GAMBIT GROUP CODE OF CONDUCT

INTRODUCTION 
 
We are a Polish manufacturer of compressed fibre sheet and gaskets and we’ve been active on the market since 1962. The company's mission is to produce and sell high quality, environmentally friendly sealing and thermal insulation products to the domestic and foreign markets. 

We wish to create seals which are safe for the user as well as for the environment, which is why we design them in accordance with the principles of sustainable development. We also ensure that all our business operations comply with laws and regulations and are carried out with due regard to their impact on communities.
This Code of Conduct has been prepared not only to certify our values, but also to provide clear and explicit guidance to all those who work with us on what is expected of them in the course of the collaboration. It contains a set of principles that reflect our practices and focuses on four main areas, representing general, business social and environmental expectations.

This document is addressed to employees and associates of The Gambit Group (hereinafter GAMBIT) and all entities that are or will be associated with GAMBIT in a legal or factual relationship, namely: customers, suppliers, service providers, capital providers or others, collectively referred to as Partners.

1.    PRINCIPLES OF BUSINESS CONDUCT
 
We are committed to full compliance with all national and international laws and regulations.
We also expect our Partners to fully comply with all applicable laws and regulations as well as to act with integrity, transparency and in accordance with generally accepted ethical principles.

The nature of the obligations and standards in relation to ethics and business values that we at GAMBIT implement as well as expect from our Partners is as follows: 
 
•    countering money laundering and terrorist financing;
•    avoiding situations that could be construed as a conflict of interest or that could pose a reputational risk; 
•    not accepting or offering any tangible or intangible benefits that may be considered as corrupt activities; 
•    copyright protection;
•    fostering a safe working environment and protecting the environment; 
•    promoting an organisational culture in which all employees recognise and value ethical behaviour and are role models for such behaviour; 
•    refraining from any action deemed to be unfair competition as well as ensuring compliance with legal standards for the protection of competition rules. 

2.    EMPLOYEE RELATIONS AND SOCIAL INVOLVEMENT
 
GAMBIT employees should treat each other with mutual respect. This implies treating people equally, acting transparently, valuing people for what they do and who they are, regardless of their position, seniority, age, gender, disability, health status, family status, ethnicity and gender identity, orientation, beliefs or nationality. The fundamental principle of respect is to ensure the dignity of the individual person. 
 
GAMBIT does not tolerate behaviour that may fall under the signs of discrimination or harassment of employees, in particular: 
•    unacceptable verbal communication (e.g. offensive language); 
•    disruption of the working environment (e.g. isolation of employees); 
•    psychological manipulation (e.g. unjustified blaming and/or criticism, especially in public, disregarding the opinions of others); 
•    violent behaviour of any kind; 
 
GAMBIT does not allow minors to work. Moreover, GAMBIT makes every effort to ensure that its subcontractors do not use children for labour or use any products or services derived from the labour of minors in their business activities, while taking care to comply with the International Labour Organisation's regulations relating to the work of minors. 
 
GAMBIT does not use forced, slave or otherwise coerced labour. It also strongly opposes illegal employment, while simultaneously promoting diversity in the working environment. 
 
GAMBIT shows the utmost concern for the health and safety of its employees and co-workers and complies with applicable standards and laws in this regard, in particular:
a)    implements safe working techniques; 
b)    ensures continuous training and development of the skills of workers and co-workers in order to avoid situations that put their health or lives at risk;
c)    prevents accidents at work and occupational diseases; 
d)    minimises workplace hazards; 

We are well aware that our presence requires responsibility towards the local communities in the environment in which we operate, which is why we encourage all employees to participate in social programmes that promote the common good.
We support initiatives that are in line with the GAMBIT global social responsibility programme.

3.    ENVIRONMENT

GAMBIT strictly complies with environmental regulations, we have up-to-date permits for: emissions, waste, water management. We conduct our operations in such a way as to minimise the risk of air, soil, surface and underground water contamination. 

In our operations, we strive to optimise and monitor the following:
a)    atmospheric emissions, including greenhouse gas emissions;
b)    the consumption of energy, water, fuels and other resources;
c)    the generation of waste, including non-recyclable waste;

We strive to eliminate, to the largest extent possible, any negative impact on the environment; therefore we only use materials from legal sources and in the production process we try to use as much as possible of the waste we generate ourselves

4.    FINAL PROVISIONS 

We recommend that Partners adhere to and promote the principles outlined in this document throughout their value chain. In the event of non-compliance with this Code of Conduct, corrective action must be taken immediately to rectify the non-compliance and appropriate measures must be taken to avoid similar problems in the future.
Please report any violations of this Code of Conduct to the following email address: gambit@gambitgl.pl 
 
The GAMBIT Management Board is responsible for reviewing and updating the content of this Code of Conduct.