ALOKAI SP. Z O.O. CODE OF CONDUCT
1. Introduction
Alokai Sp. z o.o. with its headquarters in Warsaw and its related entities: Alokai Inc. (together the “Company”) is committed to acting ethically and conducting business in compliance with all applicable laws. This Code of Conduct (the “Code”) sets out basic guidelines, rules, and principles for how employees, co-workers, contractors and consultants of the Company, as well as management staff (“Co-workers”) are expected to act when conducting business on behalf of the Company.
The Company may have additional principles and procedures which supplement this Code. Further, Co-workers may sign a separate agreement with the Company to protect Confidential Information and to transfer intellectual property. Each Co-worker is obliged to comply with such principles, procedures and agreements.
In case of any questions about any provision of this Code, each Co-worker can seek guidance from the Company’s People & Culture Department (“P&C Department” or “People & Culture Department”).
2. Compliance with Laws, Rules & Regulations
The Company takes its responsibility to comply with applicable laws very seriously. The Co-worker must follow all applicable provisions of law. Each Co-worker should know the significant laws, rules and regulations that apply to the Co-worker’s performance of duties for the Company.
3. Conflicts of Interest
While performing duties for the Company, the Co-worker is obliged to act in the Company’s best interest at all times and avoid conflicts of interest.
A conflict of interest is a situation where an opportunity for personal gain is contrary to the Company's best interests. The Co-worker must use good judgment and, when in doubt, consult the matter with the P&C Department in order to avoid situations that create actual, potential, or perceived conflicts of interest. The Co-worker shall consult the situation with their supervisor and the People & Culture Department before taking any action that may cause conflict of interest.
A potential conflict of interest must be appropriately disclosed by the Co-worker and then discussed and managed by the Co-worker’s supervisor and the People & Culture Department.
Conflicts of interests can appear in many different forms, including:
● holding shares in companies conducting (or intending to conduct) activities which compete with the Company, performing advisory functions or sitting on bodies of such companies;
● any form of cooperation with companies conducting (or intending to conduct) activities which compete with the Company, in particular providing work or services to these companies;
● conducting the Company’s business with the family members of the Co-worker or other related persons or entities;
● accepting financial benefits related to performance of official duties for the Company, directly or indirectly through a family member or other related person; and
● entering a personal relationship with a subordinate or supervisor, unless such relationship is disclosed to the appropriate supervisor and the P&C Department.
If a Co-worker believes a conflict of interest may exist, they should promptly notify their supervisor and the P&C Department. The P&C Department will consider all the facts and circumstances of the situation to decide what action is appropriate in order to avoid such conflict of interest. If the Company determines that that activity interferes with the Co-worker’s ability to perform their duties for the Company or it poses an actual conflict of interest for the Company, the Co-worker may be asked to terminate such activity.
4. Safe and Healthy Workplace (Only Applies to Employees)
Company operates with a part of the employees working remotely (outside of the Company’s designated office), in particular from their homes. Due to the above, employees are expected to follow the appropriate rules for occupational health and safety (i.e. keeping workspace well lit, ensuring correct monitor settings and that the electric cords are safely secured, etc.). Employees who have suffered an accident while performing their work duties remotely are required to immediately notify the P&C Department of the accident, if possible.
5. Professional Work Environment
The Company strives to maintain a professional work environment. Use of alcohol, illegal drugs, or any psychoactive substances, whether on or off the job, can negatively affect work performance, efficiency, safety, and health and, directly or indirectly, seriously impair the Company’s image, interests and activity.
Specifically, this Code prohibits:
● possession, use or being under the influence of alcohol, illegal drugs or any psychoactive substances while performing duties for the Company
● driving a vehicle while under the influence of alcohol, illegal drugs or any psychoactive substances while performing duties for the Company; distribution, sale, or purchase of alcohol, illegal drugs or any psychoactive substances while performing work duties for the Company.
Moderate consumption of alcohol by legal-age individuals at Company-sponsored events is permitted. Everyone involved must exercise good judgment, act professionally and responsibly, and follow directions provided for the Company event. Attendance at Company social events is not mandatory. Furthermore, attendees should not be pressured to consume alcoholic beverages.
6. Anti-Harassment and Anti-Discrimination Policy
The Company believes that a supportive and respectful workplace, where everyone feels comfortable and included, is key to success. The Company undertakes to combat discrimination at the workplace, in particular discrimination based on age, sex, race, nationality, sexual orientation, health condition, disability, ethnic background, religion, creed or lack thereof, political beliefs, family status, lifestyle, scope and basis of employment or other types of cooperation. The Company believes that diversity of backgrounds, perspectives and opinions fuels innovation and creates a supportive work environment.
The Company does not discriminate in any employment decisions, including decisions on hiring, cooperation, compensation, promotion, discipline, or termination of agreements.
The Company strives to maintain a professional environment based on respect, tolerance and equal opportunities. Discrimination or harassment will not be tolerated and appropriate consequences will be imposed on the perpetrators of such behaviours. Co-workers undertake to assist in maintaining a respectful workplace culture that is based on respect, free of harassment, bias, and unlawful discrimination of any kind. The Company has implemented an Anti-Harassment and Anti-Discrimination Policy attached as Appendix 1 to this Code.
7. Outside Employment (Only Applies to Employees)
Employees are fully committed to performing their duties for the Company. A Co-worker may not start their own business if it competes with the Company’s business, or cooperate with any entity competing with the Company’s business.
8. Protection of Intellectual Property
The Company's trademarks, logos, copyrights, trade secrets, "know-how", and patents ("Intellectual Property") are the Company’s valuable assets. Unauthorized or inappropriate use of the Intellectual Property can lead to its loss and significant loss of value. Co-worker is obliged to use the Company's Intellectual Property in accordance with the nature and intended use of the Company’s Intellectual Property. Co-worker must respect the Intellectual Property of third parties, in particular, refrain from infringing Intellectual Property rights of other parties and use the intellectual property of third parties in a manner agreed with these third parties and in accordance with the applicable provisions of law.
9. Protection of Confidential Information and the Company’s Assets
The Company is committed to keep all confidential and proprietary information ("Confidential Information") confidential. While implementing its confidentiality obligations, the Company exercises the utmost care and acts in accordance with applicable provisions of law.
While performing duties for the Company, Co-workers routinely gain access to Confidential Information of the Company or the Company’s business partners. Accordingly, Co-workers are also obligated to maintain the confidentiality of the Company’s (and its business partners’) Confidential Information, which they learn of during their collaboration with the Company, particularly trade secrets. Breach of trade secrets, according to EU Directive 2016/943 and the applicable laws in the respective country, constitutes an offense or crime. The Company's Confidential Information includes any undisclosed technical, technological, commercial, or organizational information (know-how) of the Company, for which the Company or its authorized persons have taken necessary actions to maintain confidentiality, and such information does not need to be explicitly marked as confidential.
In particular, Co-workers may not disclose Confidential Information to third parties, including family, friends, and other Co-workers, unless the disclosure of Confidential Information is justified by the duties performed by these Co-workers or has been approved by the Company. Generally, the disclosure of Confidential Information should be subject to a non-disclosure agreement.
Before accepting any Confidential Information from third parties, the parties must sign a non-disclosure agreement approved by the law firm or in-house or external legal counsel cooperating with the Company. If a Co-worker believes that they inadvertently came into possession of a third party's Confidential Information, the Co-worker is obliged to seek advice from the P&C Department.
Upon termination of the Co-worker’s employment or cooperation with the Company, irrespective of the grounds for the termination, the Co-worker must return or destroy all Confidential Information in their possession, as instructed by the Company.
