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Our Group employees are aware of the importance of business ethics and the need to observe them in a listed company. At the Unibep Group, we strive to ensure that all employees adopt the best models of behaviour. We believe that corruption and bribery are elements of a broader phenomenon related to values, ethics and integrity in business. Where people act on the basis of transparent and generally known ethical values, the threat is much lower. This is why regular staff training sessions are so important, during which existing procedures and internal instructions are refreshed and discussed.

In addition to the Code of Conduct, the Unibep Anti-Corruption and Anti-Fraud Procedure has been implemented which is part of the compliance management system in place and improves the security of operations of the Group companies.

By regulating the principles of conduct in the event of corrupt or fraudulent events that may occur in all areas of Unibep Group’s operations, at all levels of management, we express our firm disapproval of such behaviour and all forms of corruption.

The Unibep Group Anti-Corruption and Anti-Fraud Procedure includes:

  • the definition of formal and organisational conditions to ensure that activities are carried out in compliance with the law, internal regulations, industry rules and commitments made,
  • the definition of rules of conduct to prevent and counteract corruption and fraud committed to the detriment of the company,
  • the establishment of rules for reporting corruption and fraudulent activities,
  • the definition of rules for dealing with reports,
  • the implementation of effective corrective actions and efficient internal control mechanisms.

It is compulsory for all Unibep Group business managers and contract managers in Poland and abroad to familiarise themselves with the documents relating to anti-corruption procedures.

Compliance with the adopted anti-corruption regulations and monitoring of adverse events in the Group is handled by the Compliance Coordinator, who is appointed by the President of the Management Board of Unibep S.A. The Coordinator collects and handles reports of violations, ensuring anonymity for whistle-blowers, and conducts investigations and subsequently monitors and implements corrective actions. They organise systematic training and activities to raise employee awareness of fraud and corrupt behaviour. All members of Unibep Group’s governing bodies, employees and business partners have been informed of the organisation’s anti-corruption policies and procedures. In addition, all members of the governing bodies and management staff of the Unibep Group have received anti-corruption training

Unibep Group employees are required to avoid situations that may give rise to a conflict of interest that could affect their objectivity in the course of their activities and actions

The existence of conflicts of interest can lead to corruption or fraud in situations where an employee, by virtue of his or her position, may gain an advantage as a result of decisions made or influence the decisions of colleagues made in relation to the employee, persons close to the employee or a third party to which the employee has family, business or professional obligations

Anyone who has doubts about the possibility of a conflict of interest is obliged to refrain from taking any action related to the conflict situation, except for those that may expose the company to damage. A supervisor and/or the Compliance Coordinator should be informed immediately of the situation.

The Unibep Group has the following internal regulations covering the area of ethics:

  • Unibep Group Code of Conduct
  • Unibep Group Anti-Corruption and Anti-Fraud Procedure
  • Rules of Conduct for Business Partners

In 2021, no cases of corruption were identified in the Unibep Group.