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One of the key objectives of the LOTOS Group Corporate Social Responsibility Strategy for 2012-2015 is to enhance business process security within the organisation through comprehensive management of misconduct risk under a misconduct prevention system.

In 2012, in keeping with the adopted standards of corporate social responsibility and business ethics, the Grupa LOTOS Management Board announced the Misconduct Prevention Policy, which contains a clear declaration that LOTOS will not tolerate any unethical behaviour, including corruption in any form. Grupa LOTOS has adopted a systematic approach to increasing the organisation's immunity to the risk of misconduct by its employees and external stakeholders (suppliers, customers, etc.). As the Management Board attaches great importance to ethical issues, two meaningful initiatives were undertaken in 2014. The first was to implement the Group-wide comprehensive Misconduct Risk Management Programme. The other was to sign the United Nations Global Compact's Call to Action on Anti-Corruption, a global initiative where businesses join forces to fight corruption in all its forms.

pdf Misconduct Prevention Policy

Any actual or suspected ethical violations can be reported by LOTOS Group stakeholders to persons responsible for preventing misconduct within the organisation. For this purpose, dedicated channels of communication with Grupa LOTOS' Internal Audit Office have been established.

1. Individual alleged to have committed misconduct:

2. Type of misconduct:

3. Source of knowledge of misconduct:

4. Description of misconduct:

5. Evidence of misconduct:


6. Has the misconduct been reported to other persons?:

7. Other persons involved in the issue or aware of the misconduct:

Person aware:

8. Notifying person:

All personal data obtained in connection with the receipt of an alleged misconduct report is administered by the company of the LOTOS Group to which the report pertains. The data will be processed in compliance with the Personal Data Protection Act of August 29th 1997 (Dz. U. of 2014, item 1182, as amended), exclusively for the purposes of the investigation carried out to explain the reported issue. Each person has the right to access and correct their personal data. Any personal data is provided on a voluntary basis

9. Consent of the notifying person to be contacted by Grupa LOTOS: *

Grupa LOTOS reserves the right to contact the notifying person in order to verify the report and obtain additional information and, if it proves necessary to notify appropriate state authorities, in order to provide such authorities with the personal data of the notifying person.
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