Compliance

Supplier Code of Conduct.

Standards of ethics, data protection, human rights and environmental protection that we expect from suppliers of goods and services cooperating with Zwyrtek Group.

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Introduction

This Supplier Code of Conduct (the “Code”) sets out the standards and expectations applicable to all suppliers of goods and services cooperating with the entities forming Zwyrtek Group.

Zwyrtek Group is understood to mean the following Joint Controllers:

Zwyrtek Tax & Legal sp.k.
Zwyrtek Business Services sp. z o.o.
Zwyrtek Advisory sp. z o.o.
Zwyrtek Digital sp. z o.o.
Michał Zwyrtek

At Zwyrtek Group, we believe that the foundation of success is honesty, professionalism and mutual respect. We expect our Suppliers to share these values and to comply with the principles described below.

Business ethics and integrity

1.1

Anti-corruption

Suppliers must maintain zero tolerance for any form of corruption, bribery, extortion and embezzlement. It is prohibited to offer employees or contractors of Zwyrtek Group any pecuniary or personal benefits in order to obtain preferential treatment.

1.2

Gifts and hospitality

The exchange of gifts of a symbolic nature is permissible only where it is consistent with local law, is occasional in nature and does not affect the objectivity of business decisions. Suppliers should not offer gifts that could be regarded as an attempt to exert improper influence.

1.3

Conflicts of interest

Suppliers are required to avoid situations in which their personal or financial interests could conflict with the interests of Zwyrtek Group. Any family ties or close personal relationships with Zwyrtek Group employees who influence the procurement process must be disclosed before cooperation commences.

1.4

Fair competition

Suppliers must act in accordance with competition and consumer protection laws, avoiding practices such as price collusion or unfair market restriction.

Information security and data protection

2.2

Confidentiality

Suppliers are required to keep strictly confidential all confidential information obtained during the cooperation, including professional secrets (legal professional privilege, tax adviser confidentiality) and the group's know-how.

2.3

IT security

Suppliers providing digital services or having access to Zwyrtek Group's systems must apply adequate technical and organisational measures (encryption, SSL certificates, multi-factor authentication) to prevent security incidents.

Labour standards and human rights

3.1

Voluntary labour and children's rights

The use of forced labour, slave labour and child labour is strictly prohibited. Suppliers must comply with the minimum employment age set out by national law and ILO conventions.

3.2

Equal treatment and non-discrimination

We expect Suppliers to provide a work environment free from harassment and discrimination on the basis of sex, age, disability, race, religion, sexual orientation or political beliefs.

3.3

Working conditions and remuneration

Suppliers must provide remuneration in accordance with applicable minimum wage laws and comply with working time regulations and occupational health and safety standards.

Environmental protection

4.1

Sustainable development

Suppliers should strive to minimise their carbon footprint, reduce paper use (preferring electronic communication) and manage waste effectively, particularly with regard to electronic equipment (e-waste).

Compliance and verification

5.1

Supplier's responsibility

The Supplier is responsible for ensuring that its sub-suppliers also act in accordance with standards comparable to this Code.

5.2

Audit and reporting

Zwyrtek Group reserves the right to verify the Supplier's compliance with this Code (e.g. through questionnaires or audits).

5.3

Reporting irregularities

Suppliers and their employees may report any suspected breach of this Code directly to: kontakt@zwyrtek.pl. We guarantee confidentiality and the absence of retaliation against persons reporting breaches in good faith.

Closing provisions

Compliance with this Code is an integral part of cooperation with Zwyrtek Group. Serious or repeated breaches of the Code's principles may constitute grounds for termination of the contract and the ending of the business relationship.

Approved by the Management Board of Zwyrtek Group.
Katowice, April 2026