The message from the Board of Management

Craftware grows, we have become more recognizable on the market. Therefore, it is important to us that our company is associated with credibility. That is the reason why we entrust to you this document.

Thanks to the joint commitment and faith in the sense of our actions, with every day we achieve more and more, we grow stronger. But there is one more thing behind our success: the values we hold. Respect, honesty, and transparency — though they have not been written down in any code so far — accompany us daily at work in a team, as well as in contacts with clients, providers, competitors, and state institutions.  In this manner, we create our image: a trustworthy business partner and employer. We build our brand.

However, we know that life writes different scenarios. Regardless of the intentions or respecting the standards, each one of us may find themself in an uncomfortable situation that will raise ethical doubts and bring up many questions. “How to behave? Am I doing the right thing?” Sometimes the decision made in good faith may carry serious consequences, even criminal liability. We hope that the Code of Conduct will help you in recognizing that kind of situation as well as making the right choice.

We are aware that the Code may touch on complex matters, frequently even sensitive issues. We tried to present it understandably by referring to both the provisions and real-life examples. We included practical tips in the document on specific situations. In the event of difficulties with the interpretation — turn to your leader. There is also the Anti-corruption Representative with whom you may consult concerns related to the Code and its usage.

If a specific situation will raise your particular concern and you will assume that someone tries to bribe you or persuade you to act against the company’s interest, please inform your leader. You can also signal this incident using the Help Desk Craftware (Security Incident bookmark Corruption Incident) or apply directly to the Anti-corruption Representative — in person, by phone, or by email. You have the right to report the arising situation directly to the Board of Management.

Do not be afraid that action form your side will be wrongly received or misjudged. Let us remember that transparency is possible thanks to open communication, and our superior objective is always the interest of the company.

Asking for your commitment to respect the Code, at the same time, we thank you for everything you do for Craftware’s and our customers’ success every single day.

 

Awareness and avoiding conflict of interest

Part of the Craftware’s culture is the spirit of open communication and cooperation for the company’s wellbeing.

 

What is a conflict of interest?

It is a conflict between the personal interest of the employee or consultant and the interests of the company that can affect the loyal performance of employee duties or contractual duties. Personal interest may have property, professional, or private dimensions. It may concern both employees and consultants as well as the interest of people close to them.

By signing a contract with the company, you undertake to be guided by the best interest of the company, and the company undertakes to pay you remuneration specified in the agreement and ensure you tools and benefits provided by the agreement and regulations.

 

Avoiding conflict of interests

The most significant for preserving mutual trust is informing your leader about relationships that may cause a conflict of interest.

Remember:

  1. Having personal, professional, or property relationships with entities that may be our competitors, providers, or clients is not reprehensible itself.
  2. Evaluate up-to-date whether your relationships with clients may cause a conflict of interest. If you have any doubts, consult them with your leader.
  3. If the leader evaluates the risk as high — you receive other tasks unrelated to the entity you are directly or indirectly associated with. If the risk is low or evaluated as an opportunity, you can still carry out your planned tasks.

Below you will find the rules of conduct in particular cases that may cause a conflict of interests.

 

Working with relatives and close people

If two members of a family or two close people co-work or provide services for Craftware, there cannot be a professional dependency between them (for example, a supervisory relationship) without the Board of Management’s consent.

If your relative or a person you are close with is the owner, worker, or provider of services at the company doing the business with Craftware, you have to report it. To conduct issues related to the mutual interest of Craftware and this company, you need to get the approval of the Management Board.

Family members and close people are parents, siblings, a spouse, siblings of a spouse, children, parents-in-law, your and spouse’s grandparents, grandchildren, life partners, and other people who permanently live within your household.

 

Additional commercial activities

Working for other entities or running your own business may, in some situations, cause a conflict of interest. Extra full-time work, performing work under civil law agreements for other entities, or the range of your business activities have to be consulted with your leader.

The employees and consultants are not allowed to perform competitive activities toward our company. Specific commitments for the duration of the employment agreement and upon its termination are included in the relevant contracts.

 

Financial interests

Ownership of shares, stocks, or other securities of our competitors, clients, or providers have to be reported and consulted with the leader or Anti-corruption Representative. It is necessary to evaluate the risk and determine responsibilities that will not cause a conflict of interest. Detailed regulations in this respect are in the contracts signed by the employees and consultants.

