Code of Ethics

CODE OF ETHICS

OF THE DELTA TRANS COMPANY GROUP

REVISION VI

22.02.2021

INTRODUCTION

1. The term Delta Trans (DT) Company Group shall be understood as the following companies:

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

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

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

3. This Code of Ethics is a commitment of the Group 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 the laws of the countries in which we operate as well as international regulations that affect our business.

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 wages only in accordance with the Labour Code.

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

4. OCCUPATIONAL HEALTH AND SAFETY

4.1 We provide safe work conditions for all employees (permanent and temporary), in compliance with all regulations in force.

4.2 We take measures to identify and prevent health and safety risks for:

- employees (permanent and temporary),

- customers’ employees,

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

- people living in the vicinity of our work establishment.

4.3. We monitor dangerous events – we analyse them and take corrective actions to prevent them in the future.

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

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

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

4.7 The DT Company Group has a separate OHS and fire safety policy.

5. ENVIRONMENT PROTECTION AND QUALITY

5.1 The DT Company 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 carry out activities that contribute to:

- optimisation of the use of natural resources and energy,

- reduction in our emissions of pollutants into the environment,

- reduction in waste generated,

- quality of the performed services.

5.4. We implement recycling and resource recovery solutions.

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

5.6. We employ people who are responsible:

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

- for ensuring that the DT 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 check the supplies of our services / products to ensure that the product meets customer requirements.

5.9. We ensure traceability of raw materials and materials necessary for the provision 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 Corruption is understood as any act or omission to act, as well as the promise of such conduct, with the aim of obtaining, unlawfully or unethically, an advantage given, promised or implied, whether tangible or intangible, directly or indirectly.

7.2. Corruptive conduct occurs when a person who wants to achieve an objective for himself, or for an entity or person he represents, promises, offers or gives, in order to achieve this objective, a tangible benefit (i.e. a benefit the value of which can be expressed in money, understood as an increase in the value of property as well as a decrease in liabilities encumbering the property) or a personal benefit (understood as a non-monetary benefit improving the situation of a given person) to a person who holds public functions or performs important functions in economic trade. It is irrelevant whether such actions are taken personally or with the help of intermediaries.

7.3. DT Company Group has a zero-tolerance policy towards corruption in relation to all manifestations of the enterprise's business activities. Zero tolerance applies to all forms of corruption, regardless of whether they occur in the public or private sector and regardless of whether they benefit or could benefit the Companies, their vendors or business partners.

7.4. It is forbidden for employees, associates and representatives of the DT Company Group to undertake any of the following actions both in internal and external relations, regardless of whether they are undertaken directly or through others:

· bribery,

· coercion or inducement,

· influence peddling

· laundering of income from bribery.

7.5. Employees, associates and representatives of the DT Company Group may not offer, give, promise, demand or accept financial or personal benefits:

· which could be perceived as unlawful, unethical or inappropriate,

· whose purpose is to influence the terms of a transaction.

7.6. Employees, associates, and representatives of the DT Company Group are obliged to exercise particular diligence in order to protect the good name and interests of the DT Company Group, and in particular are under an obligation to:

- remain vigilant against the threat of corruption at all times,

- exercise due care in dealings on behalf of the DT Company Group with third parties,

- prevent, detect and report any instances of corruptive behaviour.

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

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

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 DT Company 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, pen, notebook) or other item whose value does not exceed PLN 50 net.

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. Financing of political activities

The DT Company Group does not finance or otherwise support political parties or their members, including candidates for political office, their election campaigns or political events, or any political organisations or movements.

10. Payments to third parties made through intermediaries

The DT Company Group, employees, associates and representatives are prohibited from making payments to third parties through intermediaries if there is a suspicion that a part or all of such payment will be used as a bribe.

11. Facilitation payments

We do not make facilitation payments, i.e. unofficial payments offered to secure or expedite routine actions by state/local government bodies.

12. Accounting documentation and records

Each of the Companies maintains accounts which reflect all transactions and asset management in reasonable detail and accuracy.

The use of false documents as well as the introduction of improper, ambiguous or misleading book entries or the use of any other accounting procedures, techniques or solutions that would conceal or otherwise disguise illegal payments are strictly prohibited.

13. Audits and inspections

Each of the companies regularly carries out audits covering financial and business activities, and checks on an ongoing basis the completeness and accuracy of the recording of all activities in books and registries, as well as compliance with legislative requirements and internal normative documents, including the principles and requirements set out in the body of this Code.

14. CONFLICT OF INTEREST

14.1 We forbid the use of employment at the DT Company Group to obtain unauthorised personal benefits.

14.2.We forbid our employees to perform, without the DT Company 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 DT Company Group's interests.

14.3.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.

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

14.5. We comply with antitrust laws. We do not tolerate price fixing and agreements, market sharing or any other form of unfair restriction of competition.

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

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

15.2 The DT Company Group's identification marks may be used only for business purposes.

15.3 We require all employees to protect the DT Company Group's and customers' property against theft, damage, misuse and destruction.

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

16. RELIABLE BUSINESS PARTNER

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

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

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

16.4 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.

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

16.6. 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.

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

17. PERSONAL DATA PROTECTION

17.1. 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.

17.2. No actions against Employees' privacy are allowed.

18. REPORTING VIOLATIONS

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

18.2. 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.

18.3. The above-mentioned reports can be made anonymously using, for example, an external e-mail address.

18.4 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.