Code of Ethics and Conduct

1. General information

The main assumption behind the creation of the Wisła Kraków Code of Ethics and Conduct (hereinafter referred to as the "Code") is an attempt to define principles and guidelines for dealing with legal and ethical problems encountered during the Club's business activities.

2. Why did we create the Code?

The Code establishes standards for the Wisła Kraków brand in the areas of professional ethics and business conduct. It was developed to support the Club in its daily work. The standards established by the Code may significantly exceed existing laws and regulations that constitute the internal regulations of the Wisła Kraków brand and should be considered complementary to them.

We can only strive for success if we are guided by a shared system of values ​​and standards. It is crucial that each of us makes a personal commitment and recognizes our responsibility to understand and meet the standards outlined in the Code, as Wisła Kraków's success and reputation depend on the effectiveness and efficiency of each of us.

The foundation of the Code is our values. They are the absolute foundation of everything we do, and each of us is expected to embrace them in our daily business activities. By living our values, we increase our chances of long-term success by continuously improving our customer service capabilities, increasing our competitiveness, and fostering a sense of pride in being part of the Wisła Kraków team.

The Code outlines not only how we should interact in our daily intra-club interactions, but also in our relationships with other businesses, public authorities, and other entities that collectively create the environment in which we operate. It specifically addresses three areas of activity:

a) compliance;
b) business practices;
c) Wisła Kraków relations.

We recognize and respect differences in local regulations regarding employment, privacy, and other areas. We will comply with local regulations regarding matters covered by this Code. If any matter contained in this Code conflicts with applicable law, the applicable law will prevail.

3. Who is the Code addressed to?

The Code is addressed to all persons employed by Wisła Kraków or its affiliated entities or bound by a civil law contract with Wisła Kraków or its affiliated entities, including co-workers of Wisła Kraków, its management and board (hereinafter referred to as "employee").

Wisła Kraków expects from everyone:
a) ethical and honest conduct in all business matters of the Club;
b) acting in accordance with the law, the Code, as well as the Club's internal regulations, policies and business practices;
c) report known or potential violations using available communication channels;
d) cooperation in investigations conducted in compliance matters.

In addition, Wisła Kraków expects from its management team:
a) promoting and supporting ethical conduct and business practices that are consistent with the provisions of the Code;
b) encouraging open and honest dialogue conducted in a confidential manner, without any retaliatory action;
c) providing support and resources in the areas of ethics and compliance.

4. Compatibility

Compliance with laws, regulations and Wisła Kraków policies.

We must all comply with applicable laws, regulations, and internal policies wherever we operate. This means that where local laws are less restrictive than the Code, we must still comply with it, even if the activities prohibited by the Code would be considered legal under local law. Conversely, where local laws are more restrictive than the Code, we must comply with applicable local laws.

5. Antitrust and competition law

Typically, the countries in which Wisła Kraków operates have laws and regulations prohibiting unlawful restrictions on economic activity, commonly referred to as antitrust or competition law. These laws are designed to protect consumers and other economic participants from unfair business practices, as well as to promote and protect healthy competition. Wisła Kraków is committed to monitoring the regulations of all countries and organizations regarding antitrust and competition law.

Antitrust and competition law vary depending on the country of issue, but they generally prohibit agreements or other activities that may restrict competition without providing any benefit to consumers. Among these activities, which are generally considered to violate antitrust or competition law, are agreements and understandings between economic operators concerning:
a) top-down price setting or control;
b) tender collusion, i.e. coordinating submitted offers leading to the conclusion of a contract with a specific tender participant;
c) boycott of specific suppliers and customers;
d) illegal division of markets;
e) restricting the production or sale of products with the aim of unfairly restricting competition.

The above-mentioned actions are contrary to public policy and Wisła Kraków's policy. Employees must not engage in discussions regarding the above-mentioned activities with representatives of other companies. Each employee should report to the Wisła Kraków Legal Department any instances of such discussions initiated by representatives of other companies.

Methods of unfair competition and misleading activities are also prohibited, such as:
a) making false, unclear or misleading statements regarding Wisła Kraków's solutions;
b) unfairly discrediting competitors and their products;
c) making product claims without providing supporting facts;
d) using trademarks owned by other entities in order to mislead the customer.
Given the complexity of antitrust and competition law, if you have any doubts, please seek advice from the Wisła Kraków Legal Department.

