1.Purpose of the Policy
The purpose of this Anti-Corruption Policy is to ensure that Skrivanek sp. z o.o. conducts its business in accordance with the highest standards of integrity, transparency and compliance with applicable laws and regulations.
Skrivanek sp. z o.o. applies a zero-tolerance approach to corruption and any conduct that may be considered unethical or unlawful.
This Policy applies to all employees, contractors, subcontractors and all persons acting on behalf of or for the benefit of Skrivanek sp. z o.o.
2.Prohibition of Corruption
It is prohibited to offer, promise, give, request or accept any financial or personal benefit in order to obtain an improper business advantage or influence business decisions.
This prohibition applies to relationships with clients, suppliers, business partners, public institutions and also to internal relations between employees and contractors.
3.Gifts and Business Hospitality
Only gifts and hospitality of symbolic value that comply with applicable law and accepted business practices are permitted, provided that they do not influence impartial decision-making.
It is prohibited to offer or accept cash or cash equivalents, provide gifts in exchange for business advantages or finance private expenses of business partners or public officials.
In case of doubt, the matter should be consulted with a supervisor or the person responsible for compliance matters.
4.Conflict of Interest
Persons acting on behalf of Skrivanek sp. z o.o. are required to avoid situations in which private interests could influence business decisions.
Any actual or potential conflict of interest should be reported immediately to a supervisor.
Conflicts of interest may include in particular family or personal relationships with contractors, financial interests in competing businesses or the use of one’s position for personal gain.
5.Relations with Business Partners
Skrivanek sp. z o.o. cooperates only with partners conducting business in accordance with applicable law and ethical business standards.
Business partners are expected to comply with anti-corruption laws, operate transparently and avoid conduct that could expose the company to legal or reputational risks.
The company reserves the right to terminate cooperation in the event of corruption or serious ethical violations.
6.Relations with Public Officials
Relations with representatives of public administration require particularly high ethical standards.
It is prohibited to offer any benefits intended to influence official decisions, make facilitation payments or finance private expenses of public officials.
Meetings related to public tenders or procurement procedures should be conducted transparently and appropriately documented.
7.Record Keeping and Financial Transparency
All transactions and expenses must be properly documented, accurately recorded and compliant with applicable accounting regulations.
The creation of undisclosed funds, false documentation or undocumented payments is strictly prohibited.
8.Reporting Violations
Any person covered by this Policy is required to report suspected corruption, attempts to exert improper influence or violations of this Policy.
Reports may be made to a supervisor, the management board or the person responsible for compliance and ethics matters.
Skrivanek sp. z o.o. does not tolerate retaliation against persons reporting concerns in good faith.
9.Responsibility and Compliance
Every employee and contractor is responsible for familiarizing themselves with this Policy and complying with its provisions.
Violation of this Policy may result in disciplinary measures, termination of cooperation and civil or criminal liability in accordance with applicable law.
10.Final Provisions
This Policy enters into force on the date of publication and is subject to periodic review.
Skrivanek sp. z o.o. is committed to conducting its business in accordance with the principles of integrity, responsibility and transparency in all business relationships.
Published and effective as of: 18.05.2026
Agata Nowak, CEO