Statement of continued support

10.01.2022

To our stakeholders:

I am pleased to confirm that PCC EXOL SA reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Dariusz Ciesielski
President of the Management Board
PCC EXOL SA

As a signatory to the UN Global Compact, we implement the principles of this organization and fully respect all values in the field of human rights protection.
In 2014, we adopted: the Code of Ethics for Employees, the Supplier's Code of Ethical Conduct, Anticorruption Policy,
and a number of other documents related to respect for human rights.

We fully support and implement the provisions of the Universal Declaration of Human Rights.
We have also implemented and implement the Policy of Corporate Social Responsibility and the Anti-Corruption Policy.

As part of the adopted idea of corporate social responsibility and the promotion of an ethical culture, we have implemented a number of regulations applicable to all employees, subcontractors and business partners associated with our organization. Each document covering ethical issues in the Company is issued in at least two language versions: Polish and English.
As a responsible employer, we strive to provide our employees with the best conditions to improve their professional qualifications, free and transparent dialogue, as well as conditions allowing for maintaining life balance and development of passion.

The result of our activities is a number of initiatives addressed to all our employees, which are often cyclical programs, dedicated to both employees and their families.
With a sense of responsibility towards our employees, we introduce uniform and systematized standards of internal communication, which allows us to build a common corporate culture. We implement and improve methods of efficient information flow and effective communication at various levels of the organization.

Our employees have the opportunity to communicate, initiate discussions, exchange knowledge and share experiences based on a variety of communication methods.
We have focused our activities on ensuring the safety of employees and process safety at the production departments. Thus, occupational health and safety management is a priority for us, which we implement through the implemented policy in this area, identification and risk assessment or participation in activities carried out in the PCC Group, aimed at conducting business in a way that protects employees, facilities and equipment.

We are constantly striving to limit the negative impact of our business, as we belong to a group of companies with a high risk of a serious industrial accident. In our activities, we take into account the focus on risks that may affect employees, the local community and the environment. We maintain disaster prevention programs and handle all reporting issues. We use modern technological solutions applied in our departments, and our production processes take place in strictly controlled conditions, in a responsible and safe way. We provide all employees with mandatory and regular training in occupational health and safety as well as individual and collective measures to protect employees.
We provide safe and hygienic working conditions that meet the standards of the chemical industry.

Concern for the safety of people and the environment is one of the priorities in our business strategy. We aim to reduce all types of hazards occurring in the work environment by taking actions aimed among others at preventing accidents.

Any employee or other stakeholder may contact our company via the contact form on the website.
In the event of any violation of human rights in our organization, each employee may report the problem to a designated person from the human resources department. Each report is anonymous.
Detailed rules for the protection of employees have been compiled and described in the Company's Code of Ethics.

Every year, our company organizes training in the field of the Code of Ethics, including training in the field of human rights. Each employee also has access to training and presentations - e-learning training.

We undertake long-term activities related to the expectations of our stakeholders in terms of satisfaction with the cooperation, work performed and the possibility of constant development. Our dialogue with stakeholders is based on:

-Management meetings with managers of production departments
-Information bulletin entitled PCC Chem News
-Intranet
-Printed materials (leaflets, catalogs, brochures)
-Communication with Ethics Ombudsmen
-Thematic e-mail boxes
-Forum of PCC Group employees
-Employee and competence volunteering
-Social media

The Management Board and its representative - Manager & CSR Proxy are responsible for the implementation of the provisions of the Code of Ethics and applicable policies related to respecting human rights.
The HR department is the cooperating and executive body.

The company is bound not only by the Code of Ethics and policies that respect human rights.
There are special procedures based on state laws and regulations contained in the Labor Code.

In 2021, no complaints were reported from the company's stakeholders in the area of human rights violations. All employee rights are 100% respected in our company. Each employee can report a problem at any time and it is solved on an ongoing basis in accordance with the provisions of the Labor Code and the Code of Ethics in force in our organization. Cooperation in our company takes place on the basis of open dialogue and mutual respect.

