DRINK ID’s Code of Ethical Conduct and Business Ethics contains the company’s established principles regarding compliance with the law and business ethics. It outlines the ethical standards and universal core values of the company. The Code of Ethical Conduct and Business Ethics is a standard of conduct set for all DRINK ID employees without exception. It is the responsibility of management at every level of the organisation to familiarise employees with its provisions and to conscientiously enforce its observance and implementation in every aspect of the activities undertaken.

Ethical behaviour is the basis of trust in business and in society. In order to guarantee trust, DRINK ID employees make every effort every day to ensure fair and equal treatment of our own stakeholders (managers, employees) and external, interested parties (customers, suppliers, contractors, agents, intermediaries, market competitors, local communities, the environment and society) and we expect the same from all stakeholders throughout our value chain and community. Our efforts can̨ only be trusted if we comply with the law, act responsibly, consistently, respectfully, fairly, treating everyone in an equal manner, with care, reliability and accountability.

We commit everyone to read the Code carefully and to abide by it in order to always act in a manner consistent with DRINK ID’s values.

This Code is our ethical compass, guiding everything we do in our workplaces. If you have information or suspect that a violation of any of the principles in the Code has occurred, you should report it immediately. We have made available a number of channels for you to report activities that you believe may constitute a breach of the Code. Information on these can be found later in this document.

DRINK ID’s Management Board would like to thank all of our employees for the passion and effort they put into upholding the highest possible standards of ethical business practices. Let us be proud of who we are, what we believe in and how we deliver on our mission.

  1. DRINK ID strives to comply with the laws, rules and regulations governing the conduct of business in all its areas. Our primary objective is to comply with them completely. Our employees shall avoid anything that threatens to entangle DRINK ID or its personnel in illegal activities. Taking advantage of DRINK ID’s employees or assets for any illegal purpose is strictly prohibited.

    In addition to the requirements strictly stipulated by law, DRINK ID employees must observe the highest standards of business and personal ethics in the performance of their duties. This means that they should always act honestly and ethically, regardless of whether they are dealing with other DRINK ID employees, third parties, other businesses, customers, suppliers or administrative or supervisory authorities. This also means avoiding any questionable relationship with persons or companies with whom DRINK ID transacts or may do business, not disclosing confidential information obtained in the course of their work at DRINK ID, and avoiding any situation that may give rise to a conflict of interest to the possible detriment of the employee and/or the company.

    Submission to DRINK ID’s Code of Ethical Conduct and Business Ethics is a condition of employment. Failure to comply with it will be subject to disciplinary consequences, including possible termination of employment. Failure to disclose violations of these standards and customs by other DRINK ID employees will also be grounds for disciplinary action against the employee.

  2. The use for personal purposes, without the consent of the Management Board, of company items or information acquired by employees in the workplace is prohibited. No employee is permitted to use company property, information or position for improper personal gain, or to directly or indirectly carry out activities that compete with DRINK ID’s business. Employees have a duty to the company to promote its legitimate interests whenever the opportunity arises.

  3. DRINK ID employees may not disclose confidential information to anyone outside the company without specific authorization. Confidentiality can cover different types of information, including all internal, confidential, proprietary or secret information related to DRINK ID’s business. Most of the company’s procedures, expertise and experience are protected as trade secrets. These constitute a valuable asset of the company. Confidential information also includes, among other things, production processes and methods, product recipes and compositions, computer software and passwords, financial data, financial forecasts, plans and strategies, customer price lists, production profits and costs, as well as other information relating to the business, customers and suppliers. In addition, in the course of its business, DRINK ID receives confidential information from other companies or individuals for the purposes of its business. Unauthorised disclosure of trade secrets may cause them to lose their value and may constitute a criminal offence or be tantamount to a breach of contract. The prohibition on disclosing trade secrets applies to employees both during and after their employment.

  4. The definition of corporate mail is very broad. It can range from e-mail, traditional mail and even individual memos, calendars and diaries. E-mail should be used primarily for business purposes. All e-mail messages are the property of DRINK ID. Employees’ use of the company’s computer systems to send or receive e-mail or to access the Internet is not covered by the Privacy Rule. DRINK ID may monitor the use of computer systems in order to prevent inappropriate use, as well as to reduce costs resulting from the storage of large amounts of data. Employees are not allowed to use e-mail for personal gain, advertising, soliciting funds, sending chain letters or sending any other message that could damage DRINK ID’s reputation. Because e-mail is not secure and its messages are essentially the electronic equivalent of a paper card, appropriate discretion should be exercised when sending confidential or proprietary information by e-mail and attached files should be password protected.

