Compliance

DBK Group Code of Ethics for Business Partners
(hereinafter referred to as the “Code”)
Consolidated text
from October 1, 2025

Entry

The DBK Group conducts business activities honestly, in accordance with the law and ethical principles and strives to create honest and ethical relationships with its business partners, including in particular its customers, suppliers, subcontractors, service providers and service recipients (hereinafter collectively referred to as “Business Partners”).

The Code contains principles considered by the DBK Group to be particularly important in business relations.

Who does the Code apply to?

The Code applies to DBK Group Business Partners, whom the DBK Group expects to adhere to the highest standards of business ethics, including, but not limited to, the principles set forth in the Code. At the same time, the DBK Group is committed to treating Business Partners in accordance with the provisions of the Code, in a fair and ethical manner.

Business partners undertake to take appropriate steps to ensure compliance with the requirements of the Code by their employees, associates and business partners.

Acceptance and commitment to comply with the Code occurs upon establishing cooperation with a company belonging to the DBK Group.

Rules and requirements

1. Mutual respect and non-discrimination

The DBK Group bases its business relationships and relations with business partners in particular on mutual respect and cooperation.

Business partners are obliged to:

✓ treating all employees and associates of the DBK Group with due respect,
✓ respecting the rights of its employees and applicable anti-discrimination laws.

2. Health, safety and environmental compliance

In order to meet the requirements of occupational health and safety regulations, the DBK Group gives priority to safety and environmental protection regulations when planning and implementing its tasks.

✓ Business partners in cooperation with the DBK Group are obliged to comply with legal provisions regarding health, safety and the environment.

3. Labor rights and human rights

The DBK Group respects workers’ and human rights. Child labor and modern slavery are not tolerated at the DBK Group.

✓ Business partners are obliged to build employment relationships on a voluntary basis, to comply with labor law and to protect and support the human rights of their employees.

4. Ethics in Social Media

The DBK Group uses social media as a tool to promote its business and connect with its customers. When publishing content online, the DBK Group respects the privacy and diversity of opinions of others, and complies with personal data protection regulations.

✓ Business partners are obliged to comply with the rules of online communication, i.e., among other things, to provide factual information, and to post content on the Internet taking into account the provisions on personal data protection and the protection of personal rights.

5. Competition protection

The DBK Group prohibits any conduct inconsistent with competition law, in particular collusion with competitors. The DBK Group’s suppliers are independent entrepreneurs selected based on objective criteria. The DBK Group does not use commercial relationships to violate unfair competition laws.

✓ Business partners are obliged to comply with the principles of fair and free competition and apply applicable competition and antitrust laws.
✓ Business partners ensure that there is no exchange of protected information relevant to competition law or any other activities that restrict or may restrict competition.

6. Anti-corruption, anti-bribery, anti-money laundering

The DBK Group does not tolerate bribery or corruption. It does not participate in the distortion of free competition, does not violate the law, ensures fair competition, and protects itself against bribery to build trust in the DBK Group. The DBK Group’s operations are based on integrity. The DBK Group does not offer or accept bribes or inappropriate gifts. It does not tolerate suppliers or business partners who act contrary to the above principles.

✓ Business partners are obliged to comply with all applicable anti-corruption and anti-money laundering regulations.
✓ Business partners guarantee that their employees, subcontractors and representatives do not give, offer or accept any material or non-material benefits.

7. In–kind donations, gifts or business favors

✓ It is prohibited for Business Partners to offer the DBK Group any gifts in the form of money (cash, transfer, etc.), regardless of the amount.
✓ It is prohibited for the DBK Group to offer, promise or give any gifts in the form of money (cash, transfer, etc.) to Business Partners, regardless of the amount.
✓ To comply with the standard of conduct generally considered customary, one must adhere to the principle that accepting or giving gifts, presents, or donations is unacceptable unless they fall within the bounds of customary norms. When assessing whether a gift or present exceeds the bounds of custom, the personal lifestyle of the individuals involved, their position in the hierarchy, and the nature of the occasion in which the gift or donation is given should be considered.
✓ It is prohibited to accept, offer, promise or give any donation in kind unless such conduct does not influence or give rise to the suspicion of exerting any influence on business decisions and does not violate customarily accepted norms.
✓ It is prohibited to participate in or be invited to events not directly related to running a business, and to participate in such events at the expense of third parties, unless the intention of these actions is not to exert prohibited influence on business decisions and does not raise suspicions that such influence has been achieved and participation in and inviting other people to such events is within the framework of customarily accepted norms.
✓ Business partners should not apply the above rules in their relationships with other entities.

8. Trade sanctions

The DBK Group does not sell, either directly or indirectly, to countries or customers subject to EU, US or UN trade embargoes or sanctions.

✓ Business partners may not establish contacts or cooperate with persons subject to sanctions, including trade sanctions.
✓ Business partners undertake to comply with all applicable international sanctions laws, including trade sanctions.

9. Conflict of interest

The DBK Group performs its duties and responsibilities impartially, avoiding conflicts of interest to prevent personal interests from interfering with professional obligations. This ensures that decisions are made in the best interests of its customers and suppliers and enhances their trust in the DBK Group. The DBK Group is politically neutral.

✓ Business partners are obliged to report any potential or actual conflict of interest at every stage of cooperation with the DBK Group.

10. Protection of confidential information and trade secrets

The DBK Group protects its internal, confidential information and business secrets.

✓ Business partners are obligated to use and protect all information appropriately.
✓ Business partners guarantee that their employees will maintain the confidentiality of confidential information and business secrets of the DBK Group.

11. Personal data protection

The DBK Group complies with applicable data protection regulations and takes the necessary measures to protect the personal data collected.

✓ Business partners are obliged to comply with applicable personal data protection regulations.

12. Intellectual property

The DBK Group uses all patents, copyrights, know-how, trademarks, etc., constituting the intellectual property of the DBK Group appropriately and does not disclose them unjustifiably. The DBK Group also respects the intellectual property of third parties.

✓ Business partners are obliged to comply with intellectual property regulations.
✓ Business partners may not use, publish or disclose materials protected by applicable law and belonging to the DBK Group without authorization.
✓ Business partners undertake to use the above-mentioned materials within the scope of authorization arising from the contract.

13. Compliance of products/articles with legal regulations

In order to build and maintain trust in its services and products, the DBK Group is committed to and wishes to comply with applicable legal regulations and maintain its current high standards of quality and safety.

✓ Importers, manufacturers and distributors with whom the DBK Group cooperates are obliged to meet the requirements and obligations regarding products/articles resulting from the provisions of generally applicable law – both Polish and EU law.

14. Artificial intelligence

The DBK Group uses artificial intelligence technologies in accordance with applicable law, including the regulations contained in the AI Act (Regulation No. 2021/0106 of the European Parliament and of the Council).

✓ Business partners using artificial intelligence technologies are required to comply with the provisions of the AI Act, including ensuring compliance with security, transparency and personal data protection standards.
✓ Business Partners are obligated to immediately inform the DBK Group of any changes that affect compliance with the AI Act. If any violations are identified, Business Partners undertake to take the necessary corrective actions.

Business Partner Checkup

For legal reasons, the DBK Group may require due diligence on its Business Partners. The DBK Group reserves the right not to establish or terminate a relationship with a Business Partner whose practices were not consistent with the DBK Group’s standards of business ethics.

Legal consequences of violating the principles and requirements of the Code

A breach of the provisions of the Code by a Business Partner may result in the termination of any contracts concluded with them and the loss of future business contacts with the DBK Group.