We also did not register any court cases, judgments, fines or other significant incidents related to human rights violations in our organization.

The human rights situation is reviewed once a year. The company has a regular SMETA audit, the results of which are presented to the Company's Management Board.

PCC EXOL has a policy governing labour practices and human rights issues through formally defined
formally defined working conditions (e.g. wages and benefits, working hours, information sharing and participation on
working conditions), to which the following documents refer:
1. the Labour Regulations*;
2. Code of Conduct at PCC EXOL.

The remuneration policy in PCC EXOL is implemented taking into account current benchmarks remuneration. Determining an individual level of remuneration takes into account the employee's qualifications, professional experience or results of individual employee evaluation. Regardless of The Company provides social benefits irrespective of the basic remuneration, including e.g. co-financing The Company provides social benefits such as co-financing of summer holidays, MultiSport cards or an extensive bonus system.
The Company operates the PCC EXOL Code of Conduct, which is a set of rules and standards of ethical conduct ethical conduct. It is disseminated among all stakeholders, promoting mutual application of the written values. Through its content, the Company expresses its conviction about honesty, transparency and ethical conduct in every sphere of its activity. It defines the rights and obligations that the Company strives to meet in order to to meet in order to maintain the high level of the adopted standards.
The constitutional norm, together with many international conventions and Community Law, regulations for the protection of children from exploitation and excessive work. PCC EXOL recognizes the right of every child to be protected from economic exploitation and performing work that is hazardous, limits the opportunity for education, or constitutes a threat to physical, mental, spiritual, moral or social health and development.
The Company does not condone the employment of children and we respect all restrictions on the employment of persons under 18 years of age.

PCC EXOL does not employ children and does not force them to work, which is regulated by, among others, developed and implemented Code of Code of Conduct at PCC EXOL.
The Company promotes observance of the Fundamental Social Principles included in the guidelines of the International Labour International Labour Organization (ILO), which was created in response to global challenges international labour challenges, with regard to working conditions, safety at work, education universal education, social security, freedom of association and the elimination of all pathologies at work and the principles of the UN Global Compact initiative with regard to the ten fundamental principles of human rights, labor human rights, labor standards, environmental protection, and corruption prevention.
PCC EXOL is a signatory to the Diversity Charter, thus promoting diversity issues within the Company and in its external environment. Diversity Charter is an initiative of the European Commission
The Diversity Charter is an initiative of the European Commission and constitutes a written commitment of the signatory companies to prohibit discrimination in the workplace. As part of this initiative, the Company aims to involve all employees, business and social partners in counteracting discrimination and promote diversity as a factor for creativity and development.

PCC EXOL has a policy governing labour practices and human rights issues through formally defined
formally defined working conditions (e.g. wages and benefits, working hours, information sharing and participation on
working conditions), to which the following documents refer:
1. the Labour Regulations*;
2. Code of Conduct at PCC EXOL.
Regular evaluation of individual employee performance at PCC EXOL is formally regulated through
the following documents:
• Order 02/2015* on detailed rules of training in the field of health and safety work;
• bonus system in the Remuneration Regulations;
• system of evaluation of employees' competences and skills.
Principles of conducting the procedure PS.C.03.PR.02.I01 Identification of hazards at workplaces and how to reduce or eliminate them procedure PS.C.03.PR.02.I01 Hazard identification and risk assessment. To this procedure applies instruction PS.C.03.PR.02.I01 Guidelines for on job characterisation*, on how to proceed in case of the development of job characteristics and identification of hazards at workplaces (identification of work-related hazards that may cause accidents at work, occupational diseases and other occupational diseases and other health problems of employees) and instruction PS.C.03.PR.02.I02 Conducting I02 Carrying out occupational risk assessment*, which specifies how to proceed when carrying out an occupational risk assessment to protect workers' health, prevent the effects of occupational hazards and take effective measures necessary to ensure safety at workplaces.

