Fixykor code of business conduct

Code of business conduct

The way our employees work with each other, with our partners and with our customers — regardless of position — rests on the following principles:

• Integrity;
• Fair competition;
• Professional ethics;
• Mutual respect;
• Good faith;
• Accountability;
• Compliance with the law;
• Economic reasonableness.

Fair competition

Competition and antitrust laws exist to keep markets fair and to protect partners and customers from dishonest business practices.

Fair competition is a cornerstone of an open market economy. Observing competition law is a basic condition of how Fixykor operates and one of our core principles.

Unfair competition means any conduct in the market that runs contrary to honest commercial practice — actions that breach competition rules, harm the legitimate rights and interests of other market participants and disrupt economic order.

We want to grow in a market that follows the highest standards of doing business. Fixykor is committed to treating every existing and prospective partner fairly and on equal terms.

We always consider the legal requirements of the countries where our counterparties operate. Unfair competition and abuse of a dominant position are prohibited in our business, and we strictly observe the competition laws of every applicable jurisdiction, including those of the European Union and Poland. Our employees may not make unjustified negative statements about competitors’ products or services.

Trade compliance

We make sure that every import and export transaction complies with the laws and regulations of the countries involved and of the countries in which Fixykor operates, including EU dual-use and sanctions regulations.

Our trade compliance process assesses the risks associated with clients, products, services, the supply chain, intermediaries, counterparties, individual transactions and geographic destinations.

Two core operating practices of our trade compliance

• Customer due diligence and supplier screening against sanctions, restricted-party and denied-party lists, to make sure that no transaction benefits a sanctioned person, company or country.
• Compliant management of product-level import and export controls across our supply chain — knowing where goods are going, identifying high-risk jurisdictions and end users, and assessing payment terms, applicable legislation, tax and customs rules, export restrictions, sanctions, and the contractual risks related to transfer of title, loss and damage.

Zero tolerance for bribery, corruption and abuse of authority

Fixykor does not accept bribery, corruption or abuse of position in any form. We follow international principles on human rights, labour, the environment and anti-corruption, and we believe every business must actively oppose corruption, including extortion and bribery.

We recognise and observe international anti-corruption rules, including the UN Convention against Corruption, the OECD Anti-Bribery Convention, the US Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, the OFAC Framework for Compliance Commitments, EU anti-corruption legislation and the Polish Criminal Code.

Relationships with customers, suppliers and public authorities

Trust and honesty are the foundation of our relationships with partners and suppliers. When we select partners and suppliers, we make sure that they share our values and principles.

We owe our customers understanding, respect and expertise, and we always aim to meet their needs as well as possible within the limits of business ethics. We treat our suppliers in the same fair and impartial way.

We build relationships with business partners — customers, suppliers, contractors and consultants — on long-term cooperation, mutual benefit, respect, trust, honesty and fairness.

We work only with reliable partners engaged in lawful business. We meet our contractual obligations in good faith and expect the same in return. Disputes are resolved lawfully, with the aim of reaching a solution acceptable to both sides.

Confidentiality and data protection

Information and IT security are among our top priorities and core competencies. Our customers trust us with their infrastructure, so we hold ourselves to the highest security standards when processing company, customer and employee data — including protection against unauthorised access, misuse, loss and premature destruction.

In addition to the technical and organisational measures we apply, every employee is personally responsible for handling the personal data of customers, colleagues and suppliers carefully and confidentially.

We make sure that our internal data protection rules are consistently applied and regularly reviewed, in line with the EU General Data Protection Regulation (GDPR). Everyone has the right to know what categories and what volume of their data we process. We collect and process personal data only with the consent of the data subject, where permitted by law or where required to perform a contract — and only to the extent, for the period and for the purposes that are necessary. We fully respect the rights of the individuals whose data we process.

All employees are committed to protecting company data and business interests. Information from and about Fixykor is treated as confidential and is not disclosed without need. We never leave business documents, files or applications open and unattended — whether in the office or when working in public places.