Code of conduct

The purpose of this document is to indicate the intentions and directions in which Billennium will develop and to ensure that Billennium, when building its operating strategy, takes into account social interests, environmental protection, relations with various stakeholder groups, the needs of the business environment and puts the importance of corporate responsibility in the first place, preventing corruption and other violations of the law, both within the organization and among business partners.

This Code applies to all employees of Billennium and all its subsidiaries in Poland and abroad.

Billennium S.A. (“Billennium”) is a Polish business backed-up with Polish equity only that offers services in the field of provision of IT solutions customised to the needs and expectations of customers, comprehensive services, management, and optimisation of communication and business processes. Billennium is among the fastest growing companies on the IT services market providing the highest quality and innovative solutions for each industry. The company’s biggest advantage is its knowledge of latest technologies and market trends and a flexible collaboration model. Utilizing the experience, expertise, and competences of professionals allows Billennium to provide a full range of information technology services.

We are aware that in terms of the type and scale of our business we impact the lives of many people and the effective functioning of organisations. In view of that, responsible business is a particularly important issue for us. Our business strategy is compliant with the interests of the surrounding environment and is based on the reasonable use of technologies.

We believe that the presented approach will contribute to the growth of business, both ours and that of our customers and suppliers, and that additionally it will bring about benefits for our social and business community.

Billennium complies with all applicable laws in all locations in which it conducts its business. We comply with the provisions of the Code also in cases when the Code sets a standard that is higher than the one provided for in legal requirements, but which is not contrary to them. We comply with the principles of the UN’s Global Compact Initiative, the Universal Declaration of Human Rights, and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work in line with the national laws and established customs.

At Billennium and all its subsidiaries in Poland and abroad, all violations in the field of compliance with legal regulations and ethical standards may be reported internally in accordance with the provisions of the internal Policy in this regard.

Child Labour 

Billennium warrants that no children are employed to perform work that is related or unrelated to any business carried out by Billennium. The term “child” applies to any person below a minimum age for admission to employment in accordance with the legislation of a given country or the local jurisdiction in which such work is performed. If a minimum age for admission to employment has not been specified, it should be set at 15 years of age. By employing young people, we must demonstrate that work performed by them will have no adverse consequences for their physical, mental, and emotional development.

Forced and Compulsory Labour 

Billennium does not employ any form of forced or compulsory labour. We do not use forced labour, slave or compulsory labour of prisoners. Employees are ensured freedom of movement and control over their identity documents. Billennium assures that employees do not pay any fees during their recruitment process or employment. Any payables concerning employees in situations required by applicable laws are our responsibility. Employment at Billennium is free from harassment, violence, intimidation, corporal punishment, psychical or physical coercion, revenge, abuse of power, insults, and discrimination.

Human Trafficking 

Billennium complies with all laws concerning the prohibition of human trafficking and slavery.

Decent Labour Conditions 

Billennium makes sure that the conditions of labour, working times, remuneration, and other benefits are compliant with national and local regulations and relevant ILO Conventions. We care about equal access to decent labour conditions for persons hired under contracts of employment, and also persons providing work under other types of arrangements. We do not follow practices consisting in illegal or disallowed deductions from remuneration. Billennium responsibly manages its employees and their places of work.

Freedom of Associations 

Billennium recognises and respects the employees’ right to associate and collective bargaining in the manner that has been provided for by laws. Employees must have the freedom to join or renounce their membership in trade unions/representation of employees.

No Discrimination 

Billennium treats its employees and business partners in a fair manner, based on factors relating to a legitimate business interest of Billennium, irrespective of race, religion, skin colour, age, sex, sexual orientation, origin, political beliefs, marital status, or disability. We support and promote an integrated labour environment and an open culture, which contribute to employee diversity.

Counteracting mobbing 

Billennium does not tolerate mobbing understood in particular as:

• hostile, destructive, unethical, verbal, visual or physical, systematic behaviour by an employer, supervisor, employee or group of employees, directed at an employee or a group of employees, consisting in persistent and prolonged harassment or intimidation, including mental or physical harassment, causing or likely to cause an employee’s low self-esteem with regards to their professional suitability, aimed at humiliating or ridiculing the employee, isolating or eliminating them from the team, causing fear in the employee;
• discriminating behaviour, i.e. having the features described above, and related directly or indirectly to the conditions of employment, promotion and access to training in order to improve professional qualifications, in particular due to sex, age, disability, religion, nationality, political beliefs, trade union affiliation, ethnic origin, religion and sexual orientation, as well as due to employment for a fixed or indefinite period, contract or full-time or part-time employment;
• any other form of psychological violence by the employer, supervisor or employee directed at an employee or group of employees.

Billennium actively counteracts mobbing, including the possibility of reporting all mobbing cases and immediate reaction in accordance with the adopted Policy of internal reporting regarding violations of law at Billennium S.A.

Illegal Payments, Corruption and Bribery 

Billennium complies with national and international anti-bribery laws and applicable anti-corruption laws, regulations, and standards. We are bound by a prohibition to become engaged in illegal payments or corruption, and by a prohibition to offer, authorise, and accept, directly or indirectly, gifts, presents, and favours, where they are aimed at – or appear to be aimed at – influencing a decision, act, omission, or obtaining a competitive advantage. We do not engage in blackmailing, frauds, embezzlement, corruption, or bribery. This also applies to actions that are to expedite (or facilitate) processes, which means making payments to a state official aimed at expediting routine administrative processes or obtaining access to services to which a payer has the right.

Details of anti-corruption proceedings at Billennium and all subsidiaries in Poland and abroad have been regulated in the internal Policy.

Occupational Health and Safety 

Billennium seeks to implement standards of occupational health and safety at a high level by applying a relevant approach to OHS management adjusted to the requirements of a specific type of business. We ensure compliance with the applicable OHS regulations and also promote and support a safe working environment that helps ensure the health of employees, safeguards third parties, and prevents accidents, injuries, harms and occupational illnesses, as well reduces the risk of exposure to dangerous factors, especially the occurrence of hazardous substances. For this purpose we regularly perform assessments of risk at work and implement relevant procedures, OHS management systems, and own safety programmes. Billennium ensures that its employees and other persons linked with the company have appropriate qualifications, are properly trained, and have been provided with equipment that ensures safe performance of work.

Protection of Personal Data 

Billennium complies with relevant laws and regulations concerning personal data protection, especially with regard to personal data of customers and suppliers, employees and associates. We ensure compliance of collecting, processing, and transmitting personal data with laws and regulations. Our priorities are: ensuring the confidentiality, integrity and availability of the processed data, ensuring technical and organisational security measures and ensuring a high level of awareness of employees in the field of personal data security.

Non-Disclosure and Confidentiality 

Billennium undertakes relevant measures to protect confidential information that has been provided by the company, its customers, and other persons. Billennium undertakes to use such information solely for a specific purpose that arises out of an agreement concluded by the parties, unless the owner of such information has expressed consent to another form of using confidential information. We do not undertake actions based on confidential information received by accident or as a result of an error, regardless of whether it comes from our customers or anyone else.

Money Laundering 

Billennium complies with the applicable laws and regulations concerning anti-money laundering and financing of terrorism. The company verifies international and national sanctions lists and does not undertake any cooperation with persons or entities subject to such sanctions.

Fair Competition 

Billennium complies with the principles of fair competition, competing with other entities solely on the basis of the criteria of value and quality of products and services. Billennium does not apply unfair or misleading market practices, neither on its behalf or other persons. We do not disclose false information about our own products or services or those of other entities. Billennium is not involved in bid rigging schemes especially consisting in the submission of courtesy offers, overstatement of amounts, rotating or withholding offers, price fixing, and provision of confidential information. We do not use any other mechanisms, the purpose of which is to falsify bids and the reduction or elimination of free competition.