As part of communication in the area of reporting violations of, among others, human rights, a team of
As part of communication in the area of informing about violations of e.g. human rights, a team of Ethics Officers has been established, whose basic task is to resolve disputes and provide explanations.
The main task of the Ethics Officer is to resolve disputes and provide clarification regarding provisions of the Code of Conduct, their possible interpretations and possible ambiguities.
All employees have the right to ask the Ethics Officer for help or advice if they feel that something is happening that does not comply with accepted ethical and social standards.
In PCC EXOL the issue of training in occupational health and safety for subcontractors working on on the premises is regulated by the Ordinance 02/2015* on detailed principles of training in the field of occupational health and safety, which translates the requirements of the Regulation of the Minister of Economy and Labor on training in the field of occupational safety and health, as amended amendments.
Additionally, the following are disseminated among the employees of subcontractors performing work on the site are distributed and made available:
• instructional videos for visitors to the site;
• leaflets on the rules of safety and hygiene in the workplace for employees and contractors;
• Material Safety Data Sheets;
• a map of the plant;
• ABC of Safe Work, a guide which was created for service contractors for the companies of the Group Companies in Brzeg Dolny.

PCC EXOL has formally developed and implemented Occupational Health and Safety Policy for PCC Group Companies, It is an element of the certified system of managing health and safety at work, according to the ISO 45001 STANDARD.
As part of the implemented, certified occupational health and safety management system, according to ISO 50001, systematic internal audits are conducted as well as inspections and internal controls, conducted by specialized occupational health and safety services.

In PCC EXOL in the scope of safety and health protection of employees the following additional measures are applied activities:
• additional medical examinations for employees at specialist positions of the departments
• production departments;
• co-financing influenza vaccinations;
• maintaining a certified system of occupational health and safety, according to the OHSAS 18001 standard,
• maintaining a certified system within the Responsible Care programme, including the Policy
• Responsible Care Policy, which declares continuous improvement of the Company's performance in the areas of
• process safety and occupational safety, and health and preventive healthcare.
The remuneration policy in PCC EXOL is implemented taking into account current benchmarks remuneration. Determining an individual level of remuneration takes into account the employee's qualifications, professional experience or results of individual employee evaluation. Regardless of the Company provides social benefits irrespective of the basic remuneration, including e.g. co-financing the Company provides social benefits such as co-financing of summer holidays, MultiSport cards or an extensive bonus system.
PCC EXOL has a policy that fixed remuneration is systematically higher than minimum wage.
The following actions are additionally applied in PCC EXOL in the scope of working conditions:
• cyclical meetings with representatives of trade union organizations on the topic of working conditions;
• eliminating losses and waste, as well as continuous improvement of the implemented solutions.
As a signatory to the Diversity Charter, PCC EXOL promotes diversity issues diversity issues within the Company and in its external environment. Diversity Charter is an initiative of the European Commission
The Diversity Charter is an initiative of the European Commission and constitutes a written commitment of the signatory companies to prohibit discrimination in the workplace. As part of this initiative, the Company aims to involve all employees, business and social partners in counteracting discrimination and promote diversity as a factor for creativity and development.

In PCC Group there are 4 trade union organizations, which according to Polish law represent all company's employees, in accordance with Polish law. The company, as an employer, conducts a dialogue with organizations throughout the year on the following issues current organization of work, working conditions and social conditions. Trade union organizations are informed about the Company's development and investment plans. Additionally, once a year wage negotiations are conducted, which result in the realization of group pay rises for the Company's employees at the level agreed upon by the parties.
A handbook distributed to each newly hired employee contains information on Trade Unions operating in the Company and the contact details of the persons representing those organizations.

PCC EXOL has a policy governing labour practices and human rights issues through formally defined
formally defined working conditions (e.g. wages and benefits, working hours, information sharing and participation on
working conditions), to which the following documents refer:
1. the Labour Regulations*;
2. Code of Conduct at PCC EXOL.

