Code of ethics

The Code of Ethics has been accepted and introduced by Scalo sp. z o. o. with its registered office in Wrocław as an approved code of conduct.

The Code of Ethics introduces the general principles of ethical conduct for the business the Company operates and intends to continue to operate.

The Code of Ethics outlines the ethical and moral standards of the Company and its suppliers considered essential to guarantee the fairness of the Company’s internal and external relations.

Scalo sp. z o. o. expects from its suppliers to apply this Code of Ethics to ensure the full and effective application of these rules in the full cycle of the service performance of the company.

Scalo will not be cooperating with entities, which do not meet the standards of this Code of Ethics.

Scalo, its personnel and suppliers shall comply with the binding laws and regulations, including the laws and regulations in the country where they perform the services, in particular they shall avoid activities and behaviour that could expose them or other people to the risk of participation in an unlawful activity.

Scalo’s personnel and its suppliers should exercise due diligence to acquire sufficient level of knowledge of the laws and regulations in the field of their professional activity. Due to the fact that personnel or suppliers do not have to be specialists in legislation that applies to their professional activity: (1) Scalo’s personnel in case of doubts should report them to Scalo for clarification, and (2) the suppliers should use qualified legal advisers.

In the field of compliance with the law it is crucial for Scalo to be compliant in particular with laws governing respect for human right, along with fundamental freedoms, labour and employment, health and safety, personal data, and protection of the environment, which fields require particular care and attention.

Scalo endeavour to shape an attitude of respect towards other people in its organization. In particular, Scalo undertakes steps aimed to counteract any discrimination on unlawful grounds.

Any form of harassment, coercion and bullying is strictly forbidden at Scalo, including those based on activities of a psychological and sexual nature.

Scalo constantly endeavour also to full compliance with the laws that:

1) govern the protection of Scalo personnel’s’ privacy,

2) are to ensure and improve the safety of Scalo’s personel in the performance of their duties.

HR department is coordinating relations among Scalo’s personnel based on the principles of mutual trust and respect, as well as treating others with dignity.

Scalo also comply with:

• the principles of the United Nations Universal Declaration of Human Rights;
• the fundamental conventions of the International Labour Organisation (ILO), in particular concerning forced and child labour;
• the principles of the United Nations Global Compact.

Personnel and suppliers should avoid situations of conflict of interest, i.e. where the interests of these individuals or entities cross or are contradictory with the interests of Scalo. All personnel and every supplier shall take care not to perform any action, either directly or indirectly, and not to make any statements that would place them in a conflict of interest with Scalo.

In particular:

1) personnel and suppliers shall not take actions and make any statements where the interests of the personnel or the supplier are wholly or partially contrary to the interests of Scalo. In such a situation, the personnel or the supplier should inform Scalo on a conflict of interest and refrain from taking actions to the time of agreeing with Scalo further course of actions.

2) personnel and suppliers shall obtain written consent from Scalo before concluding any transaction, in which there is a conflict of interest between Scalo and personnel or supplier.

3) personnel and suppliers shall not accept an assignment or work offers from a customer or competitor that could affect their judgement made in Scalo or performance of their duties in Scalo.

4) suppliers shall not take any active steps to recruit or employ Scalo’s personnel for at least a year after the end of cooperation.

Personnel and suppliers shall inform HR department of any conflict of interest situations.

Scalo endeavour to ensure compliance with the laws that govern the protection of personnel’s privacy.

Scalo sp. z o. o. and its suppliers shall meet the requirements and they follow the regulations under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) and meet the requirements therein.

Scalo strives for transparency and reliability in its communications. The aim is to enable personnel and suppliers, as well as any other recipients to be accurately informed of Scalo activities.

Personnel and suppliers shall not disclose the confidential information they got through their duties to parties outside Scalo and to other Scalo’s personnel who do not have authorisation to access it.

Particular vigilance shall be undertaken with respect to information on financial projections and results, employment and rules and conditions thereof, business concept of products and services provided by Scalo, know-how, commercial offers and relations with customers.

Scalo also cares that the disclosure of information is accurate, consistent and complete, therefore personnel and suppliers, without prior agreement with the Company, should not disclose any Scalo information to particularly sensitive recipients of information, in particular in relations with the media, investors, financial analysts and public and regulatory authorities. Communication with these entities and authorities is the sole responsibility of certain senior management at Scalo and competent Scalo’s personnel from specialized departments such as marketing and finance departments.

