(version 2.0.; Wiązowna 23.05.2023)

In order to prevent any manifestation of corruption in the course of their activities, the Management Board and Employees of ATS Display Sp. z o.o. are firmly convinced of the necessity to comply with all applicable regulations, including legal regulations and ethical standards. Ethical behaviour as well as responsible business conduct is the primary and fundamental principle guiding ATS Display Sp. z o.o. and the responsibility for achieving the above-mentioned goal rests with all Employees, Associates and Representatives of ATS Display Sp. z o.o.

The principles listed below are complementary to both the applicable national and international legal standards on anti-corruption and are intended to clearly affirm a commitment to a long-term and stable business model.

The values of the ATS Display Sp. z o.o.

1. In our daily work, we observe the principle of transparency and honesty in the way we conduct our business and the Company strives to maintain the highest ethical standards in this respect.

2. The company is categorically prohibited from directly or indirectly offering, giving or accepting financial benefits and all transactions must be reflected in the accounting documents.

3. We apply ,,zero tolerance” policy in the case of bribery and corruption and we treat any such act with the utmost seriousness. Our Employees are not allowed to accept or offer financial or personal benefits in the course of their business activities, nor are they allowed to make the performance of any business activity conditional on receiving a financial or personal benefit.

4. We apply the principle of “zero tolerance” in the case of fraud, i.e. intentional provision of false data in financial reports, intentional introduction of false documents, falsification of documents, intentional confirmation of untruths in the scope of control, misrepresentation or omission of events, provision of false information regarding the company’s activities as well as any other intentional acts which might be harmful to ATS Display Sp. z o.o.

Corruption risk management

1. All employees of ATS Display Sp. z o.o., Members of the Management Board of the Company, as well as persons performing any activities on behalf of or for the benefit of the Company within the framework of concluded civil law agreements, are obliged to comply with the principles resulting from such Policy. Each newly hired employee is obliged to become familiar with this Anti-Corruption Policy and signs an appropriate statement in this regard. The statement is attached to the employee’s personal file. The content of this Policy is available to each employee in paper form in the Human Resources Department and in the library of procedures and internal regulations of ATS Display Sp. z o.o., as well as in electronic version on the company’s server, on a drive shared by all employees.

2. The Quality System Management Plenipotentiary and owners of individual Quality Process Management processes, based on the map of these processes developed in the ISO 9001:2015 Quality Book, are responsible for identifying corruption risks, assessing and estimating corruption risks. The Company’s employees are obliged to monitor the company’s processes on an ongoing basis for the potential or actual occurrence of corruption and report such situations to the Quality System Management Officer and/or the Board of Directors.

3. The process of monitoring the risk of corruption includes, among other things, verification of the identified risks in terms of their timeliness or appropriate assessment of a given risk on a point scale. Corruption risk control is carried out regularly, at least once a year, on the occasion of conducted internal audits, in accordance with the Quality Management System adopted at ATS Display Sp. z o. o. Reporting on corruption risks and countering corruption risks is carried out as part of the annual review of the Quality Management System.

Corruption risk analysis

As part of the Anti-Corruption Policy of ATS Display Sp. z o.o., a list of corruption risks was developed as a basis for identifying corruption risks. In addition, groups of factors that reduce and increase the likelihood of corruption and the effects of corruption have been also developed.

1. Factors that reduce the likelihood of danger – security measures in place:

1. the premises are adequately secured against access by persons who are not employees of ATS Display Sp. z o.o. or employees who are not authorized to inspect the records of the company’s business area:

2. physical protection of the facility and verification of persons entering/exiting the company’s premises in accordance with the “ATS Display Sp. z o.o. Visitor Reception Procedure”. dated April 1, 2023,

3. electronic access control system to the company building based on electronic passes assigned to specific users;

4. intrusion alarm system;

5. lockable cabinets or rooms where documents containing company trade secrets, personal data or other confidential data are kept;

6. clearly defined authorizations of employees with regard to employee responsibilities and powers of attorney;

7. transparent and objective system of employee remuneration defined in the Remuneration Regulations;

8. clear division of authority regarding the preparation, verification and approval of documents and financial operations;

