Compliance program - Winning Steel

The Winning Group is aware that consistent compliance with the legal, moral and ethical principles is conducive to development and a promising future. The Winning Group’s management is committed to continuously reinforcing the corporate culture and ethics based on compliance with the rules

The core documents of this system are the Code of Ethics, Code of Ethics for Contractors and the Whistleblower Protection Rules, which reflect the values and rules of the Winning Group. These are respected by our employees and we would like our contractors to respect them as well.

Any suspected illegal or unethical conduct can be reported to our compliance contacts, either by email or by phone

CODE OF ETHICS

Introduction

The Winning Group a.s. and its subsidiaries (hereinafter referred to as the “Winning Group”) constitute a business group of legal entities (concern) operating in the construction, automotive and service industries pursuant to § 79 of Act No. 90/2012 Coll., on Commercial Companies and Cooperatives (Act on Commercial Corporations). The Winning Group believes that ethical and economic values are intertwined and therefore rejects any action that is not in accordance with the law or moral and ethical standards. The Winning Group requires all employees in the various companies in the Group to comply with laws and ethical rules and to perform their duties properly. The Winning Group therefore adopts this Code of Ethics, which sets out the rules of conduct and behavior for all employees regardless of their job title, status or contract duration. The Code is based on the principles of fairness, tolerance, responsibility, respect for rights and human dignity. The managers are role models of moral and ethical qualities for other employees. They are responsible for ensuring that their subordinates adhere to the Code of Ethics.
The values set out in this Code form an integral part of our corporate culture and business strategy. Failure to comply with the provisions of this Code will be considered a breach of work discipline in accordance with the Labor Code.

Text of the Code of Ethics

Health and Safety

Protecting occupational health and safety is one of our priorities. We are working towards preventing injuries. We responsibly and regularly train all employees in occupational health and safety. We constantly strive to create a work environment that promotes safety, health and mental well-being.

Respecting Human Rights

We strive to respect and protect human rights. We respect human dignity. We do not tolerate any form of child labor, the age of any of our employees must not be less than 15 years. We recognize the special needs of employees under the age of 18. We only provide employees with working hours that fully comply with statutory regulations.

Non-discrimination and Equal Opportunities

We do not discriminate, we treat everyone equally and offer equal opportunities to all regardless of nationality, ethnicity, age, gender, appearance, faith, disability, marital status or sexual orientation. This corporate equal opportunities policy covers all aspects of the employment relationship.

Workplace Relations

The Company is committed to creating an environment where employees are treated with dignity and respect. Every employee is obliged to respect their colleagues. At the same time, we require recognition of the views of others, even if they may not be the same as the individual’s. We work as a team, sharing our experience and knowledge. We seek open and direct communication. We are friendly and respectful to each other. We do not tolerate any form of bullying or disrespectful behavior. We build relationships based on trust.

Cooperation and Conflict Resolution

When performing tasks and in dealings with our colleagues, we do not disparage our colleagues, misrepresent or conceal information necessary to complete a task, or prioritize our own interests or those of a third party over those of the Company. We do not refuse necessary assistance to other colleagues in the performance of work tasks without good reason. When a labor dispute arises between employees, we actively, constructively and responsibly seek a solution to such a dispute, taking into account the interests of the Company, and in the event of failure to reach a consensus, we immediately inform superiors.

Personal Development

We believe in our employees, value them and support their talents and development. We want to do our best for their development, professional growth and increased potential. We fund a wide range of training courses for our employees in various professions.

Protection of the Company’s Reputation

We act and conduct ourselves with the knowledge that we represent the Company at all times, even in our off-duty activities. We avoid conduct, behavior or statements that may damage or disparage the Company’s reputation. We do not slander the Company or our colleagues. We do not disclose information that may harm the Company from a business, professional or marketing perspective.

Privacy Policy

We process personal data in accordance with Directive No. 2016/679 of the European Parliament and of the Council (EU) of 27 April 2016 (General Data Protection Regulation – GDPR) and the Czech Data Protection Adaptation Act. We protect all personal data and do not disclose it to anyone else without reason. We make sure that it is kept only for as long as necessary. We provide access to personal data only to authorized persons.

