Compliance

DBK Group Code of Ethics for Business Partners
(hereinafter referred to as the “Code”)
Consolidated text
from September 18, 2024

Entry

The DBK Group conducts business activities honestly, in accordance with the law and ethical principles and strives to create honest and ethical relations with Business Partners, including in particular customers, suppliers, subcontractors, service providers and service recipients (hereinafter jointly 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 the DBK Group Business Partners, from whom the DBK Group expects compliance with the highest standards of business ethics, including, among others, the principles expressed in the Code. At the same time, the DBK Group undertakes to treat 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 initiating cooperation with a company belonging to the DBK Group.

Rules and requirements

1. Mutual respect and non-discrimination

The DBK Group bases its professional relationships and relationships 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 regulations regarding health, safety and the natural environment.

3. Workers rights and human rights

The DBK Group respects workers’ and human rights. The DBK Group does not tolerate child labor or modern slavery.

✓ Business partners are obliged to build employment relations 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 to connect with its customers. When posting content on the Internet, the DBK Group respects the privacy and diversity of opinions of others and complies with the regulations on personal data protection.

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

5. Protection of competition

The DBK Group does not allow any actions that are against competition law, in particular collusion with competitors is not allowed. The DBK Group’s suppliers are independent entrepreneurs selected based on objective criteria. The DBK Group does not use commercial relations to violate unfair competition regulations.

✓ 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 action that restricts 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 disruption of free competition, does not violate the law, ensures fair competition and protects itself against bribery in order to build trust in the DBK Group. The DBK Group operates on the basis of honesty. 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. Donations in kind, gifts or business favors

✓ Business partners are prohibited from offering 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.
✓ In order to comply with the standard of conduct generally considered to be customary, it is necessary to proceed in accordance with the principle that the acceptance and giving of gifts, presents or donations is inadmissible if they do not remain within the limits of customary norms. In assessing whether a gift or present exceeds the limits of custom, the personal lifestyle of the people involved, their position in the hierarchy and the nature of the occasion in which the gift or donation is given should be taken into account.
✓ It is prohibited to accept, offer, promise or give any kind of gift 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 that are not directly related to running a business, to participate in such events, including at the expense of third parties, unless the intention of these activities 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 similar sanctions.

✓ Business partners are prohibited from establishing contacts or cooperation with persons subject to trade sanctions.
✓ Business partners undertake to comply with all applicable regulations regarding international trade sanctions.

9. Conflict of interest

The DBK Group performs its tasks and obligations impartially, avoiding conflicts of interest so that personal interests do not conflict with professional obligations. In this way, it makes decisions in the best interests of its customers and suppliers and increases 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 in an appropriate manner.
✓ Business partners guarantee that their employees will maintain the confidentiality of confidential information and business secrets of the DBK Group.

11. Protection of personal data

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., which are the intellectual property of the DBK Group, appropriately and does not make them available without justification. The DBK Group also respects the intellectual property of third parties.

✓ Business partners are obliged to comply with intellectual property regulations.
✓ Business partners are prohibited from using, publishing or disclosing materials protected by applicable law and belonging to the DBK Group without authorization.
✓ Business partners undertake to use the above materials within the authorization resulting from the agreement.

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 in line with the DBK Group’s business ethics standards.

Legal consequences of violating the principles and requirements of the Code

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