9. activities performed by one employee are verified by his colleague or supervisor;

10. all processes identified at ATS Display Sp. z o.o. under the ISO 9001 : 2015 Quality Management System take place through the internal CRM – ERP system developed for ATS Display Sp. z o.o. which allows processes to be tracked at each stage of execution;

11. there are clear, stable and transparent rules of conduct defined in the Quality Book and other internal legal acts;

12. all premises, except for the social rooms, are covered by monitoring;

13. meetings between employees and non-employees of ATS Display Sp. z o.o. are held with the participation of several people;

14. access to documents is secured and access rights to documents are properly defined in accordance with the Personal Data Protection Policy of ATS Display Sp. z o.o.

15. networks and IT resources are secured against unauthorized access in accordance with the Personal Data Protection Policy of ATS Display Sp. z o.o.;

16. records are maintained to identify and account for activities and transactions performed;

17. ATS Display Sp. z o.o. attaches great importance to ethical and moral issues reflected in the Work Regulations, Anti-Corruption Policy and Code of Ethics;

2. Factors that increase the likelihood of danger

1. 1. employee turnover;

   2. large number and type of operations performed (orders received from Customers, outgoing orders to Suppliers, exchange of accounting documents);

   3. meetings between employees and non-employees of ATS Display Sp. z o.o. taking place without witnesses, outside the company’s headquarters;

   4. lack of developed rules for dealing with non-standard situations occurring occasionally;

   5. exposure of employees to pressure attempts from outside the company;

3. Implications for the occurrence of corruption:

1. loss of confidence in the company from both Customers and institutions and government offices,

2. loss of customers,

3. loss of image,

4. financial consequences,

5. legal consequences,

6. organizational consequences – failure to achieve the company’s goals and objectives,

7. delays in production orders,

8. increase in the advantage of competing companies in the POS materials industry.

Next, at the quantitative analysis stage, an analysis was made of the probability of corruption risk and the severity of the consequences of its occurrence. For this purpose, a matrix was drawn up together with a risk acceptability scale, which is an internal document of ATS Display Sp. z o.o. The developed list of risks of corruption does not mean that such situations have ever occurred. The list is only an inventory of potential risks at ATS Display Sp. z o.o., and their level has been classified as low or medium in the context of their probable occurrence and possible consequences of such risk occurrence.

Giving and receiving gifts

1. As part of ATS Display Sp. z o.o.’s business relations, it is permissible to accept and give occasional gifts, use other forms of hospitality and make donations within the limits of this Policy.

2. Employees shall inform the sender of the gift of the rules under this Policy.

3. All marketing activities shall be conducted by ATS Display Sp. z o.o. taking into account the principles of prevention of corruption, in accordance with this Policy and the Code of Ethics of ATS Display Sp. z o.o..

4. Giving or accepting occasional gifts in business relations shall be permitted only in situations that do not influence or give rise to suspicion of influencing Company decisions.

5. Within the framework of this Policy, it is permissible for an employee of ATS Display Sp. z o.o. to give or accept a symbolic occasional gift (e.g. at Christmas, anniversary) of a value not exceeding gross PLN 200.

6. The Marketing Department is responsible for the purchase of gifts on the basis of the reported demand. In exceptional circumstances, with the approval of the supervisor, it is permissible to purchase a gift by the employee directly concerned, however with consideration of the maximum value of such gift indicated above. In such a situation, for the costs incurred for the purchase of a gift, the employee giving the gift is required each time to submit to the Accounting Department proofs of any purchase/invoices, where the data of ATS Display Sp. z o. o. have been indicated as the data of the purchaser, after registration of such document by the Administration Department in the register of invoices and in the internal CRM – ERP system of ATS Display Sp. z o.o..

7. Employees of ATS Display Sp. z o.o. may accept and give gifts of symbolic material value having marketing character, such as calendars, pens or other advertising gadgets with the logo of ATS Display Sp. z o.o. or the logo of ATS Display Sp. z o.o. business partner.

8. It is unacceptable under any circumstances to give or accept cash or its equivalent as a gift, as well as invitations of a luxury nature.

9. Employees are required to immediately inform their direct supervisor after receiving or giving a gift by their department.