Confidentiality

We do not share confidential information such as know-how, trade secrets, business plans, projects, etc. with anyone. This applies not only to information that our companies have an interest in keeping confidential, but also to our customers and business partners.

Keeping Records

We support transparent business. Our financial reports and all records reflect the actual state of affairs. We record financial transactions so that they comply with the Law and accounting principles. We also keep consistent records relating to health and safety, environment, human resources and training.

Compliance with Competition Rules

We condemn all illegal practices that would restrict or exclude competition. We do not tolerate agreements or mergers between competitors, unfair competition and abuse of dominant market positions.

Corruption

We reject corruption in any form. These include for example bribery, embezzlement, fraud, nepotism or conflict of interest. We expect our business partners to conduct their business in accordance with applicable laws and to finance their business activities with legally obtained funds. The Winning Group has a Code Of Ethics For Contractors

Conflict of Interest

We make decisions without regard to our personal gain and benefit. We avoid situations in which our personal or financial interests conflict with those of individual Winning Group companies.

Group Assets

The assets of the Winning Group are tangible assets (real estate, machinery, cars, money, raw materials, computers, telephones, office equipment, etc.) and intangible assets (know-how, trade secrets, our brand, etc.). We always protect assets from damage, loss, theft or misuse. We never use assets for personal gain, e.g. for business purposes.

Relations with Business Partners and Customers

We value our business partners and customers. We try to understand them, build long-term relationships with them, treat them fairly and with respect, and address their problems. We take their comments into account, which could lead to improvements in the quality of products and services. Every business meeting is conducted in an unconditionally friendly and courteous manner, within the bounds of decorum, never from a position of strength. We always convey correct, relevant information. We do not promise the impossible, we do not lie. What we promise, we deliver. We make sure that our contractors also understand our moral standards contained in this Code.

Gifts and Corporate Hospitality

Gifts and corporate hospitality cannot influence or appear to influence our business decisions or those of our business partners. They must not put the recipient in the position of feeling beholden to the donor. Only low-denomination items, such as corporate promotional items, are acceptable as gifts. Other gifts are unacceptable and must be tactfully refused if necessary.

Sponsoring

The Winning Group supports and may support with funds and in-kind donations activities and beneficiaries in the cultural, social, health, science, research, education and training, ecology, humanitarian, charitable, political, sports, physical education and many other areas.

Environment

We are fully aware of the environmental impact of our business activities. We take a responsible approach to environmental protection in the form of a certified environmental management system. We always consider the risks that our projects could have on the environment. We encourage ecological thinking among our employees.

Whistleblowing

If you suspect that conduct has occurred that is not in accordance with legal, ethical and internal policies, you may report it to the contact points listed below. The Whistleblower’s information will be treated as confidential and no form of retaliation or revenge for reporting illegal or unethical behavior will be tolerated. The identity of the Whistleblower will at all times be known only to a predefined small circle of persons under the conditions set out in the Whistleblower Protection Rules.

The report should contain specific information, such as the names of the persons involved, witnesses and other relevant information. While direct reporting of unethical and fraudulent behavior is preferred, it can also be done anonymously. However, an anonymous report may make it difficult or impossible to properly investigate the whole matter and take proper action. All reports will be treated as confidential.

It is not permitted to abuse this procedure to make false reports. Such behavior will not be tolerated and, depending on the severity of such false reporting, may be referred to law enforcement authorities for further investigation. The sender of the non-anonymous report will be informed of the findings of the investigation once it has been completed.

For all whistleblowers who make their notifications in good faith, the Winning Group provides protection from potential negative consequences.

Contact for reporting:

e-mail: kodex@be-winning.com
ethics line: +420 775 263 847

CODE OF ETHICS FOR CONTRACTORS

Introduction

In view of the above, the Winning Group adopts a Code of Ethics for Contractors. We expect our partners to respect laws, regulations and regulations and to recognize their social responsibility towards their own company, their employees, all business partners, society and the environment. We trust that all our suppliers will adhere to these principles in their day-to-day business practices and that they will ensure that their subcontractors do the same.

Text of the Code of Ethics for Contractors

Conduct on the Market

The Contractor complies with competition law, anti-corruption law and the principles of fair business practices. Shall not engage in contract rigging or any form of cartel practices with their competitors. Records all financial transactions and maintains true and fair accounts that comply with accounting principles.

