CODE OF CONDUCT

This Code of Conduct shall apply to all and any suppliers, subcontractors, agents and business partners involved in the provision of goods and/or services to Smyk S.A., with its registered office in Warsaw, Poland (“Smyk” or “We”). The abovementioned suppliers, subcontractors, agents and business partners involved in the provision of goods and/or services to Smyk shall hereinafter be referred to as “Suppliers".

Smyk is committed to conduct business with integrity, transparency and in compliance with all applicable laws and regulations and expects the same from its Suppliers. This Code of Conduct shall set forth the principles which govern the conduct of Suppliers, their subcontractors and other partners in their business dealings with Smyk.

Standards set forth herein have been based on the principles established in international human rights instruments and labour standards, such as: the United Nations Guiding Principles on Business and Human Rights, the International Labour Organization (ILO) Core Conventions, the Charter of Fundamental Rights of the European Union, the Treaty on the Functioning of the European Union and the Universal Declaration of Human Rights. Smyk expects Suppliers to respect the basic principles set out in the aforementioned documents.

Our Suppliers shall comply with this Code of Conduct, as well as any applicable laws, rules, and regulations.

Smyk expects Suppliers to comply with all applicable laws and regulations.

With respect to any processing of personal data of the officers, employees and customers of Smyk and other natural persons affiliated with Smyk, as the case may be, Suppliers and their subcontractors shall comply with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation”). They shall keep valid records to demonstrate such compliance, including relevant risk assessments, data protection impact assessments, policies, procedures and registries. These documents shall be available for inspection by Smyk or its representatives, upon request.

Additionally, Suppliers and their business partners shall implement technical and organisational measures required to ensure, for any relevant processing operation, that General Data Protection Regulation is adhered to (to safeguard the rights and freedoms of the data subjects), including in respect of the security of processing.

With respect to any processing of personal data of the Suppliers’ officers, employees, customers and other natural persons affiliated with Suppliers, as the case may be, Suppliers and their subcontractors shall adhere to all applicable laws and regulations, as well as industry standards and guidelines, subject to the right to privacy and right to personal data security.

With respect to any processing by Smyk of personal data of the Supplier’s officers, the Supplier shall provide such officers with the notice issued by Smyk under the “information obligation” defined in the General Data Protection Regulation.

Smyk does not accept any child labour and expects Suppliers not to use child labour. The term “child labour” refers to the economic activity performed by a person under the age of 15 (or under the minimum working age where the legislation in force in the territory sets that age at more than 15 years). The above does not limit the possibility of children being involved in artistic and/or advertising activities, under the conditions and within the limits of the applicable laws.

Smyk expects that employees (regardless of the type of contract under which they work) will receive fair remuneration for work performed. Smyk also expects that employees will receive any other employee benefits to which they are entitled under applicable legislation.

Employees’ working time should be managed responsibly and in accordance with local laws and international standards.

Smyk expects that Suppliers will consider the health and safety of employees (regardless of the type of contract under which they work) as a priority, and comply with applicable health and safety requirements.

Smyk does not accept any form of forced, bonded or involuntary labour.

Smyk supports promoting a diverse and inclusive work environment . All employees, regardless of the type of contract under which they work, should be treated with respect and dignity, and any form of discrimination, harassment, or abuse should not be tolerated.

Smyk supports the workers’ freedom of association and their right to collective bargaining in accordance with applicable laws. Suppliers shall respect the rights of workers in this regard.

Suppliers shall minimize the environmental impact of their activities and comply with all applicable environmental laws, rules, and regulations.

Suppliers shall respect animal welfare and adhere to relevant laws.

Suppliers shall ensure that all products which they supply to Smyk, as well as their manufacturing process, their packing and labelling are compliant with the requirements laid down in all applicable European Union laws and corresponding national laws.

Suppliers shall conduct their operations with the highest integrity and transparency, and shall not engage in any form of corruption, bribery, or other unethical practices.

The Supplier acknowledges and agrees that Smyk may from time to time require that they reaffirm this Code of Conduct or that Smyk can implement a new Code of Conduct that will supplant and replace this Code of Conduct.

This Code of Conduct has been issued in Polish and in English language versions. In case of any discrepancies, the Polish language version shall prevail.