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Anti-corruption policy

Objective:

  • Protecting the Good Reputation of Bech Packaging sp. z o.o.: Maintaining high ethical standards strengthens the trust of customers and business partners.
  • Ensuring Legal Compliance: Avoiding legal and financial sanctions resulting from violations of anti-corruption regulations.
  • Promoting an Ethical Culture: Creating a work environment based on honesty and transparency.
  • Minimizing Business Risk: Preventing financial and operational losses associated with corrupt practices.

 


1. Introduction

This anti-corruption policy aims to establish clear rules and standards of conduct at Bech Packaging to ensure a work environment free from dishonest practices such as bribery, abuse of power, or conflict of interest.

This policy applies to all employees, management, subcontractors, and business partners collaborating with Bech Packaging.


2. Scope

The policy covers all aspects of Bech Packaging's activities, including relationships with customers, suppliers, business partners, public institutions, and other third parties.


3. Definitions

  • Corruption: Actions involving offering, promising, giving, accepting, or demanding any undue advantage to gain an unauthorized benefit.
  • Bribery: Any form of monetary or personal benefit offered or accepted to influence business or administrative decisions.
  • Conflict of Interest: A situation where a person's personal or private interests (such as financial benefits, family or social relationships) may influence or affect their impartiality, objectivity, and loyalty to professional or official duties. This may lead to decisions or actions that are not fully aligned with the best interests of the company or organization but serve the individual's private gains.
  • Abuse of Power: A situation where a person or authority possessing certain powers or authority uses them unlawfully, unethically, or contrary to accepted social norms to achieve personal benefits or harm others. This involves exceeding or improperly using granted competencies, leading to the violation of the rights and interests of other individuals or entities.

 


4. General Principles

  • Zero Tolerance for Corruption: Bech Packaging sp. z o.o. does not accept any form of corruption, including bribery, paid protection, or money laundering.
  • Legal Compliance: All actions of Bech Packaging sp. z o.o. must comply with applicable national and international laws.


5. Gifts and Hospitality

  • Permissible Actions: Accepting and offering symbolic gifts or hospitality by Bech Packaging sp. z o.o. employees is allowed if it aligns with normal business practices and does not influence business decisions. Before giving a gift or form of entertainment, a Bech Packaging sp. z o.o. employee must verify whether the recipient's company internal regulations do not prohibit such actions.
  • Prohibited Actions: It is forbidden for Bech Packaging sp. z o.o. employees to offer or accept gifts other than symbolic ones or those that could be interpreted as an attempt to influence decisions.
  • Interpretation of Value: In case of doubts regarding the definition of symbolic value, one should each time seek interpretation from the managing director or two board members simultaneously.


6. Conflict of Interest

  • Employees of Bech Packaging sp. z o.o. must not allow situations where their private interests may conflict with the company's interests.
  • Any potential conflicts of interest must be immediately reported to the managing director or the board.


7. Relationships with Suppliers and Customers

  • Transparency: All relationships with suppliers and customers must be based on honesty and transparency.
  • Selection Criteria: The selection of suppliers, subcontractors, or other business partners is based on objective criteria such as price, quality, delivery timeliness, or others relevant to the scope of cooperation.


8. Reporting Irregularities

  • Bech Packaging sp. z o.o. provides confidential communication channels for employees wishing to report suspicions of corruption or other unethical behaviors. Detailed procedures are described in the Internal Reporting Procedure of Bech Packaging sp. z o.o.
  • Whistleblowers are protected from any form of retaliation.


9. Training and Education

  • The company commits to regularly conducting training for employees on the anti-corruption policy.
  • New employees of Bech Packaging sp. z o.o. are obligatorily acquainted with the anti-corruption policy during the onboarding process.


10. Monitoring and Audit

  • The Board, Management, and Integrated Management System Representatives will regularly monitor compliance with the anti-corruption policy.
  • In case of detecting irregularities, appropriate steps will be taken, including disciplinary or legal actions.


11. Consequences of Violations

  • Violation of the anti-corruption policy may result in disciplinary sanctions, including summary termination of employment and the return of all obtained benefits.
  • In case of serious violations, the company reserves the right to notify the appropriate law enforcement authorities.


12. Management Responsibility

  • The management of Bech Packaging sp. z o.o. is obliged to exemplary behaviors in promoting an ethical business culture.
  • Managers of Bech Packaging sp. z o.o. are required to set an example and support colleagues in understanding and applying the principles of this policy.


13. Cooperation with Law Enforcement

  • The company commits to full cooperation with law enforcement authorities in cases of investigations related to corruption.


14. Final Provisions

  • Any questions regarding the policy should be directed to the managing director or the board of Bech Packaging sp. z o.o., or through the anonymous information channel described in the Internal Reporting Procedure of Bech Packaging sp. z o.o.