In PCC Group there are 4 trade union organizations, which according to Polish law represent all company's employees, in accordance with Polish law. The company, as an employer, conducts a dialogue with organizations throughout the year on the following issues current organization of work, working conditions and social conditions. Trade union organizations are informed about the Company's development and investment plans. Additionally, once a year wage negotiations are conducted, which result in the realization of group pay rises for the Company's employees at the level agreed upon by the parties.

A SMETA audit was conducted which included some or all of Labour Standards, Health & Safety, Environment and Business Ethics. The SMETA Best Practice Version 6.1 was applied. The scope of workers included all types at the site e.g. direct employees, agency workers, workers employed by service providers and workers provided by other contractors. Any deviations from the SMETA Methodology are stated (with reasons for deviation) in the
SMETA Declaration.
The audit scope was against the following reference documents
2-Pillar SMETA Audit
• ETI Base Code
• SMETA Additions
• Universal rights covering UNGP
• Management systems and code implementation,
• Responsible Recruitment
• Entitlement to Work & Immigration,
• Sub-Contracting and Home working,
4-Pillar SMETA
• 2-Pillar requirements plus
• Additional Pillar assessment of Environment
• Additional Pillar assessment of Business Ethics
• The Customer’s Supplier Code

1. Assessment of the environmental footprint and impact of the company
The company declares to minimize the impact on the environment through responsible management aimed at continuous improvement of the effects of operations and taking applied improvement actions in the area of ​​the organization's environmental footprint. For several years, it has been implementing the goals of sustainable development, which are the same as the goals of the United Nations set out in the 2030 Agenda. One of them is limiting the impact on climate change caused by excessive emission of greenhouse gases from the atmosphere.
Currently, PCC Exol measures the carbon footprint of the organization and reports on the CDP (Carbon Disclosure Project) platform. It is one of the prestigious initiatives, broadly understood reporting on greenhouse gas emissions and measures implemented to reduce them on the international platform of the CDP (Carbon Disclosure Project) organization. While implementing the assumptions of this project, we are obliged to prepare a detailed emission report every year. Our balance sheet is assessed in terms of criteria such as the quality and comprehensiveness of data or the effectiveness of measures to reduce emissions in individual areas of the Company's operations.
When reporting on the international CDP platform, we are obliged to report on our annual progress in reducing greenhouse gas emissions. Our key target includes reductions in areas such as electricity consumption and heat consumption in production processes and the means of transport used. The objectives are achieved, among others, through the implementation of appropriate management systems and the implementation of internal procedures related to energy management.
In Q4 2021, we took steps to calculate the carbon footprint of our products. We are currently working on data validation.

2. Written company policy on environmental issues, including prevention and management of environmental risks.
The company has a written Environmental Policy, according to which goals and tasks related to the environment and environmental risk are defined every year. The company declares to minimize the impact on the environment through responsible management aimed at continuous improvement of the results of its operations and taking appropriate improvement measures in the areas of: quality and quantity of generated wastewater, industrial water consumption, air pollution, waste generation, environmental footprint of the organization. The goals are achieved by planning the development of the organization based on environmentally friendly technologies; identification and ongoing analysis of all environmental aspects; assessment of risks and opportunities related to significant environmental aspects; planning and implementing an environmental action program; taking preventive actions related to failures; increasing the awareness and qualifications of Employees and Business Partners for environmental protection; building the sense of responsibility of Employees and Business Partners for activities affecting the environment; commitment of Employees and our Business Partners to activities aimed at minimizing the impact of the organization on the environment.

3. Policy requiring business partners and suppliers to adhere to the Global Compact environmental principles.
PCC Exol requires its suppliers to read the Code of Ethics and accept its provisions in cooperation. PCC Exol cooperates only with proven suppliers with a good opinion on the market. Their financial and ethical credibility is examined, as well as their approach to environmental protection.

4. Describe specific goals in the area of environmental protection for the upcoming year.
In line with the environmental policy, goals and tasks related to the environment and environmental risk are defined every year. PCC Exol declares the fulfillment of the objectives and special supervision over the fulfillment of legal and other requirements - through the lack of non-compliance, protection of the earth's surface and reduction of emissions into the air, limitation of the amount of generated waste - by reducing the amount of generated waste.