Conflict of Interest 

Billennium employees inform the company about each conflict of interest, and also about each situation that creates an appearance of a conflict of interest concerning co-operation with Billennium. A conflict of interest concerns a situation whereby a private interest of a specific person creates a potential risk of influencing decisions taken by such person. Such situations of a conflict of interest include a blood relationship or marriage, civil partnerships, business co-operation, or investments.

Commercial Regulations 

Billennium conducts its business in compliance with the applicable laws governing exports and imports of goods, economic sanctions, and embargoes.

Environmental Protection 

Billennium carries out its business in a responsible fashion from a point of view of the environmental protection and in compliance with laws and regulations governing environmental protection. We perform business assessments taking into consideration any adverse impact on the environment and we strive to implement the system of preventing, identifying, and eliminating existing threats.

Licence and Reporting 

Billennium cares about obtaining and keeping up to date any required decisions, licences, and environmental permits and complying with the requirements of applicable laws relating to reporting, if such necessity arises out of the planned or conducted business of the Company.

Responsible Use of Natural Resources 

Billennium cares about the rational and sustainable use of natural resources, provided such necessity arises from the Company’s planned or conducted business. In such case, Billennium seeks to limit the utilisation of natural resources in a manner that is adjusted to the size and type of specific operations.

Reduction of Pollution and Waste 

Billennium seeks to minimise emissions of greenhouse gases, including carbon dioxide, directly or indirectly, relating to our business to the extent corresponding to the size and type of conducted operations. Billennium complies with any regulations of law concerning waste management, seeking to minimise the production of waste by its business.

In order to ensure consistency of operation, the most important documents concerning management systems have been collected as part of internal BILLENNIUM WAY policies and procedures.

Billennium expects that the Company’s suppliers will undertake relevant measures to improve the standards that have been set forth in the Code, support the values provided in it, and it encourages the development and implementation of own guidelines of ethical behaviour compliant with the standards of responsible business. In the event of non-compliance by suppliers with the standards of responsible business that are provided in the Code, we expect suppliers to take corrective measures.

• Policy of internal reporting regarding violations of law at Billennium S.A. 
• Anti-corruption policy 

• Appendix 1 – The Ten Principles of the UN Global Compact
• Appendix 2 – The Universal Declaration of Human Rights
• Appendix 3 – The four areas of the fundamental rights that humans are entitled to at work as established in the International Labour Organization’s Declaration of Fundamental Principles and Rights at Work

Appendix 1 – The Ten Principles of the UN Global Compact 

10 UM Global Compact Principles:

Human Rights

1. Support and respect the protection of internationally proclaimed human rights
2. Make sure that they are not complicit in human rights abuses.

Labour Standards

1. The freedom of association and the effective recognition of the right to collective bargaining
2. The elimination of all forms of forced and compulsory labour
3. The effective abolition of child labour
4. The elimination of discrimination in respect of employment and occupation.

Environment

1. Support a precautionary approach to environmental challenges
2. Undertake initiatives to promote environmental responsibility
3. Encourage the development and diffusion of environmentally friendly technologies

Anti-Corruption

1. Businesses should work against corruption in all its forms, including extortion and bribery

Appendix  2 – The Universal Declaration of Human Rights: 

https://www.unesco.pl/fileadmin/user_upload/pdf/Powszechna_Deklaracja_Praw_Czlowieka.pdf

Appendix  3 – The four areas of the fundamental rights that humans are entitled to at work as established in the International Labour Organization’s Declaration of Fundamental Principles and Rights at Work

1. Freedom to join a union, bargain collectively and take action (freedom of association and protection of the right to organise; right to organise and collective bargaining)
2. Prohibition of all forms of forced and compulsory labour (abolition of forced labour)
3. Effective abolition of child labour (minimum age for admission to employment; prohibition and immediate action for the elimination of child labour)
4. Elimination of discrimination in recruitment and employment (equal remuneration for men and women workers for work of equal value; no discrimination with respect to recruitment and employment).