Business Partner Code of Conduct

ZPE ZAPEL S.A. strives to achieve the highest ethical and professional standards in its relationships with business partners. This Code of Conduct aims to establish the principles and values we expect from our business partners to ensure integrity, honesty, and mutual respect in our commercial relationships.

BUSINESS ETHICS

Our business partners are committed to complying with all applicable laws and regulations in the country in which they operate. They must adhere to criminal laws concerning corruption, which are applicable in each case, including the following principles:

• It is forbidden to offer, promise, or grant financial benefits directly or through intermediaries to public officials or political party representatives to obtain or retain a contract,
• Offering, promising, or granting material personal benefits in exchange for gaining privileged positions in professional relationships is prohibited. Demanding personal benefits in dealings with business partners is also prohibited,
• No employee should accept any benefits arising from business relationships with ZPE ZAPEL S.A. that, based on a reasonable assessment, may influence business decisions or transactions. Therefore, partner employees are not allowed to accept, promise any benefits to employees of ZPE ZAPEL S.A. Employees of the partner are also prohibited from accepting such benefits from employees of ZPE ZAPEL S.A.,
• Standard fair business practices and competition rules must be followed. Partners cannot act in ways that are or may be interpreted as unfair, restricting free competition, or involving abuse. All actions must comply with antitrust laws,
• Partners ensure compliance with all laws prohibiting money laundering or financing illegal transactions. Partners guarantee that they only do business with reputable business partners, operating legally using legal sources of funding,
• Any information and data shared within the collaboration are confidential and should be treated with due caution. Business partners commit to maintaining confidentiality regarding information provided by ZPE ZAPEL S.A.

LABOR RIGHTS

ZPE ZAPEL S.A. requires its business partners to respect the human rights of all employees and treat them with respect and dignity in accordance with international conventions:

• Partners reject all forms of forced labor. No employee should be forced to work through violence or intimidation. Only individuals who voluntarily consent to work may be employed,
• ZPE ZAPEL S.A. adheres to international legal regulations regarding child labor. It requires its partners to do the same in relation to children. This applies to all stages of production. The minimum employment age must be no lower than the legal age at which compulsory education ends in the respective country, or 15 years of age in any case. Partners are committed to following international conventions that prohibit or combat the worst forms of child labor,
• ZPE ZAPEL S.A. ensures that employee wages and benefits are fair and comply with applicable laws. It also ensures compliance with laws regulating working hours,
• ZPE ZAPEL S.A. does not discriminate against any employee or job applicant based on origin, gender, religion, or political beliefs. Partners are obligated, under applicable law, to combat all forms of discrimination and unequal treatment in employment,
• ZPE ZAPEL S.A. respects its employees’ right to privacy and data protection. Additionally, partners must ensure that all forms of collecting and storing personal data comply with applicable legal regulations.

HEALTH AND SAFETY

ZPE ZAPEL S.A. ensures safe and hygienic working conditions for its employees and takes measures to minimize health and safety risks at the workplace. Therefore, it expects its partners to comply with health and safety standards.

ENVIRONMENT

ZPE ZAPEL S.A. complies with environmental laws and international standards as well as customer requirements for environmental protection. The company has implemented an Environmental Management System to minimize the negative environmental impact of its operations.

Business partners are expected to comply with universally applicable environmental protection laws, adopt a systematic approach to reduce the negative impact of their operations on the environment, and strive for effective resource utilization, reduced emissions of pollutants, and minimized waste production.

The Code of Conduct serves as guidelines for all of ZPE ZAPEL S.A.’s business partners and is an integral part of our cooperation. By adhering to these principles, we are confident that we will achieve mutual success and build lasting, mutually beneficial business relationships.

Signed by the President of the Board, CEO

Mr. Roman Leśniak