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The Anti-corruption Policy of Hicron Sp. z o.o.


Hicron applies high ethical standards in all its activities, respects the rights of employees, and the principle of honesty towards contractors and other cooperating parties. We require all employees to follow general ethical principles and legal provisions, in particular provisions containing amendments to the provisions (detailed provisions are included in Annex 3).

The principles of counteracting corruption in force at Hicron, the dissemination and implementation of the main values, i.e. honesty in relations with other Employees and Contractors, building trust in mutual relations with the environment and caring for maintaining this trust, in particular with Contractors and operating entities, transparency of all activities as well as fairness and decent treatment.


The goal

Hicron’s goal is to implement the actions taken in the Code of Anti-Corruption Policy in all aspects of actions and to take actions to cut this occurrence.



Corruption – promising, offering, giving, accepting – directly or indirectly – an improper material or personal benefit. This benefit can be accepted for this person (indirect), but also intermediate parties. Corruption is also the acceptance of interruptions or a promise of performance in return for a specific act or omission in the performance of one’s abilities.


A property benefit – it does not necessarily have to take the form of money – it can also be, for example:

– gift certificates/coupons,

– payment/transfer of the sum,

– expensive gifts (e.g. perfumes, cosmetics, tobacco products, alcohol),

– loan granted on favorable terms, to use the material benefit,

– donation transferred and accepted to provide financial benefits.


Personal benefit – a benefit for a non-property center that is positively received by the person who receives it or who is close to that person, e.g. a promise of employment, promotion, or settlement of the case.


Public acting person – a person in the art. 115 sec. 19 of the Criminal Code.


The rules

Following the Code, the following actions are always prohibited in any form, whatever the case:

– offering, promising, or giving financial or personal benefits of value and in any form,

– accepting or requiring the above-mentioned property or personal benefits,

– intermediation in the game or the awarding of the above benefits in exchange for determining actions or omissions, and in particular if it would involve the abuse or failure of employees at Hicron, in particular:

  • Employee promoting establishing cooperation with a specific contractor in return for money or promises of employment in the future after working at Hicron,
  • disclosure by the Employee (access to secrecy obligations) of the list and lists of buyers to Hicron in exchange e.g. a trip abroad or a promise of employment in the future in a competitor,
  • offering the contractor’s representative money in exchange for favorable terms of the contract with Hicron or establishing cooperation,
  • acceptance of the benefit in the form of gift vouchers by a Hicron employee in exchange for employing a specific person at Hicron in violation of the recruitment rules.


Besides, the following are prohibited:

– legalizing or attempting to legalize revenues from corruption, e.g. creating for a marketing activity, which is intended for corrupt activity, or creating fictitious accounting documentation (e.g. issuing VAT invoices) aimed at legalizing the financial benefits granted,

– all forms of coercion or inducement to the above-mentioned acts, e.g. encouraging the contractor to corrupt.


Responsibility of employees

Hicron’s senior management, and in particular the people managing teams and departments at Hicron, are to identify the possibility of a risk of corruption behavior, areas supervised by them tasks. Thus, they pay attention to and react to any situations that may pose a corruption risk and inform their employees about it, clearly and unambiguously communicating their non-acceptance of these actions and indicating the appropriate course of action. Responding to proceedings for corruption protection is the duty of every Hicron Employee.


Reporting Abuse

Each Hicron employee has an account of informing the first superior or Hicron’s management about any, even possible, conflict of interest that may arise in connection with the performance of the tasks entrusted to you.

In our organization, the legal team is responsible for the anti-corruption system. Please direct all questions related to its functioning or any other doubts directly to the Staff of this department. Communication channel: [email protected]


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