Compliance

Promoting a Culture of Openness and Fairness

TELE-FONIKA Kable S.A. (hereinafter referred to as “TFKable”) places particular emphasis on conducting operational and production activities in an ethical, transparent, and accountable manner. We undertake initiatives that positively impact the natural environment, local communities, employees and business partners.

Risk management is the cornerstone of TELE-FONIKA Kable S.A. and other companies within the TFKable Group’s corporate governance. At the core of our risk management process lies the principle of caution – meaning we do not make any decisions or undertake any operations without prior risk assessment. By the definition of risk, we understand not only the risk to the organization and its subsidiaries but also to the communities in which we operate and the environment around us. Therefore, we ensure that the precautionary principle is the overarching philosophy of each of our decision-making processes. Additionally, the risk management process is supported by internal rules governing conduct in all areas of our operations. We adhere to industry management principles and standards regulated by appropriate certifications and permits, as well as national and international standards and regulations.

However, we understand that some risk of irregularities is inevitable; therefore, detecting and appropriately responding to any irregularities is our priority.

With the above in mind, we have created simple rules for reporting any signs that may be perceived by the public as irregularities, while also allowing us to further implement appropriate remedial measures and contribute to maintaining the highest standards in our business activities.

Additionally, we have developed and implemented numerous internal regulations, which constitute a system for reporting irregularities to the organization in accordance with Directive 2019/1937 and the Act on the Protection of Individual Reporting Breaches of the Law. These include:

internal reporting regulations, defining secure communication channels
procedures for handling reports ensuring anonymity for the individuals reporting them
follow-up actions taken by a dedicated Compliance Team to verify information on legal breaches and to adopt solutions and measures that may be applied in the event of a legal breach.

As an internal entity responsible for handling reports, a TFKCompliance Team has been appointed at TFKable.

Secure communication channels for reporting irregularities are:

TFKCompliance contact phone number: +48 12 652 52 52
Email inbox: ##rdbeaxpcrt#at#iuzpqat.rdb##
Contact form on the website: https://www.tfkable.com/compliance.html
Direct reporting to the TFKCompliance Team or by mail to: TELE-FONIKA Kable S.A., ul. H. Cegielskiego 1, 32-410 Myślenice, with the note "TFKCompliance"

At the same time, we ensure all reports are registered and analysed and appropriate corrective actions are implemented.

The reporting individual may remain anonymous or provide contact details for follow-up communication, which will be used by the TFKCompliance Team to provide:

confirmation of receipt of the report – within 7 days of notification of the suspected irregularities
information on the resolution of the report – within 3 months of confirmation of receipt of the notification of the suspected irregularities.

Additionally, the TFKCompliance Team ensures full confidentiality of the irregularity reporting process in accordance with the guidelines of the European Data Protection Supervisor concerning the confidentiality of received information, as well as the protection of the identity of the reporting individuals and other involved parties.

We also trust that such an approach will enable us to continue making sound business decisions regarding the delivery of safe, technologically-advanced cables and wires, further minimizing the impact of our production activities on society and the environment.

Stakeholder engagement plan - Bydgoszcz plant investment

Report violation

x Application form

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The default recipient of reports is the Director of the Audit and Compliance Department at TELE-FONIKA Kable S.A.

The report will be subject to verification in accordance with the Internal Reporting Regulations for Legal Breaches and the Protection of Individuals Reporting Breaches of the Law at TELE-FONIKA Kable S.A.

To ensure a thorough investigation and appropriate response to the report, it should contain at least the following elements::

• the nature of the observed irregularity;
• description of the event
o• individuals involved in the reported irregularity;

and, where possible, indication of documents that may confirm the irregularity.

The application form does not have any built-in mechanisms for identifying the sender. The form allows for anonymous reporting. However, it should be noted that voluntary provision of contact information by the sender of the report will enable feedback on the resolution of the matter and potential contact in situations where additional information is needed for a thorough review of the report.

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