Any person, personnel or department that, in Scalo’s structure or in their scope of duties, has not been given responsibility for confidential information or communication, should not disclose any information about Scalo and should not undertake any communication activities regarding Scalo.

Confidentiality rules with customers and suppliers are included in the agreements with clients and suppliers.

The operations and transactions carried out by Scalo and its suppliers must be documented and recorded in a correct manner. Scalo keeps accurate accounting record based on appropriate law and accounting rules applicable in the company.

Each entry in the company’s books should be backed up with supporting documents.

Scalo and its suppliers shall endeavour to provide its personnel a safe working environment.

For this purpose Scalo:

1) identifies and assess the risk in that matter. Scalo undertakes precautionary measures to protect the personnel from accidents at work and occupational diseases.

2) Scalo in accordance with binding law provides regular training, informs personnel about potentially dangerous equipment or products, equip personnel with appropriate equipment and provide instructions for their use.

3) Scalo also ensures that his activities do not affect the health and safety of his subcontractors, third parties involved in the activities of Scalo, the local community and users of his products and services.

4) Scalo ensures that its standards comply with EU health and safety standards.

In the event of violation of these standards, or in the event of an occupational disease or accident, the incident should be reported to the supervisor in order to initiate the appropriate procedure under the Labour Code.

Scalo encourages suppliers to implement a health and safety management system Safety Management System based on binding law and where it is necessary bosed on international standards.

Scalo’s services, due to its scopel, have very limited influence on environment.

However, as an IT service provider, Scalo uses electricity. The company tries to limit its energy consumption as much as possible, e.g. by ensuring that equipment is switched off appropriately. It also uses energy-saving products.

Scalo does not use water for purposes other than those necessary to ensure hygienic working conditions under the Labour Code.

Scalo does not make air emissions.

Scalo does not use natural resources.

Scalo produces limited amount of wastes.

Scalo has a separate procedure regarding energy and waste management.

Scalo is committed to maintaining compliance of its solutions with the Copyright and Related Rights Act and relevant EU regulations.

Scalo enters into copyright transfer agreements with its personnel for remuneration.

Scalo shall comply with the Act on Combating Unfair Competition.

This act defines an act of unfair competition as an act contrary to the law or morality, if it threatens or prejudices the interest of another entrepreneur or customer.

In particular, the following actions are concerned: misleading designation of a company, false or fraudulent indication of the geographical origin of goods or services, misleading indication of goods or services, infringement of business secrets, inducing the termination or non-performance of a contract, imitation of products slander or unfair praise, hindering access to a market, bribery of a person holding a public office, as well as unfair or prohibited advertising, organising a system of pyramid selling and unreasonable extensions of payment periods for goods supplied or services rendered.

In addition, Scalo complies with the Competition and Consumer Protection Act, which prohibits agreements restricting competition and counteracting anti-competitive business conspiracies.

Scalo is subject to civil liability under Polish law for failure to comply with the above regulations, and in addition the President of the Office of Competition and Consumer Protection may impose penalties on the company as provided by law.

Scalo and its personnel are the authors of products that are created as part of their activities.

Scalo requires its suppliers to be transparent about the origin of their goods or services.

In the case of alleged breach of this rules of ethics, the personnel can inform their supervisor on the case in order to allow them to take an appropriate action in this scope.

Generally, any alleged or identified cases of ethics irregularities in Scalo should be solved internally with the involvement of Human Resources department and in case of doubt external advisors can be used, especially in legal, tax and HR matters.

Personnel who in good faith, report a breach of the rules laid down in this Code shall not be adversely affected due to such report.

As part of the whistleblowing procedure, each member of personnel has right to report any observed cases of:

• crime or offence;
• any serious and gross violation of a law or regulation, an international treaty or convention ratified or approved by Poland;
• serious threat or harm to the public interest;
• corruption and improper influence to other persons;
• accounting irregularities;
• violation of competition rules and standards;
• existence of risks related to or occurrence of serious violations of human rights and fundamental freedoms, the health and safety of people and the environment;
• other breaches of rules applicable in Scalo.