ANTI-CORRUPTION POLICY

Mobus Sp. z o.o. professes the principle of zero tolerance towards all manifestations of corruption.

Corruption is contrary to our aspirations to be a responsible company.

We want to actively participate in business as a responsible and trustworthy Company.

The zero tolerance policy for corruption applies to all of us, as well as to associates and business partners acting on our behalf. The entire management staff is obliged to take a key role in creating an organizational culture in which corruption will have no chance to occur and is a phenomenon unacceptable in any form. The Anti-Corruption Policy should be widely communicated and promoted among employees of our Company, supported by training initiatives enabling proper understanding and use of its principles in everyday work.

PURPOSE

The purpose of the Policy is to establish, both for us and for our associates and business partners, the obligation to apply the principle of zero tolerance for bribery and corruption, as well as to apply measures ensuring compliance with applicable regulations. This Policy contains guidelines that will allow identification and avoidance of the risk of irregularities.

The Policy is addressed to employees, associates, contractors, all business partners and the management staff of Mobus Sp. z o.o.

The Anti-Corruption Policy should be understood and treated in accordance with the work regulations applicable in the company.

As part of our communication activities aimed at preventing all forms of corruption, the Anti-Corruption Policy should also reach all stakeholders, including customers and suppliers.

It is important that the Anti-Corruption Policy does not constitute the sole source of information or interpretation of every business situation. Therefore, it is the duty of each of us to familiarize ourselves with regulations, provisions and publicly available information regarding corruption, bribery and related phenomena damaging the good name of our organization and undermining trust in it and its members.

In case we are not sure how to behave in a situation of corruption risk, we should contact our supervisor or the HR Manager.

WHAT IS BRIBERY AND CORRUPTION?

Bribery is:

an offer, promise or giving of a bribe (active form)
solicitation, demand, agreement to receive a bribe (passive form) in any form, of any value, which may be considered as a case of inducing bribery (active or passive), which is contrary to accepted rules of conduct, illegal, bears the hallmarks of corruption, is unethical or violates the law.

Corruption is:

abuse of an official position, power or influence in order to obtain unofficial and unjustified personal benefits or for other persons. It is also offering, giving or accepting in any form, regardless of value, any goods.

A “benefit” is understood not only as a material benefit, but also non-material, regardless of its nature and method of obtaining (including donation, employment contract, confidential information, preferential treatment, gifts, rewards, invitations).

Please do not identify acceptance of the above benefits, bribery, corruption or a bribe with loyalty programs existing in the organization and communicated to the general knowledge of members of the organization/company.

In the light of the Anti-Corruption Policy, corruption means bribery, extortion or solicitation, influence trading and laundering of income derived from these practices.

PRINCIPLES OF THE ANTI-CORRUPTION POLICY

3.1 Transparency of Corporate Governance

We act fairly and honestly. We strive to act in a modern, dynamic and friendly manner, and moreover we take care of openness and transparency of our actions. We want, thanks to such an attitude, customers to perceive us as a responsible Company that can be trusted.

We act in accordance with applicable law.

Mobus Sp. z o.o. adopts a policy of zero tolerance for corruption in all aspects of its activities.

We are committed to enforcing the Anti-Corruption Policy and undertake to train persons working in our organization in compliance with our principles.

In accordance with the adopted Policy, the following actions are always and in any form prohibited, regardless of whether they are indirect or direct actions both in Mobus Sp. z o.o. and in relations with its stakeholders:

bribery
extortion or solicitation
influence trading
laundering of income derived from corrupt activities

We wish to ensure that a person who reports a suspicion of abuse or refuses to participate in bribery or corruption will not encounter negative consequences of their decision.

3.2 Compliance with applicable law and international conventions

In most countries, the act of bribery or its attempt is treated as a crime, for which significant criminal sanctions are imposed in the form of fines or restriction/deprivation of liberty, applied both to companies and employees. Some of these regulations are international acts of universal scope aimed at combating bribery and corruption (e.g. OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, United Nations Convention against Corruption). Individual countries are working on strengthening their anti-corruption legislation.

In connection with the above, Mobus Sp. z o.o. takes appropriate actions towards its employees, associates and stakeholders aimed at informing them about obligations and the scope of responsibility.

