COTT Electronics Sp. z o.o. Corporate Social Responsibility (CSR) Policy

Introduction

At COTT Electronics Sp. z o.o., we recognize the importance of conducting business in a socially responsible and sustainable manner. We are committed to making a positive impact on society, the environment, and our stakeholders. Our CSR policy reflects our dedication to ethical practices, environmental stewardship, and community well-being, in alignment with Polish and EU standards, including the EU Corporate Sustainability Reporting Directive (CSRD, Directive (EU) 2022/2464) and Polish regulations on corporate social responsibility.

Company Details: COTT Electronics Sp. z o.o., a limited liability company registered in Poland under KRS: 0001019972, NIP: 5252944045, REGON: 524484765, with its registered office at Mikołaja Kopernika 30 / 11A, 00-336 Warszawa, Polska.

1. Environmental Sustainability

We are committed to minimizing our environmental impact and promoting sustainable business practices in compliance with Polish environmental laws and EU environmental regulations:

• Environmental Compliance: We comply with the Polish Environmental Protection Act (Ustawa Prawo ochrony środowiska) and EU environmental directives, including the EU Climate Law (Regulation (EU) 2021/1119) and the European Green Deal objectives.
• Energy Efficiency: We strive to minimize our environmental impact by adopting sustainable practices in our operations, including energy efficiency measures, waste reduction, and responsible resource management, in compliance with the EU Energy Efficiency Directive (Directive 2012/27/EU).
• Carbon Footprint Reduction: We continually assess and improve our environmental performance, seeking opportunities to reduce our carbon footprint and promote eco-friendly initiatives, such as using energy-efficient technologies in our IPTV solutions and cloud infrastructure.
• Waste Management: We implement responsible waste management practices in accordance with the Polish Waste Act (Ustawa o odpadach) and EU Waste Framework Directive (Directive 2008/98/EC).
• Sustainable Procurement: We prioritize working with suppliers and partners who share our commitment to environmental sustainability, in line with EU Green Public Procurement (GPP) criteria.

2. Community Engagement

We are dedicated to making a positive impact on the communities in which we operate, in compliance with Polish and EU regulations on corporate philanthropy and social responsibility:

• Local Community Support: We actively engage with the communities in which we operate, contributing to their well-being through philanthropic initiatives, volunteer programs, and community development projects in Poland and beyond, in accordance with Polish tax law provisions on charitable donations (Ustawa o podatku dochodowym od osób prawnych).
• Education and Digital Literacy: We support education, health, and social welfare programs to empower local communities and enhance their quality of life, such as initiatives promoting digital literacy in the hospitality sector, in alignment with EU Digital Skills and Jobs initiatives.
• Social Inclusion: We support programs that promote social inclusion and reduce digital divides, in compliance with EU social inclusion policies and Polish social assistance regulations (Ustawa o pomocy społecznej).
• Transparency in Giving: We maintain transparency in our charitable activities and community investments, in accordance with EU transparency requirements and Polish accounting standards (Ustawa o rachunkowości).

3. Ethical Business Practices

We uphold the highest standards of integrity, transparency, and ethical conduct in all aspects of our business operations:

• Anti-Corruption: We comply with all applicable Polish and EU anti-corruption laws, including the Polish Anti-Corruption Act (Ustawa o odpowiedzialności za czyny korupcyjne) and the EU Anti-Corruption Report framework, fostering a corporate culture that promotes ethical decision-making and accountability.
• Business Ethics: We maintain a code of business ethics and conduct that guides our employees and business partners, in compliance with EU business ethics standards and Polish corporate governance principles.
• Transparency: We are committed to transparency in our business operations, financial reporting, and stakeholder communications, in accordance with EU transparency requirements and Polish disclosure obligations (Ustawa o ofercie publicznej i warunkach wprowadzania instrumentów finansowych do zorganizowanego systemu obrotu).
• Fair Competition: We engage in fair competition practices in compliance with Polish competition law (Ustawa o ochronie konkurencji i konsumentów) and EU competition rules (Articles 101-102 TFEU).
• Whistleblower Protection: We have established procedures for reporting ethical concerns and protect whistleblowers in accordance with the Polish Whistleblower Protection Act (Ustawa o ochronie sygnalistów, implementing EU Directive 2019/1937).

4. Employee Well-being

We are committed to providing a safe, inclusive, and supportive work environment that prioritizes the health, safety, and well-being of our employees:

• Occupational Health and Safety: We comply with the Polish Labor Code (Kodeks pracy) and EU occupational health and safety directives, including Directive 89/391/EEC on the introduction of measures to encourage improvements in the safety and health of workers, ensuring a safe working environment for all employees.
• Work-Life Balance: We invest in professional development opportunities, employee wellness programs, and initiatives that promote a healthy work-life balance, such as flexible working arrangements, in compliance with EU work-life balance directives (Directive (EU) 2019/1158).
• Employee Rights: We respect and protect employee rights in accordance with the Polish Labor Code, EU labor directives, and international labor standards, including the right to collective bargaining and fair working conditions.
• Professional Development: We provide training and professional development opportunities to our employees, supporting their career growth and skills development, in alignment with EU lifelong learning initiatives and Polish education and training regulations.
• Employee Engagement: We foster a culture of open communication and employee engagement, encouraging feedback and participation in decision-making processes, in compliance with EU social dialogue principles.