1. Awareness raising or training of employees on environmental protection.
While running our business, we are aware that we have a significant impact on the natural environment. Its elements are the source of the necessary resources used in the production of chemicals. Therefore, we are introducing steps to identify and monitor those of our activities that may have an impact on the environment. To achieve this: we define specific goals, design programs and use dedicated tools. In order to promote ecological IT solutions, we have introduced:
• teleconferences, videoconferences, webinars which reduce the number of employees' business trips, thus limiting the use of fleet cars;
• direct benefits of this solution are: reduction of greenhouse gas emissions, reduction of energy consumption and overheads, saving time;
• electronic document circulation, which has a direct impact on reducing the consumption of office materials;
• training employees in energy saving by: turning off unnecessary lighting
in offices, turning off devices that are not currently used, using power strips with a switch, sensible ventilation of air-conditioned rooms, reducing heat losses
and steam, by minimizing breakdowns and leaks in heating and transmission systems;
• IT equipment management by PCC IT under an outsourcing agreement;
• operation of multifunctional office devices that allow you to save energy and paper
and consumables.

2. Initiatives and programmes to reduce waste materials (e.g. recycling) and consumption of resources (energy, fossil fuels, water, electricity, paper, packaging, etc.)
One of the prestigious initiatives is the broadly understood reporting of greenhouse gas emissions and activities carried out to reduce them on the international platform of the CDP (Carbon Disclosure Project) organization. While implementing the assumptions of this project, we are obliged to prepare a detailed emission report every year. Our balance sheet is assessed in terms of criteria such as the quality and comprehensiveness of data or the effectiveness of measures to reduce emissions in individual areas of the Company's operations.
When reporting on the international CDP platform, we are obliged to report on our annual progress in reducing greenhouse gas emissions. Our key target includes reductions
in areas such as electricity consumption and heat consumption in production processes and the means of transport used. The objectives are achieved, among others, through the implementation of appropriate management systems and the implementation of internal procedures related to energy management.

Another initiative is the Responsible Care Global Charter program - in our business we undertake to act in a manner consistent with the principles of ethics and sustainable development. All activities are based on the guidelines of the global Responsible Care® program. The program is an expression of the efforts of the chemical industry to constantly raise standards in the field of health, environmental and occupational safety, regardless of legal regulations.

PCC EXOL is constantly striving to optimize energy consumption. This is mainly due to the use of Best Available Techniques (BAT), promoting good practices in energy consumption among employees, or implementing energy-saving solutions in administrative buildings.

3. Activities aimed at improving the energy efficiency of products, services and processes.
The organization has implemented and operates an integrated management system covering, inter alia, energy management system according to ISO 50001, confirmed by a certificate. Every year, the organization plans and budget energy goals and tasks under the IMS Review procedure.

As part of its activities, the organization supervises its activities with energy efficiency cards, which are an integral part of the investment project charter in accordance with the instructions for developing an investment project card as part of the investment project preparation procedure.
As part of the energy management system, the Company is obliged to carry out an annual energy review, the purpose of which is to determine the Company's energy performance and to analyze data and information that will lead to determining the possibilities of improving the achieved energy results.
The energy review covers the following topics:
a.analysis of energy use and consumption on the basis of measurements and other data, i.e .:
• identification of current energy sources;
• assessment of past and present use and consumption of energy;
b.on the basis of the analysis of energy use and consumption, identification of areas of significant energy use, i.e .:
• identification of facilities, equipment, systems, processes and personnel working for or on behalf of PCC Exol that have a significant impact on energy use and consumption;
• identification of other related variables (factors) contributing to significant energy use;
• determination of the current energy performance of the facilities, equipment, systems and processes associated with the identified significant energy use;
• estimating future use and consumption of energy;
c. identify, prioritize and record opportunities to improve energy performance.
PCC EXOL is constantly striving to optimize energy consumption. This is mainly due to the use of Best Available Techniques (BAT), promoting good practices in energy consumption among employees, or implementing energy-saving solutions in administrative buildings.