6. Prohibition of unlawful financial gains

There is a strict prohibition on accepting, offering, promising, approving, brokering or making any bribes, kickbacks or monetary payments or actions/omissions involving other items of value in order to obtain business or any other advantage for Wisła Kraków or for oneself.

The above prohibition applies if such payments are made to:
a) employees and officials of government organizations or international organizations;
b) political parties and candidates for political offices;
c) business entities wholly or partly owned by companies with government financing;
d) private commercial companies;
e) Wisła Kraków employees;
f) any other entities.

Agreements or other arrangements that involve exclusive selling, tying, price discrimination, or other special sales conditions may be inconsistent with applicable antitrust and competition law. Such agreements should not be entered into without the consent of Wisła Kraków's Legal Department.

7. Economic boycott

Wisła Kraków does not participate in any economic boycott not sanctioned by the appropriate public authorities. Wisła Kraków and its employees are strictly prohibited from discriminating against or refusing to conduct business with a country that is subject to an economic boycott not sanctioned by the appropriate public authorities.

Furthermore, Wisła Kraków and its employees may not provide any information regarding Wisła Kraków's or any other entity's business dealings with a country subject to such a boycott. If you are asked to provide any information, take any action, or refrain from taking any action to further the boycott of any country, please contact Wisła Kraków's Legal Department.

8. Migration law

You are responsible for ensuring that you and all employees you employ comply with all applicable migration regulations. Wisła Kraków employees traveling abroad on business are responsible for obtaining appropriate permits, such as work permits, before entering the host country. Visa or work permit requirements apply to all Wisła Kraków employees traveling abroad on business or working on international projects or assignments abroad for any period of time. Furthermore, Wisła Kraków prohibits its employees from knowingly allowing contractors or other employees to work on a project without obtaining the appropriate authorization or documentation.

9. Confidentiality

Wisła Kraków requires its employees to maintain integrity and ethics when competing for all business opportunities. Employees involved in sales, contract negotiations, or providing services to customers are expected to understand and respect the terms of Wisła Kraków's contractual relationships. Furthermore, each employee is responsible for ensuring the accuracy and truthfulness of all statements and communications to customers. Wisła Kraków is committed to fulfilling all its contractual obligations.

All appropriate consents must be obtained before entering into, modifying, or amending any agreements. Wisła Kraków prohibits entering into or modifying agreements without prior authorization, including "side agreements" or verbal agreements.

Before purchasing any goods or services, or making any other commitments on behalf of Wisła Kraków, you must ensure that you have the authority to dispose of financial resources and the required authorization to incur liabilities. If you have the authority to sign documents on behalf of Wisła Kraków, you may not delegate this authority to another employee without prior approval.

Each employee and associate of Wisła Kraków is obliged, during the term of the contract between them and Wisła Kraków, as well as after its termination and expiration (or any other event with a similar effect), to maintain the confidentiality of all information obtained in connection with the performance of the contract, and in particular to:
a) not to use them for your own purposes or those of third parties, business entities or any other organizations, and
b) not to disclose to other third parties, business entities or any other organisations any information relating to Wisła Kraków and its shareholders and sponsors, their subsidiaries and related entities, including commercial information, the Club's transfer plans, the provisions of players' contracts, issues related to the players' training process, client lists, price structure, commercial plans, marketing policy and other information, the disclosure or use of which could in any way harm the interests of Wisła Kraków ("Confidential Information").

Disclosure of Confidential Information – excluding disclosure in connection with the performance of official duties – requires the prior written consent of Wisła Kraków. Copying, duplicating, or otherwise processing Confidential Information, as well as storing Confidential Information outside Wisła Kraków's headquarters, requires Wisła Kraków's consent. The obligation to maintain Confidential Information does not apply to publicly available information.

10. Government Contracts

Wisła Kraków strictly adheres to the laws, rules, and regulations governing the procurement of services by any government entity of any country and the performance of government contracts. Actions that may be considered appropriate when dealing with non-government clients may be inappropriate, or even illegal, when dealing with public authorities. Penalties for non-compliance with these laws are severe and can include substantial fines and imprisonment. Wisła Kraków may also be barred from conducting business with the government. Wisła Kraków employees working with any government agency, including international organizations, are responsible for understanding and complying with all rules that apply to government contracts and interactions with government officials and employees.

