Compliance

DBK Group Code of Ethics for Business Partners
(hereinafter referred to as the “Code”)

Entry

The DBK Group conducts business in an honest, lawful and ethical manner and strives to create honest and ethical relations with business partners, including in particular with clients, suppliers, subcontractors, service providers and service recipients (hereinafter jointly referred to as “Business Partners”).

The Code contains principles recognized by the DBK Group as particularly important in business relations.

Who the Code applies to

The Code applies to the DBK Group’s Business Partners, from whom the DBK Group expects to comply 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 on the part of their employees, associates and business partners.

Acceptance and commitment to comply with the Code takes place 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 relations and relations with business partners in particular on mutual respect and cooperation.

Business Partners are obliged to:

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

2. OHS and environmental compatibility

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

✓ Business Partners in cooperation with the DBK Group are obliged to comply with the provisions of law regarding health, safety and the natural environment.

3. Labor and human rights

The DBK Group respects labor and human rights. The DBK Group does not allow the employment of children and modern slavery.

✓ Business Partners are obliged to build employment relations on a voluntary basis, to comply with labor law and to protect and support human rights towards their employees.

4. Ethics in Social Media

The DBK Group uses social networking sites as tools to promote its activities and to maintain closer contact with customers. By posting content on the Internet, the DBK Group respects privacy, different views of other people and acts in accordance with the provisions on the protection of personal data.

✓ Business Partners are obliged to comply with the rules of online communication, i.e., among others, to provide factual information, 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. Competition protection

The DBK Group does not allow activities that are contrary to the competition law, in particular, it is not allowed to enter into collusion with competitors. DBK Group’s suppliers are independent entrepreneurs selected on the basis of objective criteria. The DBK Group does not use commercial relations to violate the provisions on unfair competition.

✓ Business Partners are obliged to comply with the principles of fair and free competition and apply applicable regulations relating to competition and antitrust activities.
✓ Partners ensure that there is no exchange of protected information relevant from the point of view of competition law or any other activities limiting or likely to limit competition.

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

The DBK Group does not tolerate bribery and corruption. It does not participate in disrupting 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 operation of the DBK Group is based on 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 rules.

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

7. In-kind donations, gifts or business favors

✓ It is forbidden for Business Partners to offer the DBK Group any gifts in the form of money (cash, bank transfer, etc.), regardless of the amount.
✓ It is forbidden for the DBK Group to offer, promise or give Business Partners any gifts in the form of money (cash, transfer, etc.), regardless of the amount.
✓ In order to comply with the standard of conduct generally recognized as customary, it is necessary to follow the principle that accepting and giving gifts, gifts or donations is unacceptable if they do not remain within the limits of customary standards. In determining whether a gift or gift exceeds the bounds of custom, consideration should be given to the personal lifestyle of those involved, their position in the hierarchy, and the nature of the occasion on which the gift or donation is given.
✓ It is forbidden to accept, offer, promise or give any donation in kind, unless such behavior does not affect or raise suspicion of exerting any influence on Business decisions and does not violate customary standards.
✓ It is forbidden to participate in and invite to events not directly related to running a Business, to participate in such events also at the expense of third parties, unless the intention of these activities is not to exert a prohibited influence on Business decisions and does not raise suspicion that such influence has been achieved and participation and inviting other people to such events falls within the customary norms.
✓ Partners should not apply the above rules also in relations with other entities.

8. Trade sanctions

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

✓ Business Partners may not establish contacts and cooperation with persons subject to trade sanctions.
✓ Business Partners agree to comply with all applicable international trade sanctions laws.

9. Conflict of interest

The DBK Group performs its tasks and duties impartially, avoids conflicts of interest so that personal interests do not conflict with professional duties. In this way, it makes decisions in the best interest of its customers and suppliers and increases their trust in the DBK Group. The DBK Group is politically neutral.

✓ Business Partners are required to report a potential 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 and confidential information as well as Business secrets.

✓ Business Partners are obliged to use and protect all information in an appropriate manner.
✓ Business Partners guarantee that confidential information and Business secrets of the DBK Group will be kept secret by their employees.

11. Personal data protection

The DBK Group complies with the applicable provisions on the protection of personal data 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, and does not make them available unreasonably. The DBK Group also respects the intellectual property of third parties.

✓ Business Partners are required to comply with intellectual property laws.
✓ Business Partners may not use, publish or disclose materials protected by applicable regulations and belonging to the DBK Group without authorization.
✓ Business Partners undertake to use the above-mentioned materials as authorized under the contract.

Checking a Business Partner

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 did not comply with the standards of Business ethics of the DBK Group.

Legal consequences of violating the rules and requirements of the Code

A Business Partner’s breach of the provisions of the Code may result in the termination of contracts concluded with him and the loss of Business contacts with the DBK Group in the future.