NowyStyl_Raport CSR_2022-2023_EN-www

GRI 2-23 GRI 2-24 At Nowy Styl, we adhere to a zero-tolerance policy on corruption. Our mission is to promote ethical action, based on applicable laws, wherever we operate. This approach is consistent with our values and builds Nowy Styl’s position as a reliable partner that shapes its identity in a responsible and fully transparent manner. To emphasize how important this principle is to us and to ensure its effective enforcement, we have decided to develop an additional document devoted to this topic, the Nowy Styl Anti-Corruption Policy , effective from 1st March 2022. The Nowy Styl Management Board has also appointed a Compliance Officer responsible for monitoring compliance with the Anti-Corruption Policy guidelines. As part of our periodic review, we updated this Anti-Corruption Policy on 16th September 2024. The purpose of the Anti-Corruption Policy is to estab- lish uniform rules for Nowy Styl and its related companies on how to proceed in the event of any abuse or even suspected abuse, taking into account the legal context of these entities’ operations. The policy contains guidelines to identify corrupt behaviour and avoid situations of conflict of interest. It forms part of internal ethical governance, on top of Nowy Styl’s Code of Ethics and applicable internal regulations, as well as being a component of Nowy Styl’s broader anti-corruption system. The Anti-Corruption Policy is meant for employees and associates of Nowy Styl and its related companies, as well as all stakeholders of Nowy Styl, i.e. external entities with whom we maintain or plan to establish some form of business relations. The Anti-Corruption Policy has been widely commu- nicated, i.e. by e-mail, on the Nowy Styl website in the Sustainable Development tab, on the Intranet (the Nowy Styl Portal) and on bulletin boards at production facilities. Anti-Corruption Policy topics are part of the onboarding/ induction training package. At the same time, Global Procurement and Supply Chain Department was included in the 2022 anti-corruption training conducted by a third- party law firm. Additionally, as part of teaching legal awareness, promoting correct and ethical attitudes and building a culture of compliance, in July-August 2024, employees of the above-mentioned department received the following training: Corruption in business, available on the e-learning platform of the Central Anticorruption Bureau with a proof of participation certificate. In 2024, extensive work was underway to prepare an e-learning training package. A mandatory module on compliance has been made available on the Nowy Styl e-learning platform – an e-learning course covering the following themes: Business Ethics, Anti-Corruption, GDPR. Employees were obliged to complete these training courses by the 30th of November 2024. At the same time, on the occasion of Compliance Day, which fell on the 26th of September 2024, an educational campaign was prepared to promote the values and impor- tance of compliance at Nowy Styl, with the following motto: “Let’s make compliance together”. As part of the campaign, educational posters on preventing corruption in business were prepared and made shared: Part 1: Corruption, Part 2: Conflict of interest and Part 3: Gifts and hospitality. The aim of the campaign was to present a complex topic in a viewer-friendly manner. In the Nowy Styl Anti-Corruption Policy , we commit ourselves to creating an ethical internal order with an effective and efficient corruption prevention system as a key component. Our primary goal is to prevent, detect and report instances of actions that may be conducive to corruption to the Compliance Officer. All employees and associates of Nowy Styl are obliged to avoid any actions that could lead to a violation of this principle. It is also our commitment to identify and manage conflicts of interest and to establish clear rules regarding a “gift policy” at Nowy Styl. In order to be able to actually fulfil these obligations, at Nowy Styl we focus on building legal awareness and educating our employees and associates in this area. Nowy Styl employees receive anti-corruption training, both as part of the onboarding and the subsequent training cycles. Anti-Corruption Policy 28 Table of contents