No Wisła Kraków employee should attempt to obtain from any source:
a) classified information related to government procurement;
b) confidential, internal government information;
(c) proprietary information about a competitor, including, for example, information about a bid or proposal during a proceeding, or in other circumstances where there is reason to believe that disclosure of such information is unauthorized.

If such information is inadvertently provided to you by another contractor, consultant, or government employee, you should immediately contact the Wisła Kraków Legal Department.

Wisła Kraków employees are obliged to strictly comply with all laws and regulations regarding classified information.

11. Organizational conflict of interest

Wisła Kraków employees must ensure that, when performing government contracts, there is no actual or potential Organisational Conflict of Interest that would provide the Club with unequal access to non-public information, provide an unfair advantage in competitive contracts, or impair the objectivity of Wisła Kraków employees when providing assistance or advice to public authorities or in the performance of contracts entered into with public authorities.

12. Restrictions on the employment of former government employees

Before engaging in any discussions related to possible employment or conducting business with a current or former government employee, you must obtain the consent of the Wisła Kraków Legal Department.

13. Anti-corruption regulations

No one may give or offer anything of value (directly or indirectly) to a government official in a manner that suggests bribery in order to obtain business or any other advantage for Wisła Kraków. Engaging in any form of bribery is a violation of anti-corruption laws.

14. Gifts, meals, special events

Government employees and international organizations are generally subject to laws and regulations regarding attending special events and accepting gifts, gratuities, and other items of value from companies and individuals with whom they do business. Wisła Kraków employees are prohibited from giving or receiving gifts, benefits, or other occasional courtesies when conducting business with government employees or international organizations. Examples of such courtesies include paying a dinner bill. If you have any questions, please contact the Wisła Kraków Legal Department.

15. Personal political activity

Wisła Kraków encourages employees to become personally involved in civic affairs. However, employees must:
a) provide all financial support for political and civic affairs from its own resources;
b) participate in all political and civic activities in their own free time;
c) conduct all personal political and civic activities in compliance with current regulations;
d) bear in mind that any involvement of Wisła Kraków in social matters, including the use of the Club's name and/or markings, requires the prior consent of the Club's Management Board.

16. Putting pressure on other employees

You may not use your position in the Club to pressure other employees to financially support selected political causes or otherwise support selected candidates or political causes.

17. Intellectual Property

Apart from its employees, Wisła Kraków's most important capital is its intellectual property rights, including:
a) copyright;
b) patents;
c) trademarks;
d) trade secrets.

We are all responsible for protecting Wisła Kraków's intellectual property by acting in accordance with Wisła Kraków's policies and procedures. Maintaining the confidentiality of Wisła Kraków's trade secrets and proprietary information is an important element of such protection. This obligation continues even after leaving the Club.

We also respect the intellectual property of others. Wisła Kraków will provide all software necessary for employees to properly perform their duties, based on appropriate licensing agreements with suppliers. Using, copying, displaying, or distributing third-party software, documentation, or other copyrighted materials without permission is contrary to Club policy.

For example, you may not post another party's copyrighted content on any internal or external website without first obtaining the necessary consents. You may not use or copy the software or documentation except to the extent permitted by applicable license agreements.

Please familiarize yourself with the relevant policies and guidelines of the Wisła Kraków Legal Department, including:
a) Wisła Kraków's personal data protection security policy;
b) the content of the contract with employees or collaborators containing provisions regarding confidential information and copyright.

18. Integrity in the financial area

Accurate and reliable financial and business records are crucial to meeting Wisła Kraków's financial, legal, and business obligations. Below are some helpful tips for maintaining financial records:
a) no document may be altered in an improper manner or signed by persons who do not have the appropriate authorization;
b) the handling and payment of funds related to a transaction concluded by Wisła Kraków must be carried out in accordance with a duly previously authorized written agreement of Wisła Kraków;
c) when making any business expenses, employees and associates should ensure that accounting documents are submitted to the Club's Finance Department in accordance with the rules adopted by Wisła Kraków.

19. Document storage

Information, data and materials must be stored in a manner consistent with the Club's regulations and preventing access by unauthorized persons.