10. It is forbidden to give any gifts, regardless of their value, to auditors of certification bodies, state and local government officials, as well as to persons holding public office.

The use of other forms of hospitality

1. Employees of ATS Display Sp. z o.o. may participate in free conferences or trainings organized by business partners, if their subject matter is closely related to the scope of professional duties of the participating employees. The costs of transportation and accommodation related to the events mentioned above shall be covered by ATS Display Sp. z o.o..

2. Participation in the events referred to above shall require each time the consent of the Member of the Board.

3. The provisions of the Policy do not apply to business meetings (breakfasts, lunches, dinners) with business partners, organized for the purpose of building and maintaining business relations. Employees may participate in such meetings only as part of their official tasks, provided that the nature of such meetings does not deviate from the standards accepted in ordinary business relations.

4. In the case of business meetings initiated by ATS Display Sp. z o.o., it is permissible for ATS Display Sp. z o.o. to cover the costs of meals and/or accommodation of representatives of business partners, however, this decision is at all times made by the member of the Board.

5. Employees inviting to a business meeting, for the costs incurred in connection with such a meeting, are at all times required to submit to the Accounting Department proofs of purchase/invoices, where the data of ATS Display Sp. z o.o. have been indicated as the data of the purchaser, after registration of such document by the Administration Department in the register of invoices and in the internal CRM – ERP system of ATS Display Sp. z o.o.

Sponsoring and donations

1. Any donation made by ATS Display Sp. z o. o. must be transparent, indicating the recipient and the specific purpose for which the donation will be used by the recipient.

2. ATS Display Sp. z o.o. has adopted the principle that all donations are made exclusively for social, humanitarian purposes or in support of local education and culture, i.e. for the common good. This is to support the local community and for ATS Display Sp. z o.o. to build positive relations with such community.

3. Sponsorship and donation activities shall not be related to any business relationship between the sponsored entity and ATS Display Sp. z o.o..

4. Sponsorship or monetary donations provided by ATS Display Sp. z o.o., may only be made in non-cash form, via wire transfer to an account belonging to the recipient.

5. Donations may also be made in kind, e.g. in the form of purchased food or necessities, provided that proofs of purchase/invoices for such items are registered in the invoice register of ATS Display Sp. z o.o. and forwarding them to the Accounting Department.

Conflict of interest

1. All employees of ATS Display Sp. z o.o., Members of the Management Board of the Company, as well as persons performing any activities on behalf or for the benefit of the Company under the concluded civil lawal agreements are obliged to avoid conflicts of interest.

2. A conflict of interest shall be considered any situation in which an employee, acting in his/her own interest, in the interest of another person or company, acts at the same time against the interest of ATS Display Sp. z o.o..

3. Any employee who determines the existence of a conflict of interest in his/her case shall be obliged to immediately exclude himself/herself from the case in which he/she is involved and for which the conflict exists. The situation should be immediately reported to the immediate supervisor or directly to the Board of Directors in order to appoint a person to take over the management of the case.

4. The task of department heads is to reduce the risk of conflict of interest among their subordinate employees by providing preventive information about the potential for such a risk and consulting any doubts that arise among subordinates in this regard.

Reporting of irregularities

1. In the event of noticing any deviation from the legal norms or declarations contained in the Anti-Corruption Policy, each Employee of ATS Display Sp. z o.o. should report such deviation to his/her Supervisor or anonymously drop a note into one of the confidential boxes that are located in the buildings of ATS Display Sp. z o.o.

2. Any retaliation against an employee who, in good faith, reports a violation of a policy or regulation is prohibited, even if, in the course of clarifying the situation, the allegation proves to be unfounded. It should be remembered that acting in good faith means acting without malice or dishonesty.

3. The information provided in this way is taken from the boxes by the Administration Department and entered into the register. Each time, the Administration Department establishes preventive and corrective actions with the Management.

4. Suppliers, Customers and Partners working with ATS Display may report any irregularities or concerns regarding potential corrupt practices, unfair competition and other forms of improper conduct to the following email address: enquiry@atsdisplay.com

5. The Register with reported irregularities shall be kept by the Supervisor of the Quality Management System. The Company’s Management has access to the register as well.