Норми поведінки

CODE OF CONDUCT KONCEPT – L S.A. WITH ITS REGISTERED OFFICE IN WARSAW ("Code") valid from 28th of march 2023

§ 1 INTRODUCTION

1.1 Purpose of the code of conduct

This Code of Conduct is adopted at the Company to ensure that the Company conducts its business ethically, lawfully and in a spirit of mutual respect and trust. The Company respects internationally recognized human rights, and is careful to establish business relationships only with entities that share its aforementioned values.

1.2 Scope of regulations

As part of the Code, rules of conduct have been comprehensively implemented into the Company to ensure that the Company, including its managers and employees, respect ethical laws and values aimed at ensuring that the Company operates on the basis of the highest moral standards. Within the framework of the Code, regulations have been introduced for employees, contractors, environmental protection, personal data security and the handling of property values in the Company. The procedure outlines the principles of responsibility for non-compliance, as well as modes of carrying out relevant compliance activities.

§ 2 EMPLOYEES

2.1 Personal responsibility

All employees of the Company are required to comply with this Code. It is the responsibility of the Company's management to make the contents of this Code available to employees, to obligate employees to comply with it, and to set a good example for employees in implementing the principles and values of the Code.

2.2 Protection against discrimination

The Company is governed by the principles of tolerance and mutual respect. It is unacceptable to commit any acts of discrimination against the Company's employees. The Company promotes diversity in its team and is open to cooperation with employees and business partners representing different cultures, religions, world views or nationalities.

2.3 Health and safety protection at the workplace

The Company complies with national and international regulations regarding the protection of the health and safety of its employees. Among other things, the Company has appropriate procedures in place for occupational health and safety.

2.4 Fair working conditions

The Company complies with the labor standards set by the International Labor Organization. The terms and conditions agreed with employees comply with the law and ethical standards, including, among others, the minimum age of employees or the maximum number of working hours.

2.5 Conflict of interest

The Company recommends that employees avoid conflicts of interest. If they arise, employees should report such situations to their superiors so that the Company's interests are not compromised.

§ 3 CONTRACTORS

3.1 Selection of suppliers and service providers

It is categorically forbidden in the Company to favor or prevent any supplier. The Company shall conduct fair and objective evaluations of all bids submitted by suppliers. The evaluation, decision, award and execution of the contract must be transparent and must be based on strictly professional criteria. The Company requires that business partners respect the values listed in this Code. A breach on the part of a partner may lead to the termination of the business relationship.

3.2 Money laundering

The Company strictly complies with all anti-money laundering laws and regulations. The Company has implemented appropriate procedures to put in place adequate protective measures. The Company conducts business only with reputable customers within the framework of legitimate business and with funds obtained from legitimate sources. No employee is allowed to breach the laws and regulations on money laundering in the countries where the company operates.

3.3 Competition

The Company respects the principles of fair competition and supports all efforts to maintain a free market and open competition, both domestically and internationally. Thus, the Company will not implement any contract if it would violate applicable laws. The Company and its employees will not engage in illegal or fraudulent activities to gain access to, for example, trade secrets, customer lists, information about production facilities, technical developments or operational processes of competitors. The Company and its employees will not solicit or pay anyone to obtain confidential information or pressure employees or customers of competitors to disclose information that may be considered confidential. To avoid any misconduct or illegality, the Company directs its employees to avoid communicating with competitors regarding, among other things, pricing, production, marketing, inventory, product development, markets and sales targets, market analysis, and sensitive or confidential data.

3.4 Bribery and corruption

All employees of the Company are required to unconditionally comply with the principles of fair competition and act in accordance with the competition laws applicable to the regions of the world in which they conduct business. The Company does not tolerate bribery or corruption in any form, therefore, any activities related to giving or accepting promises, gifts or money from private or public persons in exchange for favors, financial benefits, illegal activities or other tangible or intangible benefits are strictly prohibited.

3.5 Gifts and benefits

The Company strictly prohibits its employees from requesting or accepting personal benefits, i.e., services or inappropriate invitations for themselves, other persons or institutions related to them. Accepting and offering gifts in the form of money is categorically prohibited. The Company permits the acceptance of customary and occasional gifts of low value and tokens of hospitality, provided that they comply with applicable laws. The Company instructs employees to ensure that all gifts offered are in accordance with the Company's values, and that their origin and method of manufacture do not breach elementary principles of ethics and respect for human rights. Each employee of the Company, when offering or accepting gifts or other gratuities, is required to act transparently, in accordance with Company policy, industry standards and applicable laws.

§ 4 PROPERTY VALUES

4.1 Protection of company values

Employees and associates of the Company, regardless of the basis of their employment, are required to protect the Company's tangible and intangible assets. Protection shall be provided for, among other things, the Company's property, know-how, intellectual property rights, as well as any information that is relevant from the perspective of the Company, including, in particular, information that constitutes a company secret or a trade secret of the Company.

4.2 Donations

The Company may make donations only under the terms and conditions set forth in its internal corporate documents, with the obligation to verify the entity to which the donation is made.

§ 5 ENVIRONMENTAL PROTECTION

In its operations, the Company complies with domestic and international regulations related to environmental protection. The Company's employees are required to perform their assigned duties in compliance with environmental protection and sustainability standards. If there are any obstacles to the above, employees should notify their superiors of their occurrence.

§ 6 FINAL PROVISIONS

6.1 Responsibility

Each employee of the Company is obligated to comply with the Code. Management should take measures to popularize the principles of this Code among the team, and support employees in implementing these regulations in the daily performance of their duties.

6.2 Violation of rules

Employees of the Company are required to report to their superiors any irregularities in compliance with this Code. The superiors are obliged to take adequate measures to eliminate these irregularities and to reliably observe the principles of this Code within the Company's structures.

6.3 Inspections and reporting

Compliance with the Code should be monitored periodically by the Company's management. Reporting any irregularities in the Company's operation of this Code is a desirable action by the Company. The Company provides whistleblowers with appropriate protection, resulting from, among other things, the provisions of law.