4. Raise awareness among suppliers by asking for the environmental footprint of products or services.
From 2021, we inform our suppliers about the importance of the carbon footprint of the raw materials we purchase, which affects the carbon footprint of our products. We inform about the implementation of the sustainable development goals, which are the same as the goals of the United Nations set out in the 2030 Agenda. First of all, about limiting the impact on the climate changes caused by the excessive emission of greenhouse gases into the atmosphere. Suppliers are notified that PCC Exol is currently measuring the carbon footprint of the entire organization, and action has also been taken from 2021
towards calculating the carbon footprint of our products.
We are gradually asking you to send the value of the coefficient of carbon dioxide equivalent (the so-called GWP or CO2e) for the raw materials we purchase; determining the method of calculating the carbon footprint (name of the method, ISO standard, protocol) and determining the range adopted for calculating the carbon footprint (cradle to grave, cradle to gate, gate to gate).

5. Environmental management system to identify, monitor and control the company's environmental performance.
The organization has implemented and operates an integrated management system covering, inter alia, environmental management system according to ISO 14001: 2015 and energy management system according to ISO 50001: 2018, confirmed by certificates. Every year, environmental and energy goals and tasks are planned and budgeted as part of the Integrated Management System Review procedure. As part of the activities undertaken, the organization supervises its activities with the environmental investment project information cards, which are an integral part of the investment project charter in accordance with the instructions for developing the investment project card as part of the investment project preparation procedure.

6. Allocation of responsibilities for environmental protection within the company.
The division of responsibility for environmental protection in the Company is defined in accordance with internal procedures. The company has an implemented and constantly improved environmental management process, which defines basic obligations for employees, and procedures and instructions detailing the functions performed. In addition, the Company has an Environmental Protection Advisor appointed within the structure, who is the Director of the Environmental Protection Office at PCC Rokita SA.

Care for the safety of people and the environment has long been treated as one of the priorities. The company undertakes a number of actions aimed at preventing accidents by limiting various types of threats
in the work environment. The company belongs to the group of plants with a high risk of a serious industrial accident, and therefore strives to reduce the negative impact of its operations, taking into account the risks that may affect employees, the local community and the environment. It has implemented failure prevention programs and handles all reporting related issues in this area. Thanks to modern technological solutions used in production departments, production processes take place under strictly controlled conditions, in a responsible and safe manner.
Systematic monitoring of the state of the environment, informing about possible threats, answering questions from residents and public discussion are the basis for building mutual relations based on trust and respect for the interests of all parties involved. This dialogue takes place through representatives of the PCC Group, representing all its companies.
In the case of emissions, reduction of odor nuisance, the formation of odors in the Company's operations is limited with the use of tools and devices, thanks to which we have the possibility of constant supervision against the occurrence of undesirable events, e.g.
• dust emission is reduced with the use of electrostatic precipitators ensuring compliance with legal requirements in the scope of emissions.
• to reduce odor nuisance, we use encapsulated production processes,
when loading or unloading substrates and products, we use tight connections
and gas pendulums ensuring that the leakage of odorous substances into the air is kept to a minimum.
• preventing the formation of odors during wastewater treatment, devices preventing the decay of wastewater are used, the biological treatment process is hermetic,
in addition, water curtains are installed around the tanks, which, if other methods fail, effectively mask unpleasant odors.

For the assessment of environmental performance, the investment project information sheets are used - the environment, which are an integral part of the investment project charter in accordance with the instructions for developing the investment project charter as part of the investment project preparation procedure.
As part of the Integrated Management System, internal audits are regularly carried out according to the schedule of internal audits. During the audits, environmental performance is assessed.