10. Protection of the Company’s Assets
As part of the performance of work or services by the Co-worker for the Company, the Company may provide the Co-worker with access to a computer, cell phone or other devices, as well as access to the Company’s e-mail system, the Internet, and other third party applications ("Devices"). Co-worker must use the Devices solely for the benefit of the Company, for purposes in connection with the performance of work or services for the Company. The Company may monitor anything created, stored, sent, or received in using such Devices. Co-worker shall not use the Devices, including the use of business e-mail, to violate the law or principles of the Company. Further, creating, storing or sending content that others might find offensive is prohibited.
11. Privacy and Data Protection
The Company undertakes to protect the data privacy of the Company’s Co-workers, customers, potential customers, business partners, suppliers and Company’s website visitors. A Co-worker who gains access to personal data is obliged to be familiar with the internal policies that apply to privacy and personal data protection, as well as with the obligations that apply to privacy and personal data protection arising from the agreement between the Co-worker and the Company. Co-worker is obliged to comply with the above indicated principles and obligations, as well as with the applicable provisions of law regarding privacy and personal data protection.
12. Business Meals, Company Events and Other Business Events
The Company expects everyone acting on its behalf to perform their duties honestly, reliably and ethically, in accordance with the applicable provisions of law and the Company’s principles.
Co-workers may participate in infrequent and moderate business meals and company events with customers, suppliers and other business partners as part of building business relationships with these entities (“Business Events”). Business Events should be occasional, appropriate and moderate. Co-Worker undertakes to duly represent the Company during Business Events, in particular to act in a responsible and professional manner. Before offering or accepting an invitation to a company event of the customer, supplier or another business partner, Co-worker must obtain Company’s permission.
13. Giving and Receiving Business Gifts
Co-workers and members of their families may accept appropriate and moderate business gifts as part of building relationships with other Co-workers, customers, suppliers or business partners of the Company (“Business Gifts”), subject to the following conditions:
● Cash and gift cards with a value greater than reasonable are not Business Gifts;
● the Business Gift is consistent with customary business practices;
● the Business Gift is appropriate, specifically, there is not any subtext directed at the recipient of the gift, and the gift is not a bribe; the Business Gift should be reasonable in value;
● Granting of the Business Gift does not violate any rights of third parties, applicable provisions of law or the Company’s principles.
Except for symbolic gifts, Co-worker may not receive any income or material gain from a third party in connection with the Co-workers’ performance of duties for the Company. The above described material gain shall not be considered as Business Gifts.
14. Anti-Corruption Policy
Co-worker undertakes to be truthful and transparent during interactions with customers, suppliers, and business partners. Influencing the decisions of a customer, supplier or business partner through improper payments or making other illicit offers is strictly prohibited. The Company believes that acting with integrity is the basis of conducting business activity and the only way to acquire and preserve the trust of customers, suppliers or other business partners.
In particular, the following shall be prohibited:
● Bribery - offering or giving any material gain in order to influence the actions of the recipient of the bribe. Bribe can take the form of cash, as well as its equivalents, such as expensive gifts, i.e. plane tickets, vouchers for expensive hotels, charitable contributions and offers of employment.
● Facilitation payments - offering or giving tips or small monetary benefits to a government official or any public official in order to obtain or expedite the issuance of a decision.
● Kickback - returning of a sum paid (or due to be paid) in connection with business cooperation, which is or can be construed as a reward for fostering a business arrangement.
15. Fair Competition
The Company believes in free and open competition and outperforming the Company’s competitors fairly and honestly with products and services of superior quality. Co-worker must adhere to all applicable laws, as well as obligations that apply to fair trading arising from the agreement between the Co-worker and the Company.
In particular, the following conduct is prohibited:
● undertaking any activities deemed as unfair competition, in accordance with general competition law principles applicable in the relevant jurisdiction, including international antitrust standards and competition regulations;
● agreeing with competitors about prices;
● concluding agreements with entities competitive to the Company;
● hindering other entities’ access to the market, in particular concluding agreements which would restrict free trade;
● agreeing with competitors on prices, bids or to allocation of customers or markets;
● agreeing with competitors to boycott a supplier or a customer;
● violating the intellectual property rights of third parties;
● violating business secrets, i.e. disclosure or the use of Confidential Information, and
● entering a business arrangement or pursuing a strategy with the sole purpose of harming a competitor of the Company.