    When writing about business matters, it should always be borne in mind that company data is subject to compulsory disclosure to government authorities or private individuals in the course of possible legal proceedings and, more importantly, such material can be used by the media to shape public opinion about the company’s image.

    Regardless of who you write to, what you write can have significant consequences. Any message that is sent can easily be printed, modified and disseminated for purposes that are incompatible with its original purpose.

  5. DRINK ID does not tolerate any form of forced, coerced or child labour or any other unethical labour practices such as withholding of wages, denial of sick leave or daily rest, abuse of alternative forms of employment or avoidance of health insurance contributions. DRINK ID provides guarantees that such forms of labour and slavery, servitude or human trafficking do not take place within its operations and supply chain.

  6. DRINK ID does not discriminate against any employee or applicant for employment on the basis of race, colour, religion, nationality, gender, sexual preference, age, disability or political opinion. This principle applies to recruitment, during employment, access to training, promotion and other conditions of employment. Discrimination against an employee or applicant for employment is a serious breach of employment law, equal employment opportunity and DRINK ID company policy. Each supervisor has a responsibility to ensure that acts of discrimination do not occur. All human resources activities and company-sponsored employee programmes should be conducted without any acts of discrimination. The principles of equal employment are also contained in the DRINK ID’s Employment Regulations.

    Employees who have questions or complaints about compliance with this standard can address them to their supervisors, managers, HR or employer. For employees who find it inconvenient to speak openly with an authorised person, a “Complaints and Requests” box has been set up to which they can submit a written request while maintaining their privacy.

  7. DRINK ID takes the utmost care with regard to the privacy of employees, colleagues, customers, contractors, candidates, partners and others. This is particularly important with regard to personal data, which may consist of names, passwords, national identification numbers, home addresses, telephone numbers, bank account details, health information and other data made available in the process of recruitment, employment, establishment of business relationships, etc. DRINK ID’s Data Protection Notice (document) describes what personal data is collected, how and for what purpose it is used and with whom it is shared, and outlines the rights and options available to individuals in relation to the data processed.

  8. Workplace violence includes theft and other commercial crimes, physical violence and harassment (stalking), acts of violence against the employer, former or current employees and/or their family members, customers, suppliers and other third parties. In accordance with the relevant laws and regulations in force in the Republic of Poland, we prohibit the possession and/or use of firearms, other weapons, explosives/explosive devices and other dangerous materials while on company premises or in the performance of our duties. Any verbal threat of violence is unacceptable and should be reported to a supervisor or HR officer. Any report of a violent act or threat thereof will be thoroughly investigated.

    Any manifestation of verbal or physical aggression against third parties is subject to disciplinary responsibility and to reporting by the Employer to the appropriate legal authorities if there is a concern that a crime has been committed.

    At DRINK ID, there is zero tolerance for any verbal, non-verbal or physical behaviour that constitutes harassment or the creation of an intimidating, insulting, abusive or hostile environment – this includes, but is not limited to, displays of violence or sexual harassment in the workplace.

    Sexual harassment is any unwanted conduct relating to sex (including sexual orientation and transgender) that affects a person’s work. These include unwanted advances, requests for sexual favours and other verbal or physical conduct of a sexual nature that contributes to an intimidating, hostile or offensive atmosphere in the workplace.

    At DRINK ID, we do not tolerate behaviour that consists of:

    • Intimidating and humiliating others verbally or physically
    • Conduct in a degrading, offensive or hostile manner
    • Telling obscene jokes, making comments of a racial, ethnic, religious, disability, age or sexual orientation nature
    • Distributing or publishing offensive, violent or degrading material or images
    • Disseminating untrue information about others
    • Making sexual remarks or gestures or behaving in any other way that violates another person’s intimate personal area
  9. DRINK ID only employs adults. It does not provide student internships, apprenticeships for persons under the age of eighteen.

    DRINK ID does not cooperate with entities whose employees are not adults.

  10. DRINK ID employs its employees exclusively on the basis of the labour legislation in force in the Republic of Poland. No other forms of employment are allowed than those confirmed by an appropriate contract of employment with specified working and pay conditions.