The company identifies threats as one of the first steps in assessing the associated risk
with the work performed. Correct identification of threats allows you to prevent occupational diseases, near misses - incidents and accidents, and thus safely carry out the assigned tasks.
When identifying the hazards and assessing the risk, the following are taken into account:
• routine (repetitive) and non-routine (incidental) activities,
• actions of all employees with access to the workplace (including subcontractors and visitors),
• people's behavior, their abilities / potential and other human factors,
• identified risks arising outside the workplace that may adversely affect the health and safety of employees at the workplace,
• threats arising in the vicinity (vicinity) of the workplace by related activities under the control of the organizational unit.
In addition, the Company has implemented a problem-solving database that includes constant supervision over problems occurring in the organization. Actions taken in order to immediately eliminate the detected non-compliance, eliminate the cause of the detected non-compliance or other undesirable situation and increase the effects of actions, e.g. as a result of breakdowns, fires, other incidents affecting the safety of people and the environment, internal and external audits and controls, workplace inspections, inspections of buildings and installations, risk assessments, customer complaints, SMS inspections, process monitoring, data and records analysis, other operational activities.

Specific progress made in the area of ​​the environmental protection during the last reporting period
• Modernization of the gas treatment system (investment ETS-1 wet filter)
• New absorption system - purification of gas from ethylene oxide and propylene oxide
• Construction of the yard at ETE-1 for storing products in unit packages - capturing and securing against any leaks, draining any leaks to the factory conalization from the packaging in the event of leakage

Periodic review of results by senior management
As part of the Integrated Management System, the Company (ZSZ) performs a management review once a year, which includes the quality, environmental, health and safety and energy management system. During the review, an analysis is made:
• the status of the follow-up to previous management reviews,
• changes:
about external and internal factors,
o the needs and expectations of interested parties, including compliance obligations,
o significant environmental aspects,
about legal requirements and other requirements,
about risks and opportunities.
• information on the functioning and effectiveness of the Integrated Management System, in terms of:
o customer satisfaction and feedback from relevant stakeholders
o the extent to which the objectives have been met,
about incidents, non-conformities, corrective actions,
on the effects of processes and compliance of products and services,
o the results of monitoring and measurements,
o compliance with compliance obligations,
about consultation and participation of employees,
o the results of audits,
about the activities of external suppliers.
• adequacy of resources,
• the extent to which policies have been implemented and objectives have been achieved;
• adequate communication with interested parties,
• effectiveness of actions taken, taking into account risks and opportunities,
• Relevant information from interested parties, including complaints,
• opportunities for continuous improvement.
External audits of environmental performance
As part of the Integrated Management System, internal audits are regularly carried out according to the schedule of internal audits. During the audits, environmental performance is also assessed. Audits are designed to be independent and objective evaluation by supporting the entity's managers in achieving the established goals and tasks of the entity's manager through systematic evaluation and advice from the auditor. After the audit, an audit report is defined, which includes a description of the strengths and weaknesses of the organizational unit, including recommendations for improving the system in order to increase the effectiveness of quality, environment, health and safety and energy management systems.

This Anti-Corruption Policy is oriented at all the employees of the Company PCC EXOL SA and its stakeholders.
„Running the business activity in compliance with binding us legal and industry regulations, we are oriented at observing the Polish and international anti-corruption law. We refuse to accept any manifestations of corruption and we commit ourselves to run the business activity in an honest and transparent manner”
Handing in and accepting bribes is highly unethical and against the law. It may lead to serious legal consequences for individual people and to serious legal and financial sanctions. Therefore we run our business activity in a transparent and honest manner. We make sure that all our transactions are compliant with the anti-corruption regulations and also with the requirement of maintaining complete and accurate accounting books.
Prohibition of corruptive behaviour
All forms of bribery are illegal. In compliance with the Polish and international anti-corruption law, we do not promise, we do not offer, we do not hand in nor in any manner transfer valuable items or financial means to civil servants and the Company’s stakeholders, if it is illegal or against the law. It relates to direct donations, such as cash, but also indirect ones such as allowing a civil servant or a stakeholder to use the property of PCC EXOL SA. Any donations demand permission of the Management Board and they are to be recorded in relevant accounting documents as an appropriate item.
Accepting gifts, services or other manifestations of politeness
Gifts, services and other manifestations of politeness received from present or potential customers, suppliers and other stakeholders of the Company are admissible only when they are handed in for business reasons and in compliance with the law. An employee is not allowed to run or shape negotiations depending on a gift, service or manifestation of politeness received from a customer, supplier or any other third party.
Handing in gifts, services or other manifestations of politeness
Gifts, services and other manifestations of politeness rendered for the benefit of present and potential customers, suppliers and other stakeholders of the Company, are admissible only in business situations under the binding legal regulations. In each such case manifestations of politeness are compliant with the law. Any related expenses are subject to reconciliation and accounting recording, in compliance with the determined company procedures. An employee is not allowed to run or shape negotiations depending on a gift, service or manifestation of politeness rendered for the benefit of a customer, supplier or any other stakeholders of the Company.
Conflict of interests
The employees of PCC EXOL SA, managerial staff and management are obliged to proceed in an honest and ethical manner and act to the best interest of the Company. All employees, managerial staff and management should try to avoid situations which create a potential or real conflict between their interests and the interests of the Company.