Company offers products and services which are competitive because of their quality. Communication with customers or potential customers of the Company must be transparent and reliable at all times. Statements made on behalf of the Company about its products and services must be truthful. All marketing, promotional and advertising materials must be approved by the competent authority of the Company or an entity authorized by the Company through an appropriate approval process before they are published.
16. Import and Export Controls
The Company and the Co-workers must adhere to provisions of law and other applicable regulations when delivering products or services internationally.
Co-workers must be familiar with appropriate provisions of law and procedures for imports and exports, and they must adhere to them. If a Co-worker is involved in international transactions, they must know what steps are required to ensure that the Company complies with the law, in particular, the Co-worker should be familiar with any requirements related to taxes, licensing and appropriate permits.
17. Questions and Reporting a Violation of this Code
In case of any questions or doubts regarding this Code, and in case of uncertainty whether the Co-worker’s complies with this Code, this Co-worker or another Co-worker who has such doubt, shall seek guidance from their supervisor and the P&C Department.
Co-worker must report, in good faith, any actions or events which may be possible violations of this Code, regardless if the action or event turns out to be a violation or not. The Company undertakes not to draw any negative consequences from such notices made in good faith by the Co-worker. The Company will investigate reports respectfully and professionally, as promptly and confidentially as possible. A Co-worker asked to participate in an investigation is obliged to cooperate fully.
Violations of this Code are taken very seriously and may bring about consequences, which can cause the Company to terminate the agreement between the Company and the Co-worker. In cases of particularly egregious or significant breaches of the provisions of this Code of Conduct, the Company shall be entitled to terminate the contract with the Co-worker immediately, without notice
Furthermore, violation of applicable provisions of law may entail disciplinary action.
Appendix No. 1 to the Code of Conduct at Alokai Sp. z o.o.
Anti - Harassment and Anti - Discrimination Policy
at Alokai Sp. z o.o.
Chapter I
§ 1
General principles
1. Alokai Sp. z o.o. is a company that does not tolerate discrimination harassment and workplace bullying. These behaviors are contrary not only to the law, but also to our values. We want to ensure that each Co-worker has the right to perform work or provide services in a professional environment, full of tolerance, respect and equal opportunities.
2. Drawing consequences for the perpetrators of harassment, discrimination and unequal treatment is of fundamental importance to us and is an expression of our opposition to such behavior.
3. The purpose of introducing Anti-Harassment and Anti-Discrimination Policy in the Company is to prevent workplace bullying, harassment, discrimination and unequal treatment, and to establish rules of conduct in case of reporting a suspicion of the occurrence of one of the above mentioned unwanted behaviors.
§ 2
Definitions
The following meanings are hereby adopted for the following capitalized terms, whether used in the singular or plural:
a) Direct Discrimination - a situation in which a person, in particular on the basis of age, sex, race, nationality, sexual orientation, health condition, disability, ethnic origin, religion, creed or lack thereof, political beliefs, family status, lifestyle, scope and basis of employment or other types of cooperation, is treated less favourably than is or was treated by another person in a comparable situation;
b) Indirect Discrimination - a situation where, on one or more of the grounds set out in (a) above, an apparently neutral provision, criterion applied or action taken results in, or could result in, a disadvantageous disparity or a particular disadvantage, unless the provision, criterion or action is objectively justified in view of the legitimate aim to be achieved and the means of achieving that aim are appropriate and necessary;
c) (Anti-Harassment) Committee - Anti-Mobbing and Discrimination Committee established in the Company to review reports of suspected Unwanted Behavior;
d) Workplace Bullying - actions or behaviors concerning an Co-worker or directed against a Co-worker, consisting of persistent and prolonged harassment or intimidation of a Co-worker, causing them to be undervalued in terms of professional usefulness, causing or aimed at degrading or ridiculing a Co-worker, isolating them or eliminating them from the team of the Co-worker. This includes, but is not limited to:
- Harassment and intimidation: repeated offensive comments or threats.
- Degradation and ridicule: actions aimed at humiliating or mocking a Co-worker.
- Isolation: deliberately excluding a Co-worker from team activities.
- Excessive micromanagement: unjustified oversight of a Co-worker’s work.
- Unrealistic deadlines: setting unachievable deadlines.
- Unfair criticism: excessive or unjust criticism.
- Lack of support: deliberately withholding necessary resources or assistance.
- Intentional misleading: providing false or misleading information.
- Insubordination: ignoring directives or authority.
- Insulting behavior: using derogatory language and actions.
- Lying and manipulation: deliberate misinformation or manipulation.
- Unwarranted contact: making systematic and persistent work-related calls or sending messages to Co-workers outside of working hours without valid reason;
e) Sexual Harassment - any Unwanted conduct of a sexual nature or relating to the sex of a person which has the purpose or effect of violating the person's dignity, in particular, creating an intimidating, hostile, degrading, humiliating or derogatory environment towards them; this conduct may consist of physical, verbal or non-verbal interactions;
f) Unwanted Behavior - Any form of Workplace Bullying, Direct Discrimination, Indirect Discrimination, Sexual Harassment or other ‘unsocial’ behavior (aggressive attitudes, rudeness, neglect of responsibilities, or inappropriate actions);
g) Attorney - a person who is an Attorney against workplace bullying, harassment and discrimination appointed by the Management Board;
h) Policy - this Anti-Harassment and Anti-Discrimination Policy of the Company;
i) Supervisor - a person who has managerial authority in the Company's organization and who has the authority to give orders to personnel subordinate to the organizational hierarchy;
j) The Company - Alokai Sp. z o.o. with its registered office in Warsaw;
k) Co-worker - an employee, co-worker, contractor and consultant of the Company who is a natural person;
l) Management Board - the Management Board of the Company;
m) Notice - an application submitted by a Co-worker made in accordance with this Policy.
Chapter II
§ 3
Obligations of the Company
1. The Company is committed to ensuring that the work environment is free of Unwanted Behavior, and reminds Co-workers that it is their primary responsibility to foster correct principles of social intercourse in the work environment and its business environment.
2. All of the Company's decisions regarding hiring, co-op, promotion or salary increases are based on objective evaluations of experience, skills and performance.
3. The Company conducts activities aimed at raising the awareness of its Co-workers on Unwanted Behaviors by, among others:
a) Conducting trainings on anti-bullying and anti-discrimination issues, including information on current anti-discrimination and anti-bullying legislation,
b) Allowing Co-workers to evaluate relationships with Co-workers in the workplace,
c) familiarize each Co-worker with the contents of the Policy prior to beginning work or collaboration.
4. The statement confirming that the Co-worker has reviewed the Policy and commits to adhering to it is stored as an electronic document review confirmation and is kept in the Co-worker’s personnel file.
§ 4
Responsibilities of the Co-worker
1. The use of any of the Unwanted Behavior constitutes a serious breach of basic duties, both on the part of management and those in such roles.
2. The Co-worker is required to:
a) comply with the rules set forth in the Policy,
b) treat each other with kindness, respect, and dignity, demonstrating empathy, offering support, acknowledging contributions, and communicating openly and constructively,
c) not to abuse a privileged professional position, including in the Co-worker-Supervisor relationship. Co-workers must maintain professionalism, be punctual, meet deadlines, and work effectively in teams.
d) avoid conflicts, try to resolve any disagreements in an amicable manner without undue delay and without escalating the problem,
e) Participate in training sessions organized by the Company on anti-bullying and anti-discrimination issues,
f) immediately react and inform the Company of any noticed signs of Unwanted Behavior.