It is also appliable when the owners are relatives or people close with the employees or consultants who cooperate with Craftware, regardless of the form of cooperation.

 

Preventing anti-corruption practices

Craftware rejects all of the corruption and bribery practices. We do not tolerate offering or accepting bribes by our employees or consultants. We do not gain clients this way, and we do not practice that in our contacts with state administrative authorities or self-government administrative authorities, providers, and competitors. We do not tolerate this kind of practice in our internal relationships.

We are aware that bribery and corruption may occur in official as well as in business relations. Therefore, we ask all of the employees and consultants to discuss with the leaders or Anti-corruption Representative their concerns and abnormal behavior of the external stakeholders.

 

Benefits due and undue

Benefits due are those resulting from the agreement concluded with the company, internal regulations, and legal provisions. They include remunerations, bonuses, training financed by Craftware, awards, equipment passed on contractually, benefits provided by ZUS (Social Insurance Institution), paid holidays, commissions, etc.

A benefit due is also what the employee or consultant will receive from other entities with the knowledge and approval of the company.

In conclusion, what we get from the company or with its approval or from the state institutions is, in general, a benefit due (exception: if we misled them to gain benefits.)

Other benefits received concerning the work or services of the different entities or people are, in principle, undue benefits.

Let us remember that the same rules that stand for what is a benefit due and what is an undue apply to persons performing public functions and representatives of our providers, clients, and competitors.

 

Corruption in the public sector

Corruption crimes in relationships with persons performing public functions consist in giving undue benefits in exchange for:

  • professional activities (such as making a decision, the conclusion of a contract),
  • failure to act (such as exemption from control or punishment.)

To ensure the transparency of our relationships with persons performing public functions, we adopt the principle: we do not give, do not offer and do not promise any benefits. We do not give gifts, even no company gadgets of negligible value. We do not provide or promise a tokens of gratitude. We do not invite to the company’s parties.

 

Sales for the public sector – restrictions

Every establishment of the business relationship to sell services for the public sector requires the approval of the Management Board.

It includes following types of entities: offices, agencies and other state entities and local governments, companies owned by the State Treasury or local government companies, state-owned enterprises and local government enterprises, public health care facilities, public universities, and research institutions, international organizations and their entities, political parties and their foundations.

 

Corruption in business

Giving, offering, or promising undue benefits to the representative of other company in return for the unreliable performance of the official or contractual duties is against the law, especially if:

  • May expose other companies for the property damage.
  • Constitutes an act of unfair competition (unfair favoring of a provider.)
  • Constitutes unacceptable favoring of a buyer (unfair favoring of a client.)

Of course, acceptance, demanding, or promise acceptance of an undue benefit by the company representative in the abovementioned situations is also a crime.

To ensure the application of the business ethics and fair competition in relations with our business partners and competitors, we adopted the principles as follows:

  • We accept and offer only those benefits that are consistent with our gift and hospitality policies.
  • We check if our business partners apply gift policy and ethical code, and we do not make proposals that exceed those principals.
  • We refuse to accept any undue benefits or promises in return for acting against our company or for favoring of provider or client
  • We do not give or promise none of the benefits undue in return for acting against a company of the gifted person or for unfair favoring treatment of our company.

 

The rules of conduct in the corruption situation

In the case of being offered a corruption proposal, apply the following rules:

  • Firstly — refuse unambiguously.
  • If possible, refuse in front of witnesses.
  • Inform your leader or Anti-corruption Representative immediately, either orally or in writing (if the report is oral, prepare a written information after that.)
  • Secure evidence and documents concerning the case (if there are any), for example, email correspondence, paper documents.
  • If a corruption proposal was related to an attempt of direct bribery, do not secure it by the acceptance,
  • If an undue benefit was transferred indirectly (by a courier, hidden in a documentation or a gift given) — secure it, and write a protocol jointly with the Anti-corruption Representative.

After your report, its analysis, and gathering evidence, the company pursues proper legal action. If and evidence is sufficient, the company prepares a notification to the authorities.

Remember, you have the right to:

  • Skip the chain of command and report corruption incident directly to the Board of Management.
  • Directly inform the authorities about an attempted crime.

 

Gift and hospitality policy

To preserve transparent and fair rules of conducting our business, we apply the following rules.