  11. DRINK ID requires that no person performing official duties for the company and while on company premises is under the influence of alcohol or other psychoactive substances. This rule applies to all DRINK ID’s employees while on company premises, as well as while working off the premises. If an employee comes to work under the influence of drugs or is found to have alcohol or other chemical substances in their system, disciplinary action will be taken against them, up to and including possible termination of employment. Employees who have significant problems maintaining the quality of work or who cause serious accidents or damage to property will be disciplined if a medical examination reveals the presence of drugs in their system. Employees who distribute, sell, buy, manufacture, distribute, possess or use drugs while at work or on company premises may also be dismissed.

  12. DRINK ID applies transparent rules for the remuneration of employees for their work. The components of remuneration are specified in the documents binding the employee and the employer to the employment relationship (employment contract). The employee has the right to review at any time the manner in which his/her remuneration has been calculated, has the right to receive confirmation of the deductions made from his/her remuneration and to receive a statement of all the components of his/her remuneration. DRINK ID pays wages only to the bank account indicated by the employee. The company applies the minimum wage rules. Details and remuneration rules are described in the Remuneration Regulations, which are in place in the company and with which each employee is acquainted.

  13. All DRINK ID employees have a duty to report any suspected illegal, dishonest or unethical activity as soon as possible.

    All reports of violations are prioritised, investigated promptly and treated confidentially (to the extent legally possible) if that is the employee’s wish.

    There is no tolerance for retaliation against those who make a report.

    Employees can make reports in a form that is convenient for them: directly to their supervisor, to a member of the human resources department, to their employer, by telephone (telephone number listed on the electronic pass, available 24 hours a day), by e-mail or through the “Complaints and Requests” box.

  14. DRINK ID has a specialised unit dedicated to ensuring health and safety at work on behalf of the employer. The company provides all employees with the personal protective equipment necessary to perform their work, including protective and work clothing. There is also constant monitoring of factors potentially hazardous to the health or life of employees, job training on occupational health and safety, and trial evacuations and alarms.

    DRINK ID’s operations are subject to a number of health and safety regulations and laws, as well as environmental protection, which regulate emissions into the atmosphere and water bodies, waste disposal, including hazardous waste, transport of hazardous materials, chemical substance management and emergency plans.

    In addition to being familiar with DRINK ID’s operating and system procedures, the employee must be familiar with the environmental regulations and company policies governing its operations. The employee must immediately bring any emission or spill under control by reporting it in the manner provided for by the relevant regulations and company rules. Measures to ensure safety and corrective measures should be taken as soon as possible to minimise the adverse environmental impact of such accidents.

  15. DRINK ID’s production facility and the products it produces are subject to food safety regulations. All employees are expected to comply with these regulations and to report immediately to their supervisor any violations of these regulations. Employees should also immediately report all defects or failures in DRINK ID’s production processes, as well as any other incidents or situations that could threaten the destruction, deterioration of quality or contamination of food products produced in the company. In order to ensure quality and food safety in the company, a Food Safety Officer is appointed and a quality and food safety policy is implemented. DRINK ID constantly strives to improve and develop in the area of food safety by meeting the requirements of food standards and proceeding to their certification and maintenance.

  16. DRINK ID strictly respects the protection of intellectual property through: protection of industrial property rights, i.e. patents, utility models, own and client’s trademarks, protection of copyrights and commercial strategies through protection of trade secrets, confidentiality agreements with employees, clients and contractors.

    At DRINK ID, the obligation to respect intellectual property also applies to all computer applications. We only use legal software in accordance with the provisions of any licences for its use.

  17. DRINK ID operates by complying with national and international trade regulations, observing all import and export requirements making sure that the required duties, taxes and applicable fees have been paid. All transactions carried out by the company are concluded with the support of legal advisors to avoid potential illegality. DRINK ID does not trade with partners from embargoed or sanctioned countries. DRINK ID does not tolerate corruption in any form (including bribery, facilitation payments, reciprocal favours, extortion, abuse of power for personal benefit, giving undue advantages to influence decisions), whether in the private or public sector, and regardless of scale. DRINK ID requires its employees to make sure that all of the company’s business partners, including agents, consultants, contractors, suppliers, sales representatives, brokers, intermediaries, distributors, subcontractors, other partners and service providers throughout the value chain understand that corruption is unacceptable and thus to thoroughly check the aforementioned for this before engaging in collaboration.

  18. DRINK ID strives to actively participate in the social life of the local market. The company is a regular donor to local initiatives, supports non-public institutions, foundations, associations both materially and in kind. It engages in sponsorship activities.

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