20. Disclosure of Public Information

Wisła Kraków must disclose accurate and complete information regarding its business performance. Financial results and other material matters must be reported in a full, fair, accurate, timely, and understandable manner. The club will not tolerate unauthorized leaks or disclosures of corporate information to the press or the public.

All contacts with the press and the public must be approved in advance by the Wisła Kraków Press Office.

21. Business Courtesies

It is common practice to provide meals, beverages, entertainment, and admission to various events in connection with business discussions with non-governmental personnel. You may do so when appropriate under the circumstances. However, such practices must not violate the standards of conduct of the organization represented by the other party, any client agreement, or any expense policy. You are responsible for familiarizing yourself with such policies.

The Club prohibits the giving of anything of value (including charitable donations or event sponsorships) directly or indirectly to any individual, company, or entity for the purpose of improperly inducing business. Employees who make, facilitate, and/or authorize expenses for meals, beverages, or entertainment must exercise caution to ensure that such expenses are an ordinary and proper part of their business and cannot reasonably be construed as bribes or improper inducements.

In any case, business courtesies must be modest enough to avoid the appearance of influencing the other party to secure unfair, preferential treatment, or gain an improper advantage. The ultimate test of whether business courtesies are appropriate, even if permitted by law, is whether their public disclosure would be embarrassing to the Club and/or the counterparty. All business courtesies given or received with a value exceeding 500 złoty must be reported to the appropriate supervisor.

22. Business Courtesies That Can Be Accepted

a) gifts

Wisła Kraków employees are generally permitted to accept unsolicited gifts or other business courtesies from actual or potential customers, suppliers, or other business partners, provided they have no material value and are not given with the intent to influence the employee. It is never appropriate to solicit gifts or other business courtesies, directly or indirectly. If an individual, company, or representative of a company that has or is seeking to establish a business relationship with Wisła Kraków offers you a gift or other business courtesy of material value, you must demonstrate that it cannot be construed as an attempt to secure favorable treatment for the other party. Neither you nor any member of your family may accept any benefit, guarantee of benefit, or payment from any individual or company that does or seeks to do business with Wisła Kraków.

b) entertainment

You may accept occasional meals, drinks, or other entertainment appropriate to the circumstances of normal business discussions. As mentioned above, it is inappropriate to accept such favors if they are offered solely to influence your business decision. Each employee and associate is personally responsible for ensuring that the acceptance of any business courtesies, gifts, or entertainment is appropriate and does not appear to be a reasonable attempt to secure favorable treatment for the other party.

23. Conflict of interest

The term "conflict of interest" refers to any circumstances that may raise doubts about an employee's ability to act completely objectively with respect to the Club's interests. Wisła Kraków aims to ensure that employees' loyalty to the Club is natural. All employees are obligated to avoid financial, business, or other relationships that may conflict with the interests of Wisła Kraków or may conflict with the performance of their employment duties. Employees should act in a manner that avoids even the appearance of a conflict between their personal interests and the interests of Wisła Kraków.

Conflicts of interest can arise in many ways. Examples of inappropriate actions by Club employees and associates in the event of a conflict of interest with Wisła Kraków include:
a) employment by a competitor, regardless of the nature of the employment, during the period of employment relationship with Wisła Kraków;
b) entering into business contracts with any company in which the employee, a member of his or her family or a business associate of the employee has a significant ownership interest or managerial responsibility;

c) representation of the Club by the employee in negotiations with the company in which the employee, a member of his family or his partner holds shares;

d) ownership of a company or significant shares in it when it is a competitor or supplier of the Club;

e) acting independently as a consultant to a competitor of Wisła Kraków, as well as to its client or supplier;
f) engaging in any activity or employment relationship that may disrupt or negatively impact the employee's activities at Wisła Kraków or that requires disclosure of proprietary information of the Club;
g) sitting on the supervisory board or acting as an advisor to an actual or potential competitor, client, partner or supplier of the Club;
h) any form of support for a potential partner, supplier or candidate applying for a job in the Club, which could have a positive impact on increasing the chances of being selected;
i) the employee's involvement in the recruitment or employment process of a member of his or her family or partner, as well as being in a relationship of subordination to employees who are related to him or her or in a partnership.

Sometimes conflicts of interest arise accidentally or unexpectedly, and the appearance of a conflict of interest can easily arise. If you believe you have an actual or potential conflict of interest, report all relevant details to your supervisor. The existence of a conflict does not necessarily mean that the activity being discussed is prohibited. It is your responsibility to fully disclose all aspects of the conflict to your supervisor and completely remove yourself from the decision-making process.

