CSR

Code of Ethics

The Scarlett Group, as the foundation of its ethical activities, introduces a Code of Ethics, which is a guideline setting out the rules of conduct for all employees at different levels in daily business activities. The Code reflects the company's aspiration to build relationships based on trust and fair cooperation with its business partners. 

The Code of Ethics is an inventory of the values that make up the company's organisational culture, shaped by employees, customers and the external environment.

1 Scope of application of the Code of Ethics

The Code of Ethics applies to all employees of Scarlett Services Sp. z o.o. and Scarlett Group companies, regardless of position, and business partners. It applies in every area of the company's business, both domestically and internationally.

2 Process for Reviewing and Updating the Code of Ethics

The Code of Ethics will be reviewed every two years, or more frequently if necessary, to ensure that it is up-to-date and in line with applicable laws and company values. The review process will be conducted by a dedicated ethics team.

3 Dedicated Responsibilities

The role of the Ethics Ambassador:
The Ethics Ambassador is responsible for monitoring compliance with the Code of Ethics, receiving and investigating reports of violations and initiating corrective action. The Ambassador or his/her designee provides training to employees and management on ethical principles and their application in practice.

Responsibilities of Employees:
Every employee is obliged to know and comply with the Code of Ethics. Any concerns regarding the Code of Conduct should be reported immediately to the Ethics Ambassador.

4 Procedure for reporting infringements

Employees have the right and duty to report any violation of the Code of Ethics. Reports can be made anonymously in accordance with the provisions contained in the Whistleblower Procedure 

5. Documentation and Audit

All reports of violations and the results of investigations are documented and stored in accordance with the company's privacy policy. These records are only accessible to authorised persons and are subject to regular audits to ensure compliance.

6 Communication and Training

Scarlett is committed to providing regular training on the Code of Ethics for all employees and management. The purpose of the training is to build ethical awareness and the ability to recognise situations that may violate the Code. Each supervisor ensures that employees in his or her area know and apply the above Code of Ethics. In case of questions and ambiguities, the first person to contact is the immediate supervisor.

7 Specific Principles of the Code of Ethics

  1. Compliance with the law-we comply with laws, rules and regulations around the world relating to our business activities. We respect human rights and demand the same from the companies we work with;
  2. Integrity in financial reporting and accounting - we maintain accurate and comprehensive records of our financial and business activities; All business activities are conducted openly. Information relating to labour, health, safety, environmental practices, business activities, structure of financial position and performance should be disclosed in accordance with applicable regulations and industry practices;
  3. Quality - we make every effort to ensure that the level of service we provide is of the highest possible standard and strive for continuous development;
  4. Ethics in competition - we only achieve an advantage over our competitors through excellent quality of work and continuous development. We do not take part in illegal or unethical commercial activities. We gain the company's advantage over our competitors through the professionalism that comes from the experience and knowledge of our employees;
  5. Anti-corruption - we operate openly and directly under the standards of fair competition and anti-trust law. Our employees are not permitted to offer their current or future business partners any financial benefits. It is also forbidden to provoke customers to offer employees bribes, illegal commissions or any other inappropriate gifts or favours. The company does not accept any corrupt activities that may lead to an attempt at bribery. Our employees undertake to prevent corruption in their daily work by:
    1. To be informed of circumstances likely to affect the impartial performance of their duties
    2. In the event of the occurrence of corrupt behaviour, employees are obliged to secure any evidence and inform their superiors without delay
    3. Information on possible attempted unfair cooperation is communicated in a confidential manner, each reported incident is checked personally by the employer or a person authorized to do so
    4. Confirmed allegations of corruption entail the employer drawing official consequences against the person who has engaged in unlawful behaviour;
  6. Protection of intellectual property - copying, distribution, unauthorised use, modification is prohibited. It is necessary to secure customer and supplier information;
  7. Employee documentation - as part of the recruitment process, employees must receive a written employment contract in their mother tongue, describing the terms and conditions of employment. A personnel file is established and maintained for each employee. The documents are kept during the employment relationship and for a minimum of I O years after its termination. Only copies or copies of documents should be kept in the employees' personal files. The employer may only ask to see the original document, which he then gives back to the employee. Employers may not withhold, conceal, destroy or deny employees access to their identity or immigration documents, e.g. work permits;
  8. Free choice of employment - no forced, compulsory, involuntary work through the use of threat , force, coercion. We do not impose unreasonable restrictions on freedom of movement on company premises, restrictions on entry or exit. Employees should be free to leave work at any time or to interrupt their employment;
  9. Data transfer control - staff ensure that information flows quickly and seamlessly in a holistic and falsification-free manner. We only use fair and lawful means of transferring information. We comply with data protection requirements and laws relating to the protection of information and safeguarding against the misuse of confidential, secret and personal data. We are committed to commercial confidentiality, internal information is only available to those authorised to receive it;
  10. Adhering to the principles of equal employment and respecting cultural differences - Equal employment and equal treatment of our employees is a key element of how our business operates. Any form of harassment or discrimination in the workplace on the basis of nationality, race, gender, religion, political affiliation, disability, sexual orientation, etc. is unacceptable. Employees should be provided with adequate space for religious practice. Any form of inappropriate behaviour towards another person that compromises their personal freedom is strictly prohibited. We do not accept any form of violence, either psychological or physical, in the workplace. We do not allow professional positions to be used to humiliate others or to harm anyone;
  11. Forced labour and child labour - any form of forced labour through restraint or threats of physical violence as a form of control and discipline of employees is prohibited. In the recruitment process, we respect the minimum age in accordance with national legislation in this area. The employment of children is strictly prohibited. The term child refers to persons below the age of 15 or below the age of completion of compulsory education. Young workers under the age of 18 should not perform work that may endanger their health and safety. Young apprentice workers are directed to what is termed light work without the possibility of night work or overtime;
  12. Freedom of association - we recognise the fundamental right of all workers to form trade unions and to elect their representatives in order to cooperate satisfactorily and to seek a balance of interests. We respect the rights of all workers to form and become members of unions and associations of their choice, the right to bargain collectively and to join peaceful assemblies. This allows workers and their representatives to openly communicate and share ideas and concerns about working conditions without fear of discrimination. At the same time, the rights of workers to refrain from such forms of activity must be respected;
  13. Avoiding conflicts of interest - we avoid relationships with others that could affect our judgment or create a conflict between our private interests and our loyalty to the company. We do not abuse our position in the company to take improper advantage for ourselves or others. We place great emphasis on ensuring that our employees, in the course of performing their duties, do not enter into relationships with customers, suppliers, etc. that may result in biased choices and a lack of objectivity. If a conflict of interest arises, such activity must be terminated;
  14. Protection of assets and information - we use company assets as well as all information only for company-related activities. We will not distribute entrusted information to third parties;
  15. Compliance with safety standards and regulations - we comply with applicable health and safety standards and regulations in our daily work. We consistently promote safe practices, avoiding unnecessary risks to our employees. Any safety hazards should be controlled through appropriate design, administrative controls, safe working procedures and regular training. The potential for employee exposure to safety hazards e.g. chemicals, fires, vehicle accidents, falls should be identified and assessed. In emergency situations, we seek to minimise their impact by implementing emergency plans and response procedures e.g. enforcement of notification, notification and evacuation of employees, training and drills for employees in this area, provision of appropriate equipment, clear and active emergency exits and role account recovery plans. All of these actions aim to minimise risks to health and life;
  16. Occupational diseases - procedures should be put in place to prevent, manage and report occupational injuries and diseases, provide necessary treatment, implement remedial measures and ensure return to work;
  17. Chemical, biological and physical agents - workers' exposure to harmful agents must be known, investigated and controlled according to the hierarchy of control measures . Potential hazards should be controlled and eliminated. In addition, workers should be provided with personal protective equipment and educational materials in this regard;
  18. Workplace hygiene - workers' exposure to the hazards of physically demanding tasks such as operating machinery, long standing, tasks requiring force, frequent lifting of heavy objects, etc. should be controlled. Particular attention should be paid to securing production machinery, proper maintenance, use of guards, interlocks, barriers and proper use. Workers should have access to clean toilet facilities, drinking water, a place to prepare and eat meals;
  19. Environmental protection - protecting the environment that surrounds us is a priority for us. We operate in compliance with current environmental legislation and permits. We continuously improve our products and technologies to become more environmentally friendly. All required environmental permits, standards, approvals and restrictions should be updated and complied with. Emissions of pollutants should be eliminated, their level and impact on the environment should be controlled, technological processes should be modified to minimise pollution levels. Natural resources should be used sensibly, economically and with the least possible impact on the environment. Hazardous substances should be appropriately labelled, secured, stored, recycled or disposed of. Segregating waste and reducing waste generation, as well as improving environmentally friendly technology, is our daily action and challenge ;
  20. Prohibition of sourcing minerals from war zones - there should be due diligence in sourcing and in the chain of custody of minerals. In addition, the due diligence measures in place should be made available to customers upon request;
  21. Remuneration and fringe benefits - we provide employees with details of their remuneration. Wages and fringe benefits are calculated and paid in accordance with applicable law. We respect legal requirements regarding minimum wage, overtime and mandatory fringe benefits. Employees should receive a pay slip for each consecutive pay period in a timely manner. This slip should contain sufficient information to verify the accuracy of the remuneration for the work performed;
  22. Working time - we maintain a transparent and reliable system of working time and payroll records. We respect the legal requirements for maximum permissible working time. The number of working hours and overtime hours is in accordance with the applicable legal provisions on permissible working hours. We comply with current legislation and standards regarding public holidays. The working week should not include more than 60 hours of work, including overtime, except in emergency and unusual situations. Employees should have at least one day off for every seven days. The daily break should be 11 hours and the weekly break is a minimum of 35 hours. Persons with a recognised moderate or severe disability have a daily standard of 7 hours and a weekly standard of 35 hours within an approved reference period of one month;
  23. Staff holidays - an employee is entitled to a leave of absence of 20/26 days per calendar year. The amount of annual leave depends on the length of service. A person classified as severely or moderately disabled is entitled to additional annual leave of 10 days per calendar year;
  24. Relationships with employees - are based on rules that are clear to both parties in line with current legislation. We foster a sense of satisfaction and responsibility for the company;
  25. Relationships with business partners - we are characterised by mutual respect and trust in our day-to-day relationships: timely billing, transparency of proposed offers, commercial agreements, reliable compliance with contract provisions and the consequences of these provisions;

8 Liability and Sanctions

Violations of the Code of Ethics may result in disciplinary action, up to and including termination of employment. Sanctions are decided on the basis of the results of an investigation by the Ethics Ambassador.

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