This Code of Conduct explains STX Next position on general compliance areas, especially:
- Anti-corruption and Ethics,
- Labour Standards and Human Rights, and
- Environment.
This Code of Conduct applies to everyone at STX Next – all persons working for or cooperating with STX Next or on STX Next behalf in any capacity. It includes employees1 at all levels, in particular, but not limited to, managers, executive officers, and members of the management board (board of directors) and supervisory board. Everyone is expected to follow this Code of Conduct.
Managers have special responsibility to establish a work/cooperation environment where ethical behavior is encouraged and rewarded. Employees should understand that every instruction that is given or goal that is set by their supervisor/coordinator is done in the context of this Code of Conduct.
As part of the corporate compliance program and in line with the principles articulated in this Code of Conduct, STX Next has also published an Internal Reporting and Follow-Up Procedure (Whistleblowing Policy) for reporting potential breach at STX Next. As described in more detail in the Whistleblowing Policy, STX Next has zero tolerance for discrimination against employees who, in good faith, report potential breach through the whistleblowing system.
It is STX Next's belief that following this Code of Conduct is essential to the continued success of STX Next, and we sincerely thank all employees for their efforts in this regard.
By adopting and implementing this Code of Conduct, STX Next aligns its operations with international standards for responsible business. The company supports the objectives of the OECD Guidelines for Multinational Enterprises, the UN Global Compact principles, and thebroader European commitment to climate neutrality and sustainable development.
Supplier Code of Conduct.
At STX Next, we expect our suppliers to adhere to the highest standards of legal compliance. Our suppliers should conduct business activities in a way that allows to be socially and environmentally responsible, especially provide us with services and products, ensuring full compliance with the standards set out in this Code of Conduct. The provisions of this Code of Conduct apply to our suppliers accordingly. STX Next does not tolerate any illegal or unethical acts. STX Next may refuse to continue doing business with a supplier that fails to comply with this Code of Conduct.
1 Employees under this Code of Conduct should be understood as persons employed under an employment contract or, when applicable, persons providing work on a basis other than employment relationship, including under a civil law contract.
1. INTRODUCTION
STX Next states in this Code of Conduct its position on key issues in three general areas:
- Anti-corruption and Ethics,
- Labour Standards and Human Rights, and
- Environment.
This Code of Conduct embodies standards of business conduct and ethics that all managers, executive officers, and members of the management board (board of directors) and supervisory board must follow. These standards are based on sound business practice, responsibility, and common sense, and are intended to encourage a high degree of personal and professional integrity.
The following documents are considered, among others, the internal regulations or internal standards:
- Work regulation;
- Terms and Conditions of Remuneration;
- Regulations for remote work;
- Social fund regulation;
- Data Protection Policy;
- Charter of Ethics;
- Anti-fraud, corruption and bribery policy;
- Anti-facilitation of tax evasion policy;
- Anti-slavery and human trafficking policy;
- STX Next Information Security Policy;
- STX Next User Information Security Manual;
- STX Next Operational Security;
- Information Security Organization at STX Next;
- Secure Software Development and Maintenance Policy;
- Procedure for entering and leaving the building.
2. ANTI-CORRUPTION AND ETHICS
2.1. Anti-bribery
STX Next refuses to accept or retain business through bribery. Employees do not directly or indirectly offer, promise, grant, or authorize the giving of money or anything of value to someone in order to unduly influence the recipient in the performance of professional duties or in order to obtain or retain an improper business advantage. Employees do not ask for or accept improper benefits from others for performance of their duties to STX Next. Applicable anti-bribery laws are strictly followed. STX Next implemented Anti-fraud, corruption and bribery policy and Charter of Ethics.
2.2. Competition
STX Next and its employees follow applicable competition law. Employees do not engage indiscussions with competitors regarding market allocation, information exchange, production and sales quotas, or bid rigging.
2.3. Conflicts of interest
Employees avoid situations in which their own personal interest, or the interest of their family members, conflict with those of STX Next. A conflict of interest exists when an employee’s personal interests are inconsistent with those of STX Next and create conflicting loyalties.
Every business decision is based on the best interests of STX Next, not personal interests.
3. LABOUR STANDARDS AND HUMAN RIGHTS
3.1. General
STX Next does not compromise on requirements set out in national law or international standards with regard to worker safety and human rights. STX Next takes responsibility for all people success are not deprived of their human rights, or subject to mental or bodily harm in their labour. STX Next understands that its business may have an impact on human rights issues STX Next complies with all relevant international covenants and conventions as well as all laws which are applicable to worker safety and working conditions for employees.
3.2. Privacy
Confidential personal information is safeguarded, and employees follow applicable laws on the handling of personal data. Data is disclosed to third parties only when legitimate grounds to do sohave been established and appropriate measures have been taken to protect the personal data tobe transferred.
3.3. Equal opportunity and anti-discrimination.
All employees are treated with dignity and respect. STX Next provides equal opportunities toeveryone. Discrimination or harassment based on race, ethnicity, gender, physical disability, sexual orientation, or religion is not tolerated.
3.4. Working conditions
STX Next provides a healthy and safe work environment for its employees and constantly strivesto make working conditions even better. Abuse (whether physical or verbal) and unlawfulharassment are strictly prohibited. STX Next implemented Regulations for remote work.
3.5. Forced labour
STX Next does not, directly or indirectly, use forced labour or other forms of involuntary labour,including prisoners, bonded workers, illegal workers, or other non-paid workers.
3.6. Child labour
STX Next recognizes and honors the rights of every child to be protected from economic exploitation. STX Next complies with applicable law and international standards regarding childlabour. STX Next implemented Anti-slavery and human trafficking policy.
4. ENVIRONMENT
STX Next complies with all applicable environmental laws and regulations. Environmental resources are used responsibly and carefully and STX Next constantly strives to conduct its business in an environmentally sustainable way, by way of, for example, improved efficiencies or investment in sustainable products, services, and technologies.
5. MONITORING OF COMPLIANCE AND ENFORCEMENT
5.1. Understanding and complying with this Code of Conduct
It is the personal responsibility of every employee to acquaint and comply with this Code of Conduct. Managers should ensure that their subordinates fully understand and comply with the standards and requirements stipulated in this Code of Conduct. Problems encountered in enforcement as well as comments or suggestions for improvement should be escalated in line with standard reporting procedures, and if appropriate, to the CEO. References to STX or STX Next mean a reference to both STX Next S.A., with its registered offic ein Poznań (address: ul. Mostowa 38, 61-864 Poznań, KRS: 0000967074, NIP: 7781424849, REGON: 300013306) and its subsidiaries.
5.2. Violation of this Code of Conduct
STX Next does not tolerate any illegal or unethical acts. STX Next may refuse to continue doing business with an employee that fails to comply with this Code of Conduct. Any employee who breaches this Code of Conduct will face disciplinary action, which could result in dismissal or may have their contract terminated.