Additionally, if you observe any situation involving another employee that you believe is or may be a conflict of interest, report the situation to your supervisor.

24. Charitable activities

We are committed to using our technology and resources to advance education in innovative ways, promote diversity, enrich community life, and protect the environment. The Club does not make charitable donations to secure business deals or curry favor with decision-makers. However, business units may support nonprofit organizations as long as they do so within the framework of a lasting, positive business relationship, not intended to result in a successful outcome of specific business negotiations, or otherwise not provide unfair, favorable treatment that impacts the Club.

25. Protection of confidentiality

Everyone is obligated to protect confidential information to which they have access in connection with their employment with Wisła Kraków. The Club's personal data protection policy governs the collection, use, transfer, and security of employee data, customer data, and prospective customer data, as well as data to which Wisła Kraków has access in connection with its services. You are obligated to comply with these policies when collecting or processing relevant personal data. All information relating to the Club's activities that is not publicly available must be treated as confidential. Confidential information includes:
a) software and other inventions or solutions (regardless of the stage of development);
b) marketing and sales plans;
c) competitiveness analysis;
d) product development plans;
e) valuations/price list;
f) potential contracts, mergers or acquisitions;
g) business and financial plans or forecasts;
h) information about employees.

Furthermore, information relating to Wisła Kraków's clients, partners, potential clients and suppliers that has been provided to the Club in confidence is considered confidential information.

Protecting Wisła Kraków's trade secrets is crucial to our operations. Any disclosure of trade secrets outside the Club must be approved in advance by the appropriate department head. Before disclosing any source materials, please contact the Wisła Kraków Legal Department to obtain the appropriate approvals.

Your obligation to protect the Club's confidential information and personal data continues after your employment with Wisła Kraków or an affiliated entity ends. Furthermore, just as we expect employees to honor their nondisclosure obligations upon leaving, we also expect them to honor their obligations to protect the confidential information of their former employers. No confidential information obtained during or as a result of your employment with former employers should be transferred to the Club or used in any way during your employment with Wisła Kraków.

26. Social Media

As a Club, we encourage communication between our employees, clients, partners, and others. Blogs, social media, discussion forums, websites, videos, and other social media can be a great way to stimulate conversation and discussion. It's especially important to remember the rules that apply in this regard. The following rules constitute a set of best practices that Wisła Kraków employees should adhere to whenever they are active on social media platforms as Club representatives:
a) All activities undertaken by Wisła Kraków employees on social media relating to their professional activity should be consistent with the Club's current strategy and mission. Wisła Kraków employees must also be aware that content published on social media concerning their personal lives may be publicly available, which may impact the employee's perception by others and the overall reputation of Wisła Kraków;
b) Each employee is personally responsible for any content posted on social media and for their own personal safety. We recommend using the highest level of privacy settings and platforms for their personal profiles;
c) employees who refer to Wisła Kraków products and services on social media should maintain full transparency and should not conceal the fact that they are employees of the Club;
d) Any content published on social media by a Club employee must not violate confidentiality or trade secrets, and must not violate the law regarding the disclosure of financial information. Employees must not disclose confidential information or secrets of Wisła Kraków or its clients, partners, investors, or any third party who has disclosed confidential information or provided information without express consent to its publication on social media. If you have any doubts as to whether certain information may be publicly disclosed, please contact the Wisła Kraków Legal Department;
e) Employees are prohibited from posting content on social media that may infringe on the personal rights of other companies. This includes using logos or trademarks of companies that have not provided express consent;
f) any comments, opinions, facts or information published by Club employees on social media should be communicated in a professional, truthful manner and with respect for intellectual property, if applicable;
g) publications in official Wisła Kraków communications, including posts and publications created at the request of and in cooperation with journalists, should always be previously verified and approved by the Club's Marketing Department.
At the same time, the only persons authorized to speak on behalf of the Club are: the President of the Club Management Board, the Club Spokesperson and persons designated by them.

h) publishing content that discriminates against any national, ethnic, religious, sexual, etc. minorities is strictly prohibited.

Any concerns regarding the right to express one's views on social media or the scope of topics discussed should be consulted with the Wisła Kraków Marketing Department. Furthermore, if any Club employee believes they have violated the above rules, they should inform the Club's Legal and Marketing Departments. We also encourage employees to report instances of offensive, false, or inaccurate content regarding Wisła Kraków appearing on social media.

27. Use of Club Resources

To carry out our duties, we utilize a range of Club assets and resources. These include Wisła Kraków's resources, computers, telephones, and email. It is crucial that each of us fully understands the requirements for the proper use of these resources. Adherence to the Club's resource use policies is required, particularly those regarding:

a) personal use of Wisła Kraków resources;
b) securing connections with the Wisła Kraków network;
c) use of passwords and virus prevention;
d) protection of confidential information.

Wisła Kraków may employ security procedures in its offices to monitor and maintain security, including the use of closed-circuit television (CCTV) cameras. Use of the Club's computers, systems, and resources may also be monitored to the extent permitted by applicable law.

Furthermore, Wisła Kraków requires its employees to adhere to the Club's information security and physical security policies at all times. Upon leaving Wisła Kraków, all Club property—including ID badges, computer equipment, software, manuals, and internal documents—must be returned to Wisła Kraków.

Wisła Kraków reports

28. Wisła Kraków and its employees

We encourage you to share your ideas for improving the workplace and to express any concerns about the workplace or specific work-related issues. We will not engage in or tolerate retaliation against employees who raise a problem, complaint, or concern in good faith. Our goal is to treat every employee fairly and equitably.

29. Diversity

Wisła Kraków adheres to the principle of equal employment opportunities regardless of sensitive data, including but not limited to: race, religion, nationality/origin, skin color, gender, age, disability, pregnancy, marital status or sexual orientation.

We apply and promote these principles in all locations in accordance with the law. We affirm the principle of freedom from discrimination in all aspects of the employment relationship, from recruitment and hiring, through performance reviews, compensation, and promotions, to termination of employment with Wisła Kraków.

We base employee actions strictly on individual abilities, performance, experience, and the needs of the company. We avoid actions influenced by personal relationships and any type of discriminatory practices. Our goal is to reward employees—through salaries, bonuses, and other benefits—according to their responsibilities, results, and services.

30. Mobbing

Wisła Kraków's policy is to provide a workplace free from harassment. The club prohibits harassment in any form, whether physical, verbal, or non-verbal.

Report cases of mobbing in accordance with the Club's anti-discrimination, anti-mobbing, and anti-sexual harassment procedures.

31. Health and Safety

We are committed to protecting the health and safety of our employees and visitors. Our policy is to maintain our offices and conduct our business in a manner that does not compromise the health and safety of our employees. All employees are expected to comply with occupational health and safety regulations and Wisła Kraków's safety policy.

32. Suppliers and partners of Wisła Kraków

We maintain open and honest business relationships with our suppliers and partners and strive to develop mutually beneficial relationships. By building partner networks, we can become a global company. We expect our suppliers and partners to adhere to high ethical standards and avoid engaging in any activity that contains even the appearance of impropriety. We expect our suppliers and partners to comply with all applicable laws and regulations and ensure that all services and goods they provide comply with all applicable legal standards. Every Club employee must prioritize customer and partner satisfaction.

33. Communities

The Club is committed to using technology and resources to advance education in innovative ways, promote diversity and enrich community life.

34. Enforcement

Wisła Kraków's strength lies in its people. The club is fortunate to employ a talented group of employees. We trust that each of you will agree that if we want to be leaders in our industry, we must adhere to the standards of the Code and uphold Wisła Kraków's business values. While we are confident that we can count on every Wisła Kraków team member, we would be remiss if we did not state categorically that deviations from our principles or standards of business conduct will not be tolerated. Any violations of the Code should be reported in accordance with the Code and/or our anti-discrimination, bullying, and sexual harassment procedures.

35. Entry into force

It's worth emphasizing that the principles and standards contained in the Code have long been an integral part of the Club. We believe that the values ​​and ethics that guide this document have long been a reflection of the attitudes and actions of our employees. Therefore, although the Code officially comes into effect on December 18, 2023, we consider the spirit of the new regulations to have long been present in our organization, shaping and continuing to shape our shared corporate culture.

*By "Wisła Kraków" or "Club" we mean the Wisła Kraków SA Sports Association and any related entity.