Environmental Protection Policy and Procedures
1. Purpose
The company’s objective is to reduce the negative impact of its activities on the environment, comply with legislation, and promote sustainable and responsible business practices.
2. Scope
These procedures apply to all employees, contractors, and visitors of the company, and cover all areas of activity: production, storage, transport, and office work.
3. Principles
- We comply with all local and international environmental laws and requirements.
- We minimize waste generation and promote recycling and sorting.
- We use resources (water, electricity, raw materials) efficiently.
- We prevent pollution and leaks.
- We inform and train employees on environmentally friendly practices.
- We cooperate with partners who follow environmental standards.
4. Procedures
4.1 Waste Management
- Waste is collected separately (paper, plastic, bio-waste, hazardous waste).
- Hazardous waste is stored separately and handed over to a licensed waste handler.
- Waste volumes are monitored quarterly.
4.2 Energy Use
- Lighting and equipment are switched off when not in use.
- Energy-efficient equipment and LED lighting are used where possible.
- Energy consumption is monitored annually, and reduction targets are set.
4.3 Water Use
- Water leaks are checked and eliminated immediately.
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Water consumption is measured quarterly.
- Employees are provided with guidance on water-saving practices.
4.4 Pollution Prevention
- Chemicals and other hazardous substances are stored in labeled containers.
- In case of an accident, emergency procedures are followed.
- All employees are trained in basic response actions.
4.5 Employee Awareness and Training
- Environmental training is organized for employees once a year.
- New employees are given an overview of the environmental policy and procedures as part of their induction training.
5. Responsibility
- The company management is responsible for environmental compliance.
- All employees must adhere to this policy.
6. Monitoring and Continuous Improvement
- Procedures are reviewed annually.
- The environmental impact reduction plan is updated as necessary.
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Results (waste, energy, water) are documented and analyzed.
Human Rights Policy
1. Purpose
To uphold and promote respect for human rights across our operations and supply chain, in accordance with international standards including the UN Guiding Principles on Business and Human Rights and the Ethical Trading Initiative (ETI) Base Code.
2. Scope
This policy applies to all individuals working for or with the company, including employees, contract workers, interns, suppliers, and service providers.
3. Our Commitments
We are committed to:
- Prohibiting forced or bonded labour
- Prohibiting child labour and complying with the legal minimum working age
- Providing safe and healthy working conditions
- Respecting freedom of association and collective bargaining
- Ensuring no discrimination in hiring, employment, or termination
- Providing fair wages and working hours according to national legislation
- Upholding the dignity, privacy, and wellbeing of all workers
- Protecting workers from harassment and abuse
- Ensuring access to remedy for human rights concerns
4. Implementation
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Employees receive training and are informed of their rights
- Management monitors compliance and investigates any concerns
- Suppliers and partners are expected to align with this policy
5. Reporting Concerns
Workers may report human rights concerns to their supervisor, the development specialist, or anonymously if possible. All reports are treated confidentially and without retaliation.
6. Responsibility and Review
The management team is responsible for ensuring this policy is understood and implemented. It is reviewed annually or when laws or conditions change.
Non-discrimination and anti-harassment policy
Puljong OÜ
Date: 18.09.2025
Approved by: Jana Koppel (CEO)
Applies to: All employees, contractors, interns, and management
1. Purpose
To ensure a respectful, inclusive, and safe working environment, free from any form of discrimination and harassment, in accordance with local legislation and international labour standards (including the ETI Base Code).
2. Scope
These principles apply to all employees, regardless of position or contract type, and cover situations that occur:
- On company premises
- During work-related travel or events
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In digital or remote work settings
3. Principle of Equal Treatment
The company guarantees equal treatment in all employment matters. No employee shall be discriminated against based on:
- Race, ethnicity, skin colour
- Gender, gender identity or expression
- Age
- Religion or beliefs
- Disability
- Marital or family status
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Sexual orientation
- Political views
- Trade union membership
- Any other characteristic protected by law
All employment-related decisions (e.g., recruitment, promotion, compensation, termination) are based on performance and business needs.
4. Anti-Harassment Policy
The company does not tolerate any form of harassment, including:
- Verbal abuse or threats
- Unwanted physical contact
- Sexual comments or advances
- Bullying or humiliation
- Retaliation for reporting a concern
The harasser may be a colleague, supervisor, or a third party (e.g., supplier, client).
5. Reporting Procedure
Employees may report incidents to:
- Their direct supervisor
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The development specialist or a member of management
All reports are handled confidentially and investigated promptly. No retaliation is allowed against anyone who reports in good faith.
6. Consequences
Violations of these principles may result in disciplinary action, including termination of employment.
7. Communication and Training
All employees are informed of these practices during onboarding and/or in staff meetings.
8. Review and Responsibility
These principles are reviewed annually and updated as needed. The management team is responsible for oversight and implementation.
Personal Data Protection Policy and Procedures
1. Purpose
To ensure the responsible collection, use, storage, and protection of all personal data related to employees, contractors, and applicants, in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR).
2. Scope
This policy applies to all personal data processed by the company in the context of employment, recruitment, payroll, and internal communication. Personal data includes, but is not limited to:
- Full name
- ID code or date of birth
- Contact details
- Bank account information
- Work performance records
- Health or leave-related information (where applicable)
3. Principles of Data Processing
We follow the key principles of lawful data processing:
- Lawfulness, fairness, and transparency
- Purpose limitation
- Data minimization
- Accuracy
- Storage limitation
- Säilitamise piirang
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Integrity and confidentiality
4. Employee Rights
Employees have the right to:
- Access their personal data
- Request correction or deletion
- Object to processing under certain conditions
- File a complaint to the Data Protection Authority
5. Data Access and Security
Access to personal data is limited to authorized personnel only. All data is stored securely in physical or digital form. Passwords, encryption, and secure file systems are used to protect digital records.
6. Data Retention
Personal data is retained only as long as necessary for employment or legal compliance. Once the data is no longer needed, it is safely deleted or anonymized.
7. Data Breaches
In case of a data breach, the company will notify the appropriate authority and affected individuals as required by law.
8. Responsibility and Review
The development specialist is responsible for overseeing data protection practices. This policy is reviewed annually or when laws change.