 

The rules of giving gifts and expressing hospitality

  1. Do not give, offer, or promise gifts and other benefits on the quid quo pro principle.
  2. We do not provide any gifts (even promotional gadgets of a negligible value) to persons performing public functions; we do not fund them anything or invite them to private parties.
  3. We do not propose to business representatives of other companies anything that could violate their own gift and hospitality policies. We should check in advance whether such a policy exists (it may be a part of a document of a different name). We apply the principles of a partner in mutual relations unless ours are more stringent.
  4. In cases justified by business needs, we can provide official promotional gadgets of our company.
  5. In cases justified by business necessities, the marketing department can offer gifts to customers and business partners only when the value and nature of the offerings are appropriate in the circumstances.
  6. Offering refreshment (hot and cool soft drinks and snacks) to any visitors in our office or at the official the exhibition stand (for example, during trade fairs or events) is allowed.
  7. We try to negotiate contracts in the office environment.
  8. In the case of organizing marketing events opened for all visitors such as business breakfast, it is allowed to offer a small refreshment (soft drinks, sandwiches, sweets, etc.).
  9. In the case of closed marketing events (that is, by invitation only for specific individuals or companies) combined with entertainment and consumption paid by Craftware, the participants can be the existing clients and other business partners.
  10. In cases not described above or in the event of any doubts related to applying those rules, consult with the Anti-corruption Representative.

 

The rules of the gifts and hospitality manifestations aceptance

  1. We do not accept any gifts or manifestations of hospitality on the quid quo pro principle because it may be a crime.
  2. We do not accept any gifts or manifestations of hospitality from our competitors or potential providers because it may cause a conflict of interest.
  3. We are allowed to accept gifts and invitations from the rest of our business partners (the current and potential ones). But only when the value and nature of gifts or invitations are appropriate in the circumstances and both a beneficent and a beneficiary case. Gifts and invitations must always be given and accepted openly.
  4. In the case of receiving a gift proposal or a manifestation of hospitality that we must not accept it should be refused assertively and indicated as inconsistent with the applicable Code of Conduct of the company.
  5. In cases not described above or in the event of any doubts related to applying those rules, consult with the Anti-corruption Representative.

 

Fair competition. Conspiracy

Selling our services, we apply to the rules of fair competition.

We do not tolerate any form of collusive bidding or other acts of unfair competition. They are subject to financial penalties and sometimes criminal liability.

We do not agree or consult our actions concerning the current and potential clients with our competitors in no way.

In the case of such an attempt by competitors — refuse assertively and report this as the Corruption Incident.

 

Accounting reliability

Account books, records, and financial statements of Craftware are kept with the appropriate level of detail to reflect company operations accurately. It is both required by the law and system of the internal control of the company.

The company documents are properly stored and archived. It applies to paper documents as well as electronic documents.

 

Fairness in relations with business partners

Craftware makes every effort to be fair and reliable toward all clients, providers, and other business partners. Never mislead about the quality, function, or product availability of our company and never do anything illegal or unfair to gain or implement the order.

An attempt to obtain information by lying or pretending to be someone you are not is unethical and may be illegal. Do not do this. If, by mistake, you receive other company confidential information, return or destroy them.

 

Fairness in the internal relations

 

Using company equipment and property

Craftware trusts its employees and consultants, allowing them to use from a wide range of devices and technologies helpful in the effective work. These tools should be used in accordance with the purpose.

Computers, mobile phones, and other devices provided by Craftware are the company property. It also applies to the Internet, electronic business mail, and other systems and tools used at Craftware.

Provided devices and technologies should be used in accordance with the policy of security of information.

Company’s property should be used in accordance with the purpose, responsibly, in a manner that protects it against loss or destruction.

 

Work time settlement

Work time is used for the performance of professional responsibilities. We take essential rest breaks at work for maintaining occupational health principles.

We base settlement of working hours on mutual trust. We expect that the number of hours logged on a project corresponds to reality.

 

Audits and external inspections

From time to time, you may meet internal and external auditors and inspectors who ask you to provide information. Never mislead or try to affect any investigation, audit, or inquiry.

In case of any legal doubts, consult your leader in the first place.

 

Leadership

This Code applies equally to all the employees and consultants of Craftware regardless of the form of cooperation. However, the leaders are under additional obligations.