5. Diversity and Inclusion

We actively promote diversity and inclusion within our workforce, recognizing and celebrating individual differences:

• Equal Opportunities: We foster an environment that values diversity, ensuring equal opportunities for all employees, in line with EU anti-discrimination laws (Directive 2000/78/EC establishing a general framework for equal treatment in employment and occupation) and Polish equality regulations (Ustawa o równym traktowaniu).
• Non-Discrimination: We prohibit discrimination based on race, gender, age, disability, sexual orientation, religion, or any other protected characteristic, in compliance with the Polish Labor Code and EU equality directives.
• Inclusive Workplace: We create an inclusive workplace culture that respects and values diverse perspectives, backgrounds, and experiences, in alignment with EU diversity and inclusion initiatives.
• Accessibility: We ensure our workplace and services are accessible to people with disabilities, in compliance with the Polish Act on Vocational and Social Rehabilitation and Employment of Disabled Persons (Ustawa o rehabilitacji zawodowej i społecznej oraz zatrudnianiu osób niepełnosprawnych) and EU accessibility requirements (Directive (EU) 2019/882).

6. Stakeholder Engagement

We engage with our stakeholders to understand their expectations and address their concerns:

• Stakeholder Dialogue: We engage with our stakeholders, including customers, suppliers, investors, employees, and the wider community, to understand their expectations and address their concerns, in accordance with EU stakeholder engagement principles and Polish corporate governance standards.
• Transparent Communication: We maintain open and transparent communication channels to build trust and foster positive relationships with our stakeholders, such as through regular updates on our CSR initiatives, in compliance with EU transparency requirements.
• Customer Relations: We prioritize customer satisfaction and maintain high standards of customer service, in compliance with EU consumer protection laws (Directive 2011/83/EU) and Polish consumer rights regulations (Ustawa o prawach konsumenta).
• Supplier Relations: We work with suppliers who share our commitment to ethical business practices and social responsibility, in accordance with EU supply chain due diligence requirements and Polish procurement regulations.

7. Philanthropy and Social Investments

We contribute to philanthropic initiatives and social investments that align with our values:

• Strategic Philanthropy: We contribute to philanthropic initiatives and social investments that align with our values and address critical social and environmental issues, such as supporting technology access for underserved communities, in compliance with Polish tax law on charitable donations (Ustawa o podatku dochodowym od osób prawnych).
• Partnerships: We actively seek opportunities to support and collaborate with organizations working towards positive societal impact, including local Polish charities and NGOs, in accordance with EU partnership principles and Polish regulations on public benefit organizations (Ustawa o działalności pożytku publicznego i o wolontariacie).
• Social Impact Measurement: We measure and report on the social impact of our philanthropic activities, in alignment with EU social impact measurement frameworks and Polish reporting requirements.

8. Compliance and Accountability

We hold ourselves accountable for our social and environmental impact:

• Legal Compliance: We comply with all relevant Polish and EU laws and regulations governing our business operations, including environmental, labor, data protection, consumer protection, and competition laws.
• CSR Audits: We hold ourselves accountable for the social and environmental impact of our activities and will continually seek ways to improve our performance, including through regular CSR audits and assessments, in compliance with EU sustainability reporting standards.
• Internal Controls: We maintain internal controls and procedures to ensure compliance with our CSR commitments and applicable laws, in accordance with Polish corporate governance requirements and EU compliance standards.
• Remediation: We take prompt action to address any identified non-compliance or negative impacts, in line with EU remediation principles and Polish legal requirements.

9. Reporting and Communication

We are committed to transparent reporting on our CSR initiatives:

• Sustainability Reporting: We transparently report on our CSR initiatives and progress through regular sustainability reports and other communication channels, in line with the EU Corporate Sustainability Reporting Directive (CSRD, Directive (EU) 2022/2464) and Polish reporting requirements.
• Stakeholder Feedback: We actively seek feedback from stakeholders to continuously improve our CSR efforts, ensuring our policies remain relevant and effective, in accordance with EU stakeholder engagement principles.
• Public Disclosure: We make our CSR reports and policies publicly available on our website, in compliance with EU transparency requirements and Polish disclosure obligations.
• Regular Updates: We regularly review and update our CSR policies and practices to reflect changes in laws, regulations, best practices, and stakeholder expectations, in alignment with EU and Polish regulatory developments.

10. Governance and Oversight

Our CSR activities are governed by clear structures and processes:

• Management Commitment: Our management team is committed to CSR and provides leadership and resources to support our CSR initiatives, in accordance with Polish corporate governance standards and EU corporate responsibility principles.
• Board Oversight: Our CSR activities are subject to appropriate oversight and review, in compliance with Polish corporate governance requirements and EU corporate responsibility frameworks.
• Policy Review: This CSR policy is reviewed regularly to ensure its continued relevance and effectiveness, in alignment with EU and Polish regulatory requirements and best practices.

Conclusion

This CSR policy represents our commitment to making a meaningful contribution to the well-being of society and the environment. We will regularly review and update this policy to ensure its alignment with our evolving goals and aspirations, as well as Polish and EU regulatory requirements, including the EU Corporate Sustainability Reporting Directive and related Polish implementing regulations.

By adhering to this policy, COTT Electronics Sp. z o.o. demonstrates its commitment to responsible business practices and sustainable development, contributing to a better future for all stakeholders.

Contact Us

For inquiries about our CSR initiatives, please contact us at: