESPECT

6.1 We prohibit:

- employee discrimination for any reason,

- use of various forms of intimidation against employees,

- abuse or humiliation of employees.

6.2 Detailed instructions on equal treatment in employment based on the provisions of the Labour Code are enclosed with the current Work Rules.

7. ANTI-CORRUPTION MEASURES

7.1 We always act appropriately when dealing with customers, suppliers and consumers. We treat them fairly and with respect.

7.2 We use services of Suppliers who do not violate ethical standards by bribery or by granting similar illegal benefits.

7.3 We prohibit the following activities:

- bribery,

- coercion or inducement,

- influence peddling,

- laundering of income from bribery.

7.4 We do not accept or give any monetary or material benefits to induce anyone to take or not to take certain actions, or for any other inappropriate purposes.

7.5 We prevent, detect and report cases of bribery or any other cases of corruption to the competent authorities.

8. PROCEDURE CONCERNING GIFTS

8.1 We approve only of those gifts that are freely offered to an employee by an entity cooperating with the Delta Trans Group and which meet the following requirements:

- the benefit has no influence on the way the matter is handled,

- the benefit does not require reciprocation,

- the employee does not have to hide it,

- the benefit is an advertising, promotional (e.g. a calendar) or other item whose value does not exceed PLN 50.

8.2.We prohibit:

- giving or accepting money as a gift,

- giving gifts of any value to government employees or representatives,

- giving or accepting excessively expensive gifts or too often,

- giving any gifts in thanks to government employees,

- giving or accepting gifts that could influence business decisions,

- giving or accepting gifts which depend on the extent of business done,

- offering a gift which to your knowledge would violate the rules of accepting gifts at the recipient's company,

- offering or accepting offered participation in an entertainment event unrelated to the company's activities, e.g. a musical concert or a match.

8.3 We always make sure that a given gift is compliant with rules adopted at the Delta Trans Group and if it violates the adopted rules, we refuse to accept it and we inform the giver about it.

9. CONFLICT OF INTEREST

9.1 We forbid the use of employment at the Delta Trans Group to obtain unauthorised personal benefits.

9.2.We forbid our employees to perform, without the Delta Trans Group's prior consent, any competitive professional activity, including operating a business, or to participate in transactions for other entities, in particular for competition, or any other third parties whose interests are, or could be, in conflict with the Delta Trans Group's interests.

9.3.Employees have a constant obligation to inform the company about any conflicts of interest which may occur between their employment at Delta Trans and a possible relationship with a Supplier.

9.4. We require Employees to avoid creating potential conflicts of interest and to identify and report any conflicts they encounter.

9.5. We comply with antitrust laws.

10. PROTECTION AND MISUSE OF THE COMPANY'S EQUIPMENT, ASSETS AND TIME

10.1.We prohibit the appropriation of the company's property for personal use or resale.

10.2 The Delta Trans Group's identification marks may be used only for business purposes.

10.3 We require all employees to protect the Delta Trans Group's and customers' property against theft, damage, misuse and destruction.

10.4 All Employees must ensure that intellectual property is protected from access by unauthorised Employees and third parties.

11. RELIABLE BUSINESS PARTNER

11.1.Our goal is to build long-term relationships with our suppliers and customers, based on fair and honest principles.

11.2 We pursue our business objectives with respect for the rights and welfare of all our customers.

11.3. We are guided by responsibility and trust in our partnership with customers.

11.4 We make every effort to ensure responsible sourcing of materials and raw materials. Responsible sourcing and extraction of raw materials also includes consideration of environmental protection, including chemical management, as well as respect for human rights.

11.5. We avoid purchasing and using materials that have been acquired illegally or through ethically reprehensible or unreasonable activities.

11.6 We require that our Suppliers develop, implement and apply effective methods and procedures to detect and minimise the risk of counterfeit parts and materials entering our supply chain.

If such an event is detected, we expect Suppliers to implement effective procedures to identify the product and notify the recipients of the counterfeit product.

11.7 We comply with the provisions of the Public Procurement Law.

12. PERSONAL DATA PROTECTION

12.1. We process personal data lawfully, diligently and transparently, ensuring its adequate security, including protection against unauthorised or unlawful processing and accidental loss, destruction or damage, using appropriate technical and organisational means.

12.2. No actions against Employees' privacy are allowed.

13. REPORTING VIOLATIONS

13.1.A violation of the rules of the Code of Ethics may result in disciplinary action.

13.2. Any violation of the rules of the Code of Ethics must be reported in person or by e-mail to the Organisational and Legal Department, at the following e-mail address: B.Konopka@deltatrans.pl

13.3 Possible violations:

a) related to labour law, OHS and human rights will be examined by a team composed of:

- representative of the organisational and legal department,

- representative of the OHS department,

- representative of the human resources department.

b) related to environmental protection will be examined by a team composed of:

- representative of the organisational and legal department,

- environmental protection specialist.

c) related to other matters will be examined by a team composed of:

- representative of the organisational and legal department,

- representative appointed by the Company's Management Board.