3. All Company executives have a special obligation to carefully observe the behavior of Co-workers and to respond appropriately and in a timely manner to Unwanted Behavior. In addition, their role is to make subordinates aware of the impact they have on those around them.
4. Each and every Co-worker who recognizes an Unwanted Behavior or who notices the Unwanted Behavior towards another Co-worker or the fact of encouraging the Unwanted Behavior is obliged to notify the Attorney in accordance with the procedure described below. In the case of lack of such notification, the Company may take appropriate consequences against such a Co-worker, including termination of the employment or other service agreement between the Co-worker and the Company, with immediate effect.
Chapter III
§ 5
Notice to Attorney
1. Notices of suspected Unwanted Behavior must be reported:
a) in writing to the Attorney's address: ethics@alokai.com ,
b) directly to the supervisor or other representative of Management,
c) or through the Supervisor in writing to the Attorney's address: ethics@alokai.com .
2. The Notice should include:
a) A statement of the facts, including a description of events, if possible including time and place of events, frequency of events, surrounding circumstances,
b) Identify supporting evidence, including the names of persons who can demonstrate that the acts or conduct described in the Notice actually occurred;
c) identifying the person or persons by name who engaged in the Unwanted Behavior and identifying the person harmed by such action.
3. The Notice should be signed with your name.
4. An anonymous Notice may be recognized when its content allows, in particular: the scope of information about Unwanted behaviors and about the perpetrator of these behaviors and the person harmed by the perpetrator's Unwanted Behaviors.
5. Upon receipt of the Notice, the Attorney shall promptly record the Notice.
§ 6
Entitlement of the Company and the Attorney
The Company or the Attorney shall undertake actions indicated in the Policy also in the event of obtaining information on a suspicion of Unwanted Behavior from a source other than the Notice referred to in § 5 of the Policy.
§ 7
Actions of the Attorney
1. Upon receipt of a Notice, the Attorney shall take reasonable steps to investigate the validity of the Notice. In particular, the Attorney may initiate the proceedings referred to in §8 and §9 below.
2. In minor cases, the Commissioner may decide to take action without going before the Commission. In such a case, the Attorney shall hold explanatory or disciplinary talks with the parties concerned. The Attorney shall further take all necessary action to remedy the situation and prevent Unwanted Behavior in the future.
§ 8
Proceedings at the (Anti-Harassment) Committee
1. As a result of the filing of the Notice, if warranted by the contents of the Notice, the Committee shall, within not more than 14 business days after receipt of the Notice, convene a meeting.
2. The Committee's role is to objectively and fairly review the Notice and determine whether the Unwanted Behavior described in the Notice occurred.
3. The Committee consists of:
a) Attorney as Chairman of the Commission,
b) The Director of HR or his/her authorized designee,
c) an impartial Co-worker appointed by the Board,
d) other persons, including independent experts (e.g., legal counsel, psychologist), if their appointment by the Board of Directors is deemed necessary by the Chair of the Committee.
3. No member of the Committee shall be a person who has filed a Notice, a person whose conduct is the subject of proceedings before the Commission, or a person who is reasonably believed not to be impartial in the matter.
4. The members of the Committee shall act in accordance with the principles of confidentiality, impartiality, fairness, with the aim of comprehensively explaining the case and solving the problem.
§ 9
Work of the Committee
1. The Anti-Harassment Committee shall commence proceedings without undue delay and no later than 14 days after the first meeting.
2. The Committee shall endeavor to consider the Notice within a period not exceeding 30 days. The Committee may extend the proceedings in particularly justified cases.
3. The proceedings before the Committee, including evidence and facts established in the course of such proceedings, constitute Confidential Information. Proceedings before the Committee shall be conducted with respect for the rights and with particular care for the protection of participants in the proceedings.
4. At the request of the Committee, the Company must make available to the Committee required documents and provide all necessary information to establish the circumstances of the case.
5. The parties to the proceeding (i.e., the person who filed the Notice, the person alleged to have engaged in unwanted conduct, and the aggrieved person) have an equal right to be heard by the Committee.