Relationships with Winning Group employees

The Contractor may not offer, promise or give money or other personal benefits to Winning Group employees in return for preferential treatment in business dealings. Similarly, business partners may not offer valuable gifts or other non-standard incentives. The partner must ensure that their employees do not offer or accept any such benefits. Employees of the Winning Group must not accept any personal gifts or benefits which by their nature are likely to influence business decisions within the Winning Group and therefore the Contractor must not offer any such non-standard benefits.

Relationships with the Contractor’s Employees

The Contractor shall ensure that working hours are observed and that wages are paid regularly and properly. The Contractor shall offer equal opportunities regardless of nationality, ethnicity, age, gender, appearance, faith, disability, marital status or sexual orientation. All employees shall be treated with dignity and respect, and no psychological or physical pressure shall be tolerated. Does not employ persons under the age of 15 and recognizes the special needs of employees under the age of 18.

Health Protection

The Contractor warrants occupational safety and health protection. Every effort shall be made to avoid injuries. They regularly and responsibly train their employees with regard to occupational health and safety. They strive to continuously improve the work environment to promote safety and health.

Environmental Protection

The Contractor complies with applicable legislation and environmental management system standards. The Contractor shall seek to minimize the burden on the environment and shall always consider the risks that their projects may have in this area. They encourage ecological thinking among our employees.

Privacy Policy

The Contractor processes personal data in accordance with Directive No. 2016/679 of the European Parliament and of the Council (EU) of 27 April 2016 (General Data Protection Regulation – GDPR) and the Czech Data Protection Adaptation Act. They protect personal data, store it securely and do not disclose it to anyone else without reason.

Trade Secrets and Confidential Information

The Contractor shall ensure the protection of the Winning Group’s confidential information, regardless of whether this information originates from the Winning Group, its customers or anyone else.

Whistleblowing

Suspected crimes or violations of the principles and obligations contained in this Code may be reported by the Contractor and its employees by email or telephone.

For all whistleblowers who make their notifications in good faith, the Winning Group provides protection from potential negative consequences.

Contact for reporting:

e-mail: kodex@be-winning.com
ethics line: +420 775 263 847

WHISTLEBLOWER PROTECTION RULES

Report

Any person, as a Whistleblower, may submit a report containing information about a possible violation of internal regulations of the Winning Group, a criminal offence or misdemeanor, or a violation of European Union law of which the Whistleblower has become aware in connection with an activity related to the Winning Group.

The report should contain specific information, such as the names of the persons involved, witnesses and other relevant information.

The Winning Group has set up an internal reporting system, according to the rules of which individual reports are reviewed by an authorized person.

Procedure after Making a Report

The Whistleblower shall be informed in writing of the receipt of the report within 7 days from the date of receipt, unless the Whistleblower requests not to be informed of the receipt or the information would reveal the identity of the Whistleblower.

The report will be screened through the Winning Group’s internal process and the results of the screening will be communicated to the Whistleblower within 30 days of receipt of the report, whereas in the case of a report that may have a material impact on the Winning Group, the 30-day period may be extended up to two times, each time for a maximum of 30 days. The Whistleblower will be informed of the extension and the reasons for it.

If the report is found to be justified, the Winning Group or the relevant Group company will take action to remedy the infringement. The Whistleblower will be informed of the adopted remedy without undue delay.

If the report is found to be unjustified, they shall inform the Whistleblower without undue delay and inform the Whistleblower of their right to file a report with a public authority.

Authorized Person

The person authorized to investigate the notification is JUDr. Martin Drahotský, attorney at law, reg. no. ČAK 15924, which ensures the independence of the investigation of the report and the protection of the Whistleblower.

Whistleblower Protection

The Winning Group will not retaliate against the Whistleblower and other persons whose protection is guaranteed by law in connection with the report, nor will any information about such persons be retained unless the persons concerned provide their consent.

The Winning Group highly values Whistleblowers and individuals who, through their reporting and cooperation, help to expose and eliminate any wrongdoing.

Procedure of Making a Report

Reports can also be made anonymously through the internal reporting system, orally or by contacting the contacts listed below: