In 2022, we implemented the Compliance Management Policy at CD PROJEKT S.A., based upon which the Chief Compliance Officer and the Privacy & Compliance team jointly monitor and coordinate the Company’s needs in the compliance management process, and support the Group’s subsidiaries in this regard. Compliance management at the Company is based on the principle of continuous improvement and alignment – both with regulatory needs and the needs of current operations – so that a balance is maintained between compliance and the Company’s chosen business objectives.
Business and Ethics Standards at CD PROJEKT Group
CD PROJEKT has published a set of standards titled Rules of the Game. Business and Ethics Standards at CD PROJEKT Group (the “Standards”). This document forms an obligation to abide by the highest ethical norms, legal regulations and principles by which CD PROJEKT Group companies are guided in their daily work. The Standards explain what type of behavior we support, and what type of behavior we do not tolerate. In addition to establishing the core principles of ethical conduct, within the framework of the Privacy & Compliance team we take a number of actions to ensure compliance with the law, with internal regulations and with best practices.
Anti-corruption policy
In 2022 CD PROJEKT Group has adopted an Anti-Corruption Policy, the purpose of which is to establish basic principles for recognizing, preventing and mitigating the risk of corruption and corruption-related abuse in daily operations of Group companies. The adopted principles apply to both business relations and relations with public authorities. The CD PROJEKT Group applies a zero-tolerance approach to all manifestations of corruption. As part of the Anti-Corruption Policy, there are rules on accepting and giving gifts, relations with third parties (in business or administrative contacts), and rules on exercising caution in situations which may constitute a conflict of interest, including external employment, involvement with entities competing or cooperating with CD PROJEKT, and personnel-related decisions.
SpeakUp! Policy for Preventing Irregularities
In 2023, we implemented the SpeakUp! Policy for Preventing Irregularities at CD PROJEKT S.A. Our Policy sets out, among other things, the basic principles of whistleblowing, the rights and obligations associated with whistleblowing and information about the people involved in the process.
With the adoption of the Policy, we have updated the detailed whistleblowing procedures:
- a procedure for reporting inappropriate behaviour in relations with employees (including bullying, discrimination and harassment), and
- a procedure for reporting violations (including laws, internal regulations and ethical values).
Anyone who reports a wrongdoing is entitled to protection against negative actions that may be associated with the report (so-called whistleblower protection). Such protection is also afforded to witnesses and the person assisting in the whistleblowing. In all cases, we take action appropriate to the irregularity reported. We conduct our investigations in accordance with the law, internal regulations and with confidentiality and impartiality.
If you wish to report a irregularities, you can:
- send an e-mail to: naruszenia@cdprojektred.com
- use the anonymous form
- send a letter by regular mail to: CD PROJEKT S.A., 74 Jagiellońska Street, 03-301 Warsaw with a “Confidential: Compliance” annotation.