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.
Reporting irregularities
Whistleblowing is an important part of open communication that helps strengthen mutual trust, so in 2022 at CD PROJEKT we updated our existing whistleblowing system and implemented a new Whistleblowing Procedure at CD PROJEKT S.A. For comfort in deciding whether to send a report, team members can report evidence or suspicion of irregularities both through a dedicated form that ensures confidentiality, anonymity and integrity of the information sent, and in person or in writing to the Company’s headquarters’ address. Submissions are reviewed and verified by persons designated by the Management Board, or, if the submission concerns a member of the Management Board, by the Supervisory Board.
At CD PROJEKT, team members should be guided by the principle of mutual respect, which means that their behavior and statements must not violate the rights and dignity of others. Therefore, one of the key areas covered by the whistleblower system is undesirable behavior in relations with employees. In 2022 the Company updated its existing internal regulations related to counteracting, among other things, bullying and discrimination, and implemented the Procedure for Counteracting Undesirable Behavior in Relationships with Employees. Based on this procedure, the Company is committed to strengthening its efforts to prevent and counteract any undesirable actions that may bear the hallmarks of bullying, discrimination, including sexual harassment, or any other violation of the law.
If you wish to report a irregularities at CD PROJEKT S.A. you can:
- send an e-mail to: naruszenia@cdprojektred.com
- send a letter by regular mail to: CD PROJEKT S.A., 74 Jagiellońska Street, 03-301 Warsaw with a “Confidential: Compliance” annotation.
Anyone who reports irregularities at CD PROJEKT, as well as anyone who assists in making the report, is protected from negative actions that may violate their rights or cause damage.