Anti-Corruption & Business Ethics Policy

1. Purpose

This Policy aims to prevent corruption, promote integrity, and ensure that Sorigo sp. z o.o. (“Company”) operates in compliance with applicable laws and ethical business standards.

2. Scope

This Policy applies to:

  • employees,
  • contractors,
  • business partners acting on behalf of the Company.

3. Zero Tolerance for Corruption

The Company applies a zero-tolerance approach to corruption.

The following is strictly prohibited:

  • offering, promising, or giving any undue benefit,
  • accepting such benefits,
  • influencing business or administrative decisions improperly.

This applies especially to interactions with:

  • clients,
  • business partners,
  • public officials.

4. Gifts and Hospitality

Only acceptable:

  • low-value gifts,
  • reasonable business hospitality,

provided that they:

  • do not influence decisions,
  • comply with applicable laws,
  • are transparent.

Prohibited:

  • cash or cash equivalents,
  • any benefit intended to gain improper advantage.

5. Payments and Commissions

All payments must be:

  • legitimate,
  • properly documented,
  • transparent.

Prohibited:

  • hidden commissions,
  • facilitation payments,
  • excessive intermediary fees.

6. Conflict of Interest

Individuals must avoid conflicts of interest.

Any potential conflict must be:

  • disclosed promptly,
  • properly managed.

7. Reporting Violations

Suspected violations can be reported to: compliance@sorigo.pl

The Company:

  • ensures confidentiality,
  • prohibits retaliation.

8. Accountability

Violations may result in:

  • disciplinary actions,
  • termination of cooperation,
  • legal consequences.

9. Training

The Company promotes awareness through:

  • internal communication,
  • training when necessary.

10. Final Provisions

This Policy is subject to periodic review.

Effective date: May 4, 2026
Version: 1.0