6. After hearing the parties to the proceeding and other persons called as witnesses, the Committee shall decide on the merits of the Notice.
7. A report shall be drawn up on the work of the Committee and signed by all members of the Committee. The report shall include: a description of the facts, the evidence carried out, the Committee's decision together with the reasons for its position, the proposed remedial and corrective measures for the identified violations.
8. The report will be provided to the Management Board immediately.
9. The Committee shall acquaint the parties to the proceeding with the conclusions and recommendations of the report.
§ 10
Activities of the Management Board
1. On the basis of the Anti-Harassment Committee's report, the Management Board takes actions aiming at eliminating identified irregularities and prevents their recurrence, following the principle of proportionality to the occurring violation of the Policy's provisions and the law.
2. If the Notice is found to have merit, the Board may:
a) with reference to an employee, with whom the Company is bound by the employment contract - apply the legal measures of disciplinary character provided by the law with reference to the perpetrator of the Unwanted Behavior, in particular, order penalties, termination of employment and remuneration conditions, termination of employment;
b) in relation to Co-workers with whom the Company is bound by a cooperation agreement - the Management Board may immediately terminate cooperation with such a person,
c) refer the perpetrator to training on preventing Unwanted Behavior or disparate treatment,
d) transfer the aggrieved Co-worker, at the Co-worker's request or with the Co-worker's consent, to another position appropriate to the Co-worker's qualifications, which will prevent direct contact between the aggrieved Co-worker and the perpetrator of the Unwanted Behavior;
e) deprive the perpetrator of rights under labor laws that are contingent on not violating employee obligations, such as bonuses or awards.
3. The Board shall be entitled to apply the measures referred to in paragraph 2 above also to persons who intentionally slander the commission of Unwanted Behavior.
Chapter IV
§ 11
Confidentiality
1. Proceedings triggered by the filing of a Notice are confidential and will not be disclosed to other Co-workers or third parties except as necessary to investigate and conduct proceedings in connection with the Notice or as required by law.
2. All persons participating in the proceedings caused by the Notice, are obliged to maintain secrecy of all the facts and circumstances, with which they became acquainted in the course of the proceedings. Violation of this rule shall constitute a violation of the obligations of an employee or arising from the cooperation agreement with the Co-worker and may result in liability for disciplinary action or termination of the employment relationship or cooperation agreement with immediate effect.
3. The contents of the documentation of the proceedings are confidential. It can be viewed by the Attorney, members of the Committee, the Management Board and, if necessary, persons additionally authorized by the Management Board.
4. Members of the Committee, Parties to the proceeding and persons who are witnesses in the case are required to submit a written statement of confidentiality of everything they learn in the course of the proceeding. A template of the declaration is attached as Appendix No. 1 to this Policy.
Chapter V
§ 12
Final provisions
1. The exercise of the rights set forth in the Policy, in particular the filing of a Notice, shall not be a basis for adverse treatment and shall not result in adverse consequences, in particular it shall not constitute a reason justifying termination of employment by the Company.
2. The policy is effective as of June 01, 2022.
Appendix No. 1
ANTI-HARASSMENT PARTICIPANT CONFIDENTIALITY STATEMENT
I the undersigned
.................................................................
(name of Participant)
I hereby certify that as a Member of the Committee/Party to the Proceeding/Witness/other character of Participant: [NAME] in a case from a report of Unwanted Behavior (within the meaning of the Anti-Harassment and Anti-Discrimination Policy at Alokai Sp. z o.o.) Mr./Ms. [NAME] submitted to the company Alokai Sp. z o. o. with its registered office in Warsaw and examined by the appointed Anti-Harassment Commission, I oblige myself - both during my testimony and after the Anti-Harassment Commission has examined the complaint - to keep it secret and not to disclose to third parties any information possessed in this matter.
on date …………………………………….
…………………………………………………..
(legible signature of the Participant)