Business competition is an extremely important factor in determining economic growth. It makes it possible to improve the quality of products offered on the market, gaining an advantage and acquiring the opportunity to seek new, innovative applications and advantages. Competition intensifies the organisation’s efforts at self-development, making it possible to offer customers a range of products with different characteristics. We respect all of our competitors operating within the sphere of our business activities.
All employees are committed to unconditionally upholding the principles of fair competition and acting in accordance with the competition laws applicable to the regions of the world in which they conduct business.
In particular, each employee is obliged to:
• entering into agreements and organised activities which do not have the effect of restricting market competition;
• not provide competitors or other stakeholders in the company’s business sphere with any confidential information regarding, for example, pricing policies, strategies or customer data;
• apply the precautionary principle in business discussions;
• not inducing the company’s customers and suppliers to stop cooperating with competitors and not taking actions to limit an access to sources of supply for the competing entities;
• not to disseminate untrue information and opinions about the quality of products and not to undermine the knowledge and competence of employees of competing companies; all matters concerning competing entities and tasks requiring the involvement of market competition data should be consulted with the Legal Counsel
Respecting the principles of fair competition is a marker of honesty and business integrity for our customers and suppliers. This is why we comply with the relevant laws on fair competition and seek advice from Legal Counsel if problems arise.

REPORTING MISCONDUCT
In case of a justified suspicion that a misconduct or an event equal to a misconduct occurred in connection with
PCC EXOL SA business activity, each employee is obliged to immediately notify such suspicion directly or through their manager.
Employees may anonymously report all situations, and we protect those reporting in good faith from any retaliation. Besides a direct meeting, both internal and external stakeholders of PCC Exol SA may safety and efficiently inform about any misconducts by sending a letter to the following address:
The Management Board Office:
PCC Exol SA
ul. Sienkiewicza 4,
56-120 Brzeg Dolny, Polska
or by informing Members of the Management or Supervisory Boards of PCC Exol SA.
In case of a suspicion regarding a misconduct, immediate measures are undertaken, directed at gathering information enabling determination whether there has been a misconduct, and an investigation is carried out in order to classify a given incident.
If the misconduct is proved, proper measures are undertaken, including disciplinary actions, as well as measures aimed at prevention of occurrence of similar events in the future, and, if necessary, adequate authorities are informed and court proceedings are instituted against the offender, in order to repair the loss incurred by the Company.

RESPONSIBILITY
The Management Board of PCC EXOL SA. is responsible for creation of work environment free from any misconduct, for detection and prevention of misconducts, and minimisation of negative results of misconducts.
Each manager of an organizational unit should be particularly attentive and vigilant in case of any non-compliances, unusual events and violations of the applicable rules of behavior in their area of responsibility.

The company has a controlling unit which ensures compliance with all laws and regulations related to fair business. Internal audits are carried out
including periodic reviews by senior management.
In 2021, there were no investigations, lawsuits, judgments, fines and other corruption-related events related to corruption and bribery.