AREAS OF CORRUPTION RISK (CORRUPTION THREATS)

Reasonable gifts and invitations (meals, events, entertainment) may support the process of concluding, maintaining and developing important business relationships, as well as loyalty programs organized by Mobus Sp. z o.o. and stakeholders and cooperating companies. The intention of our organization is that its employees do not feel exposed in such situations to accusations of maintaining business relations through behavior inconsistent with applicable norms and regulations. Giving or receiving gifts in a manner considered inappropriate may expose both our employees and the Company to accusations of violating legal provisions on corruption.

Therefore, before accepting a gift or offering one, you should make sure that your action complies with the principles adopted in our company.

We allow:

accepting or offering modest gifts, the value of which, as a rule, does not exceed the equivalent of PLN 100. Gifts may not include cash or its equivalents (e.g. gift cards, vouchers, etc.),
accepting and offering small holiday gifts, constituting an element of culture and customs prevailing in Poland.

Below are examples of actions considered unacceptable:

transfer, promise of transfer, offering or inducing gratification in the form of payment, gift, trip, invitation or other benefit in order to obtain a specific business benefit or in gratitude for obtaining a business benefit,
transfer, promise of transfer, offering gratification in the form of payment, gift, trip, invitation (meals, events, entertainment) or other benefit to a public official or intermediary in order to facilitate or accelerate routine procedures,
promise of payment or acceptance of payment from third parties when you suspect or are certain that they expect specific business benefits in return,
acceptance of a gift, trip, invitation (meals, events, entertainment) or other benefit or promise thereof from third parties when you suspect or are certain that they expect specific benefits in return.

All contacts with contractors, associates and clients of Mobus Sp. z o.o. may take place only within business relations. Contact should take place via email correspondence, fax, business phones and through direct meetings with the knowledge and consent of the supervisor. In email contacts we use only company emails.

Mobus Sp. z o.o. does not allow accepting or giving bribes (financial gratifications). From third parties we expect application of the principles of our Policy with due diligence.

OBLIGATIONS

Employees:

Prevention, detection and reporting of cases of bribery, as well as other forms of corruption, is our duty, as well as the duty of those who work under our supervision. All employees of Mobus Sp. z o.o. are obliged to avoid any actions that could lead to a violation of this principle. If you suspect that such a violation has occurred or may occur in the future, you should report this fact as soon as possible to your supervisor or the HR Manager. An example of a case that should be reported is a situation in which a client or potential client offers you something thanks to which they could obtain a business benefit or suggests that giving a gift or financial benefit is a condition for concluding a transaction. In the case of an offer or receipt of a gift from a business partner, this fact should be immediately reported to the direct supervisor or the HR Manager.

Contractors, suppliers, cooperating companies:

The Anti-Corruption Policy of Mobus Sp. z o.o. obliges business partners, suppliers, customers to act honestly without intentions and actions related to corruption and to comply with the following principles:

compliance with this Anti-Corruption Policy,
not offering and not giving any financial or other benefit,
cooperating with Mobus Sp. z o.o. in eliminating corrupt behavior,
ensuring that relations with public officials, private persons and other entrepreneurs are open and transparent in order to exclude the possibility of allegations and corruption risks,
avoiding conflicts of interest that could lead to corruption risk.

REPORTING ABUSES

Employees of Mobus Sp. z o.o. may report their concerns or seek advice in case there is suspicion of violation of the Anti-Corruption Policy or other legal provisions, without fear of retaliation, acts of discrimination or disciplinary proceedings.

Reports are treated confidentially and examined with due diligence.

Suspicions of violations of the Anti-Corruption Policy of Mobus Sp. z o.o. or other legal provisions may be reported directly to the supervisor or the HR Manager.

External entities, including business partners, suppliers and other interested parties, may report cases of violations, in particular concerning corruption, bribery or unethical business practices, via the email address: mobus@mobus.pl.

DOCUMENTATION, TRANSPARENCY AND CONTROL PROCEDURES

The regulations mentioned above oblige Mobus Sp. z o.o. to demonstrate compliance with applicable regulations and appropriate procedures, the purpose of which is to ensure the reliability of accounting books and records.

Therefore, our Company follows the principle of full transparency in its activities and applies adequate control processes.

The Management Board of the company and persons designated by it periodically monitor and review compliance with this policy and procedures related to risk management in Mobus Sp. z o.o.

FINAL PROVISIONS

Each employee of the company is obliged to familiarize themselves with this document and strictly comply with its content

Mobus Sp. z o.o. clearly defines the consequences of corrupt behavior and non-compliance with the Anti-Corruption Policy – from warning, reprimand up to disciplinary dismissal, and including notification of law enforcement authorities

Each case of non-compliance with this procedure will be considered individually