DECLARATION OF ETHICS

Ethics is a multifaceted and valuable subject for our Company. We are a team of highly qualified specialists in the field of chemical system solutions for the pulp and paper industry, the recycling of secondary raw materials and use of paper and board for further processing. Practical knowledge of paper production technology and experience backed by a track record of success are our guarantee of creating projects of the highest standard.

In our daily operations, we are committed to demonstrating conduct that complies with applicable regulations, norms and standards; conduct that is honest, reliable and transparent. We strive for ethical values to be an integral part of our Company’s strategy and operations.

Economic, social and environmental factors are important in our Company’s operations. We are aware of how the activities of TSC sp. z o.o. affect the environment. Therefore, we care for the environment and proper relations with our surroundings. We implement the concept of Corporate Social Responsibility (CSR). We place great emphasis on the quality of our products and processes we carry out, while simultaneously reducing negative impact on the natural environment. We are constantly seeking the most suitable products and services, paying attention to the environmental and social dimensions of our activities. The chemical agents we offer meet the highest quality norms and standards of the European Union and the Eurasian Economic Union. Many of our products hold certifications such as ISEGA, Blue Angel, Eco Label, Nordic Swan and comply with FDA and BfR (Recommendation XXXVI) standards. All products have a safety data sheet compliant with REACH regulations and are labelled in accordance with the CLP regulation. The production of the agents we offer is carried out in accordance with ISO standards.

We strive for our Employees to recognise our values as paramount and for the success of our Company to be our collective achievement. The positive image of TSC sp. z o.o. has been our hallmark for years. As the Management Board, we are aware that the success of our Company is determined by the satisfaction of our Team and our Customers. We hereby present our Code of Values and Ethics, expecting that our Employees, Customers and Contractors – together with us, the Management Board – will be responsible for adhering to the provisions of the Code.

Management Board of TSC sp. z o.o.

OUR PRINCIPLE: COMPLIANCE WITH THE LAW

OUR COMMITMENTS

We conduct our operations in accordance with applicable laws and regulations concerning environmental protection. We operate on the basis of a permit for the collection and transport of non-hazardous waste. Since 2015, our Company has undergone regular recycler audits (EMAS) and inspections conducted by the Marshal’s Office, the results of which confirm the reliability of our environmental documentation. We issue documents such as KPO (Waste Transfer Note), EDPR (Recycling Confirmation Export Document), DPR/DPO (Recycling Confirmation Document/Recovery Confirmation Document). BDO (Waste Database) Number: 000013145.

QUALITY STANDARDS

The chemical agents offered by TSC sp. z o.o. meet the highest quality norms and standards of the European Union and the Eurasian Economic Union. Many of our products hold certifications such as ISEGA, Blue Angel, Eco Label, Nordic Swan and comply with FDA and BfR (Recommendation XXXVI) standards. All products have a safety data sheet compliant with REACH regulations and are labelled in accordance with the CLP regulation. The production of the agents we offer is carried out in accordance with ISO standards.

OUR OBJECTIVES

  • Ensuring compliance with legal regulations within our Company.
  • Conducting business in accordance with national and international law, and in particular with the standards of the European Union and the Eurasian Economic Union.
  • Undertaking activities based on current and valid permits and licences.
  • Subjecting the operations of TSC sp. z o.o. to audits and inspections.
  • Drafting contracts with Customers and Contractors in compliance with applicable legal regulations.
  • Creating rules and regulations for work, remuneration, remote work and sobriety testing in a manner that is transparent and understandable to Employees.
  • Familiarising Employees with commonly applicable labour law regulations and internal documents in force at TSC sp. z o.o.
  • Familiarising Employees with the scope of responsibilities in their respective positions.

PROBLEM REPORTING AND RESOLUTION PROCEDURE

We encourage our Employees, Customers and Contractors to report any incidents of legal violations at TSC sp. z o.o. All reports are treated confidentially and whistleblowers will not be subject to retaliation.

OUR PRINCIPLES: HONESTY, INTEGRITY, RESPONSIBILITY, SAFETY

OUR PRINCIPLES

Our Company is guided by the following ethical values:

  • Honesty: We adhere to fair competition and avoid potential conflicts of interest.
  • Integrity: In business relations, we do not accept any manifestations of corruption, abuse of power or obtaining tangible and intangible benefits.
  • Responsibility: We are aware that the quality of our products and the processes we carry out should be of the highest standard and we should take actions to reduce negative impacts on the natural environment.
  • Safety: Our products and services are of the highest level; we ensure compliance with the quality norms and standards of the European Union and the Eurasian Economic Union.
  • Professionalism: We begin the cooperation process by selecting a product according to the Customer’s expectations; then, through consultancy, technological implementation, regular technical service and training of the Customer’s employees, we strive for continuous optimisation of production stages.
  • Apolitical Stance: We do not engage in political activity, we do not support political parties, and we do not transfer Company funds for political campaigns.
  • We implement the concept of Corporate Social Responsibility (CSR).

OUR ACTIONS

  • Fulfilling reporting obligations.
  • Maintaining the Company’s financial records in an accurate, error-free, verifiable and up-to-date manner.
  • Accurately documenting all transactions and archiving documents in forms and for periods compliant with legal regulations.
  • Production of chemical agents in accordance with ISO standards.
  • Issuing quality certificates to Customers.
  • Offering our Customers technical service provided by a qualified team of experts with over twenty years of experience in the paper industry.
  • Imparting knowledge and skills to Employees and requiring Employees to adhere to the aforementioned principles, particularly the principles of honesty and integrity.

PROBLEM REPORTING AND RESOLUTION PROCEDURE

We encourage Employees, Customers and Contractors to report any incidents of violation of the above principles. All reports are treated confidentially and whistleblowers will not be subject to retaliation. We value the loyalty of our Employees to our Company and the respect and recognition of our Customers and Contractors.

OUR PRINCIPLE: EQUALITY

OUR COMMITMENTS

Our Company is committed to promoting equal opportunities and diversity in the workplace. Our equality policy aims to create an environment where all Employees feel respected, valued and have equal opportunities for professional development, regardless of their gender, race, age, sexual orientation, disability, religion, nationality or any other personal characteristics. The principle of equal opportunities for women and men is permanently embedded in the operations and management of our Company – internal standards at TSC sp. z o.o. guarantee equal treatment in employment and non-discrimination of Employees in any way, directly or indirectly, including on the basis of gender.

OUR OBJECTIVES

  • Ensuring that all recruitment, employment, promotion and remuneration processes are transparent and based on objective criteria.
  • Creating a work environment that promotes diversity and inclusivity.
    Providing appropriate conditions for individuals who care for dependants (including flexible working hours, carer’s leave).
  • Educating Employees about equality and diversity and the importance of these values in our organisation.
  • Addressing all forms of discrimination, mobbing and harassment in the workplace.

EQUALITY PRINCIPLES

  • Equal opportunities: All Employees and candidates are treated fairly and impartially at every stage of employment.
  • Diversity: We employ individuals with diverse experiences, skills and perspectives to enrich our organisational culture.
  • Support for Employees: We offer support to Employees in need of assistance, including mentoring programmes and training.

PROBLEM REPORTING AND RESOLUTION PROCEDURE

We encourage Employees to report any incidents of discrimination or mobbing. They will be treated seriously and resolved in accordance with applicable procedures. All reports are treated confidentially and whistleblowers will not be subject to retaliation.

MAINTAINING EQUALITY

We regularly monitor and evaluate our equality policy and implement changes in response to Employee needs and changing market conditions. We organise periodic training for Employees and management staff to increase their awareness of equality, diversity and inclusivity.

SUMMARY

By adopting the equality policy, our Company is committed to creating and maintaining a respectful work environment that promotes diversity and counteracts all forms of discrimination. All Employees are obliged to follow these principles and actively support the equality policy in our organisation.

OUR PRINCIPLE: CONFIDENTIALITY

OUR COMMITMENTS

Our Company, as an international leader in chemical services for the paper industry promoting modern technologies and optimal solutions, is particularly obliged to protect trade secrets. By trade secrets we understand technical, technological and organisational information of the enterprise or other information of economic value which, as a whole or in a specific combination and collection of its elements, is not generally known to persons usually dealing with this type of information or is not easily accessible to such persons, provided that the person authorised to use or dispose of the information has, with due diligence, taken steps to keep it confidential.

MAINTAINING CONFIDENTIALITY

  • In cooperation with Customers, we ensure confidentiality by creating appropriate contractual provisions.

We do not transmit confidential information to Contractors by electronic mail without adequately securing the transmitted information.

  • We train Employees in the safe use of electronic means of communication. Specifically, we emphasise the obligation to create strong passwords, treat messages from unknown senders with caution and secure transmitted documents.
  • We have created Remote Work Rules and Regulations defining the rules for communication between the Employer and Employees working remotely and specifying the safe use of work materials and tools. As part of the Remote Work Rules and Regulations, we have established a transparent procedure for personal data protection during remote work.
  • The principle of confidentiality applies to Employees during their employment, but we also strive to maintain the confidentiality of information after termination of employment.

PROBLEM REPORTING AND RESOLUTION PROCEDURE

We encourage Employees to report any incidents of confidentiality and trade secret breaches. All reports are treated confidentially and whistleblowers will not be subject to retaliation.

OUR PRINCIPLE: EDUCATION AND INTEGRATION

OUR COMMITMENTS

We are aware that our primary goal should be to care for the natural environment. When seeking appropriate products or services, we pay attention to the environmental and social dimensions of our activities. Employees in each of our departments uphold our values:

  • The Chemicals Department applies the latest product and technological solutions. It ensures the continuity of paper machine operation and high quality of the end result, i.e. the finished product. Sets of chemicals are selected completely on a case-by-case basis, making them expertly conceived and effective. Our Company offers constant supervision of the production process and technical service.
  • The Recycling Department specialises in sourcing, sorting and securing supplies of raw material for manufacture of paper products. Our enterprise carries out wastepaper recycling, while also enabling third-party recipients to purchase the raw material for processing.
  • The Paper and Board Department specialises in production and sales.

We share our knowledge and experience in both the industry and community environments, not only locally but also internationally. We hope that the skills we have acquired over the years will contribute to the development of chemical services in the paper industry. We are proud that, as an international leader in our field of services, we can present our Customers with state-of-the-art technologies and optimal solutions. Our Employees offer a wide range of services and we trust they will actively participate in continuous improvement of our products, services and processes by sharing their expertise and experience.

OUR OBJECTIVES

  • We organise specialised training courses and workshops.
  • We share knowledge about products, their application and origin.

We provide technical support during production processes.

  • We build long-term and mutually satisfying cooperative relationships.
  • As part of integrating the paper industry community, we propose participation in sporting events such as marathon running, sailing and golfing.

EDUCATING CUSTOMERS’ EMPLOYEES

We initiate the process of cooperation with a Customer by selecting the suitable product. Subsequently, through consultancy, technological implementation, regular technical service and training of the Customer’s employees, we strive for continuous optimisation of production stages. Training of the Customer’s employees by our specialised Employees constitutes an important stage of our business cooperation.

EMPLOYEE EDUCATION

We recognise that our Company’s success is driven by qualified Employees. Therefore, we encourage our Employees to pursue self-development in the field of chemical system solutions for the pulp and paper industry. To this end, we provide specialised, modern and unique training for Employees, particularly in onboarding to the paper production technology process, production of chemicals and acquisition of skills in implementing optimal systems tailored to the specific conditions of our Customers’ paper machines.

Our Company especially fosters Employee development in the following areas:

  • occupational health and safety,
  • information security and personal data protection, including rules of personal data processing,
  • trade secret confidentiality,
  • anti-corruption,
  • counteracting mobbing and discrimination,
  • IT security.

PROCEDURE FOR ENGAGEMENT IN EDUCATION

We encourage our Employees to engage in training courses and workshops, both as participants and as speakers sharing their expertise and experience.

OUR PRINCIPLE: HELPING OTHERS

OUR COMMITMENTS

We utilise our capabilities to support social projects and initiatives whose values resonate with ours. Our Company supports numerous charitable foundations and social institutions. We aim to engage Employees in these actions by communicating core values such as respect for beneficiaries of our actions and their rights, traditions and environment.

OUR OBJECTIVES

  • We support educational programmes for children and youth.
  • We participate in charitable campaigns aiding children, particularly those at risk of social exclusion, as well as senior citizens and veterans.
  • We foster an attitude of openness to helping others among our Employees, Customers and in the broader community.
  • We support the activities of entities and institutions whose mission is to help those in need.
  • We undertake cultural activities, such as building a contemporary art collection.

OUR ACHIEVEMENTS

  • Charitable support for children from the ‘Jaś’ and ‘Małgosia’ Children’s Homes on the occasion of Christmas.
  • Support for the Museum of Warsaw Foundation.
  • Support for activities of the Association of Polish Volunteer Fire Brigades (ZOSP RP) in the Mazovian Province.
  • Support for the Make a Change Foundation in the ‘Follow your dreams and Make a Change’ programme.
  • Sponsorship of meet-the-author events in Lutsk, Ukraine, accompanying the ‘Poland and Poles at the Turn of the Centuries’ exhibition.
  • Support for ZASP – Union of Polish Stage, Film, Radio and Television Artists – in financing the Home for Veteran Polish Stage Artists in Skolimów.
  • Financial support for the Siemacha Association for educational trips of the Association’s Charges to Africa.
  • Funding prizes for laureates of the ‘Young Leader of District Ecology’ competition.

PROCEDURE FOR REPORTING SOCIAL PROJECTS AND INITIATIVES

Employees are encouraged to propose social projects and initiatives. Each submission is individually assessed for feasibility and the scope of our Company’s assistance.

THE CODE OF ETHICS IN PRACTICE

  1. The Code of Ethics applies to all Employees of TSC sp. z o.o., its Customers, Contractors and other associates. We expect our Employees to act in accordance with legal regulations and ethical principles.
  2. Employees are acquainted with labour laws and their responsibilities to:

a. adhere to working hours established at TSC sp. z o.o.,

b. follow the work rules and regulations and established workplace order,

c. comply with occupational health and safety laws and rules as well as fire protection regulations,

d. respect principles of social coexistence applicable in our Company,

e. protect the welfare of TSC sp. z o.o. and its property, and maintain confidentiality of information that could harm the Employer if disclosed,

f. observe trade secret confidentiality.

  1. Employees are obliged to perform their work diligently and carefully and to follow the instructions of their superiors. Failure to comply with employee duties, including unethical conduct, may result in the Employer applying disciplinary measures, up to and including termination of employment.
  2. Employees are encouraged to report:

a. suggestions for solutions that could positively influence the workplace atmosphere in the Company,

b. areas where special attention of the Employer is required,

c. needs and forms of professional development,

d. social projects and initiatives that require the support of TSC sp. z o.o.,

e. activities suspected of being unethical, irregular or illegal,

f. any questions or concerns they wish to direct to our Company regarding the content of the Code of Ethics and the activities and daily operations of TSC sp. z o.o. Reports and enquiries should be made by:

i. notifying the immediate superior,

ii. notifying the person responsible for the matter,,

iii. contacting the HR department,

iv. contacting a member of the Management Board of TSC sp. z o.o.,

v. sending a report to etyka@tsc.com.pl.

We ensure that every report will be investigated by our Company in a manner that ensures optimal protection for the whistleblower and the Employees mentioned in the report. No one will suffer negative consequences unless and until the circumstances of the reported incident are confirmed.

Warsaw, 16.09.2024

The Management Board of TSC sp. z o.o.