If you are a leader or manager, please be aware that the success of the Code and adherence of ethical values are dependent on your leadership and commitment. Therefore:

  • Be a good example; always choose fairness.
  • React proportionally to minor irregularities to prevent major abuse.
  • Speak up if you see a problem and encourage others to do the same.
  • Do not accept gifts or manifestations of hospitality from your subordinates if the value of those may cause a conflict of interest and interfere with objectiveness evaluation.
  • Make sure that your subordinates understand this Code and what is expected of them.
  • Encourage your subordinates to consult you about their doubts and discuss situations of the potential conflict of interest; evaluate risk, and make decisions.
  • If necessary, consult the Anti-corruption Representative.
  • Encourage your subordinates for signalizing abuse, and justified suspicion of abuse or corruption, protect whistleblowers from retaliation, pass the information on to the Anti-corruption Representative.

 

We treat people with dignity and respect

 

Mutual respect

We respect, support, and protect human rights and dignity. We believe that successful cooperation can only be realized while maintaining mutual trust in the atmosphere of support. At Craftware, we do not tolerate behaviors that contribute to the atmosphere of intimidation, hostility, or insulting.

We all have the right to work in the environment free from harassment and violence. It applies to the way we treat one another and all of the people with whom we maintain business relationships.

At Craftware, we do not tolerate

  • All instances of mobbing, physical, verbal, or sexual harassment and other behaviors with the aim of insulting, humiliating, intimidation, etc.
  • We do not accept spreading rumors, making false accusations, and sharing unproven information.
  • We do not use professional status to reap personal or financial benefits unlawfully.
  • We do not offer personal or financial benefits in return for improving professional position.

 

Equal opportunities

At Crafware, we value diversity; we do not tolerate discrimination in any form. We follow the rules of equal opportunities in employment. We recruit, employ, remunerate, train, promote and dismiss employees in accordance with applicable principles and regulations, regardless of race, skin color, faith, age, gender, nationality, marital status, sexual orientation, disability.

 

Safety and health

Craftware conducts activities in a manner ensuring the safety and health of our employees, also counterparties, and all of the people visiting our offices. We comply with the principles of occupational safety and health principles of work.

 

Data protection

Personal data of our coworkers and business partners is used only for the purpose for which it is stored, and we treat them confidentially. We adhere to the rules of data protection strictly.

 

How to consult doubts and report violations

 

Clearing up doubts

We encourage you to ask and consult about any doubts. You can request information from:

  • your leader
  • other managers you trust
  • the anti-corruption representative: Magdalena Wałęka, email address: mwaleka@craftware.pl, phone: +48 600 333 883

The choice of person or persons you consult with is up to you.

Remember that we want and can help you, though we need to know what the issue is. We guarantee you that advice on ethical matters will be provided to you with the confidential treatment of personal information and reported problems.

 

You see something — react!

You are our first line of defense of the ethical code. If you see that someone’s behavior may be against this Code, admonish them in the way following the organizational culture of our company.

 

Signalizing violations and corruption

If an attempt of corruption or bribery was made toward you, please follow the rules described in the section “Preventing corruption practices.”

In situations like this, we encourage you to signalize issue in one of the following ways:

  • Using the Help Desk Craftware (Security Incident bookmark Corruption Incident.)
  • In-person, by phone or email to the Anti-corruption Representative.
  • In justified cases, you can skip the chain of command and report the issue directly to the Board of Management.

You can also report the case anonymously.

Remember, if you witness a crime or preparation for a crime (for example, corruption or fraud), reporting the issue is mandatory and advisable also for your legal safety. Failure to report leads to no less than the moral co-responsibility for the incident and its consequences, and in some situations, even criminal or civil liability.

 

Reporting in good faith and protection of whistleblowers

Signalizing in good faith means that any report of the possible violations of this Code, the company’s policy, or law are reported sincerely and honestly. In other words, there is no difference if your suspicions will be confirmed. You must report them with the best of intentions.

Signalizing is the early warning system that prevents converting irregularities into serious crimes. It is action in the interest of the company and all employees and consultants who follow the Code of Conduct.

The Board of Management declares to protect whistleblowers from retaliation of people who break our ethical rules. Reports are explained with respect for dignity and the good name of the persons involved. At the same time, in a way that protects the identity of a whistleblower. (In the circumstances provided by the law, whistleblower’s identity may be revealed to the authorities.)