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1. Introduction

Public Dialog Sp. z o.o. is committed to upholding the highest standards of ethics, integrity and transparency in all facets of its operations. It is a priority for Public Dialog Sp. z o.o. to ensure fair and ethical business practices, both internally and in its interactions with clients, business partners and the community.

This Anti-Corruption Policy underpins the Agency’s commitment to combating corruption, fostering a healthy work environment, and building trust with stakeholders.

Public Dialog Sp. z o.o. adheres to a zero-tolerance approach to any form of corruption. Corruption runs counter to the principles of the Agency as a responsible, trustworthy and accountable company that actively engages in business while promoting integrity, ethics and sustainability in the market.

Public Dialog Sp. z o.o. runs an anti-bribery and corruption programme, the main objective of which is the prevention, detection and elimination of such irregularities. The key aspects of this programme include:

  • Involving senior management in promoting a culture of zero tolerance and a commitment to the prevention and detection of bribery and corruption;
  • Regular bribery and corruption risk assessments;
  • Keeping appropriate procedures in place with the aim of preventing corruption;
  • Systematic awareness-raising communication as well as regular training.

2. Definitions

Within the framework of this Policy, corruption is defined as any action that violates the principles of ethics, integrity and objectivity in the operations of Public Dialog Sp. z o.o. Corruption includes giving or accepting bribes, nepotism, abuse of power, manipulation of information and any other action that leads to an unfair advantage or affects the integrity and credibility of our operations.

Bribery is the act of offering, promising, giving or transferring anything of material value, a service, intangible benefit or other type of gratification in order to influence the conduct, decisions or behaviour of a person in authority, a public official, an employee of Public Dialog Sp. z o.o. or any other person in order to obtain an advantage unrelated to a fair business process.

3. Anti-Corruption practices

Public Dialog Sp. z o.o. introduces an Anti-Corruption Policy, which prohibits and does not support any form of corruption. In complying with this Policy, the Agency believes that anti-corruption is key to building a fair and just society and to promoting sustainable economic and social development. In addition, this Policy aims to define the prohibitions that apply to all employees of Public Dialog Sp. z o.o., as well as to identify and clarify the underlying principles of the Anti-Corruption Policy.

4. Goals

The Agency does not permit any behaviour contrary to the Agency’s interests (conflicts of interest) or corruption of any kind and is committed to honest business operations. To ensure the integrity of our business activities and to meet the expectations of our stakeholders, the Agency shall take detailed measures to prevent bribery and corruption in accordance with this Policy.

5. Scope of application

This Anti-Corruption Policy applies to members of the management and all employees and associates of Public Dialog Sp. z o.o. The scope of this Policy also includes any circumstance, action or situation that may lead to the actual or attempted use of any form of bribery or corruption, whether direct or indirect.

6. The rules

  1. Commitment to Countering Corruption: Public Dialog Sp. z o.o. strongly emphasises its opposition to any form of corruption and condemns all its manifestations. All employees of the Agency are required to comply with this Policy and to take actions that promote integrity and ethics.
  2. Acting with Integrity: Employees of Public Dialog Sp. z o.o. are expected to be guided by the highest ethical standards and integrity both inside and outside the workplace. It is prohibited to use one’s position or influence over others to gain an unfair advantage.
  3. Managing Conflicts of Interest: Employees of Public Dialog Sp. z o.o. are obliged to report potential or existing conflicts of interest that may affect the objectivity and integrity of the actions undertaken. Conflicts of interest must be handled in a transparent manner and in accordance with our values.
  4. Prohibition of Accepting and Offering Benefits: Employees of Public Dialog Sp. z o.o. are obliged not to accept, offer or facilitate the acceptance of any unjustified tangible or non-tangible benefit. All business relationships should be based on fairness and objective criteria.
  5. Transparency and Accounting: All transactions and activities of Public Dialog Sp. z o.o. must be properly documented and must comply with accounting rules and the law. Accounts and finances are transparent and audited in line with binding standards.
  6. Training and Education: Public Dialog Sp. z o.o. undertakes to train its employees on the Anti-Corruption Policy and professional ethics.
  7. Notification and Reporting of Violations: Employees are encouraged to immediately report any suspicions or instances of violations of the Anti-Corruption Policy. The Agency guarantees confidentiality and protection for whistleblowers.
  8. Consequences of Violations: Violations of the Anti-Corruption Policy of Public Dialog Sp. z o.o. may lead to disciplinary consequences, including dismissal and, if required by law, legal liability.

7. Responsibilities under the Policy

  1. All Agency employees must read, understand and comply with this Policy.
  2. All Agency employees must attend all training courses organised by the Company.
  3. The prevention, detection and reporting of cases of attempted bribery and other forms of corruption is the responsibility of all persons working for or under the control of the Agency. All such persons are required to avoid any action that may lead to or suggest a breach of this Policy.
  4. All employees of the Agency must ensure that relations with public officials, private individuals and other businesses are open and transparent so as to exclude the possibility of allegations and threats of corruption.
  5. All Agency employees are required to avoid conflicts of interest that could lead to a risk of corruption.
  6. If you are asked to make a payment on behalf of the Company, you should always consider what the payment relates to and whether the amount requested is proportionate to the goods or services provided. You should always request a receipt that details the reason for payment. If you have any suspicions, doubts or questions about payments, you should, if possible, raise them with the Board before taking any action.

8. Summary

This Anti-Corruption Policy underpins the Public Dialog Sp. z o.o. Agency’s commitment to ethical and lawful conduct.

Public Dialog Sp. z o.o. is committed to upholding these values and striving to develop trust both internally and in its relations with stakeholders.