CODE OF ETHICS

AND

BUSINESS CONDUCT

 Turka Invest Sp. z o.o.

 

Tarczyn, 1 June 2026

1. Introduction

Turka Invest Sp. z o.o. with its registered office in Tarczyn, address: Aleja Krakowska 10, 05-555 Tarczyn, entered into the register of entrepreneurs of the National Court Register kept by the District Court Lublin East in Lublin with its registered office in Świdnik, Commercial Division of the National Court Register under KRS number: 0000382428 (hereinafter referred to as: the “Company”) operates on the basis of the highest standards of integrity, responsibility and business ethics. The foundation of our operations is a culture based on trust, transparency and respect for the applicable law and the principles of social coexistence. We build relationships with customers, business partners, colleagues and all stakeholders by consistently making responsible and ethical decisions.

This Code of Ethics and Business Conduct (hereinafter referred to as the “Code”) sets out the values, standards and rules of conduct applicable in the Company. It is a set of guidelines that are followed by members of the Company’s governing bodies, management, employees, and all representatives acting on behalf of the Company.

The Code sets out the minimum ethical, social, environmental, health and safety and business requirements that the Company expects all of its suppliers, subcontractors, service providers and business partners to comply with.

The Company operates in the food industry, specializing in the production of flat bread and bakery products, in particular tortillas. In its activities, it is guided by the principles of responsible business, food safety, respect for human rights, commercial integrity and care for the natural environment.

This Code is intended to define the standards of conduct applicable to business cooperation, in particular in relations with suppliers and other entities involved in the supply chain, so that the activities of all parties are conducted in accordance with applicable law, the principles of business ethics and the expectations of customers, business partners and other stakeholders.

The Company is aware of the responsibility arising from operating in the global supply chain and takes actions to promote and enforce respect for human rights, labor standards and environmental protection rules.

The Company undertakes to conduct its business in an honest, reliable, transparent manner and in accordance with applicable law, ethical principles and good business practices. We believe that both the way we act and the decisions we make have a significant impact on building lasting relationships based on trust, responsibility and mutual respect.

The Company also expects its employees, associates, suppliers, contractors, distributors, business partners and all other entities related to the Company (including employees and associates of the Company’s subcontractors, suppliers or contractors) to comply with ethical standards in accordance with the principles set forth in this Code.

The Code aims to promote a culture of integrity and accountability, prevent fraud, and support lawful and ethical business conduct. It sets out the Company’s expectations towards employees and cooperating entities, as well as complements the Company’s policies, procedures and internal regulations, including those that may be implemented in the future.

You must comply with national and other binding laws and regulations of the place of business, as well as the rules set out in this Code. In the case of simultaneous application of different regulations, those provisions that provide the highest level of protection take precedence.

Any violation of the principles set forth in this Code will be treated as a violation of the applicable standards of conduct in the Company and may result in taking appropriate actions provided for by law and internal regulations of the Company.

 

This Code is an integral part of the process of qualification, assessment and periodic verification of all suppliers, subcontractors, service providers and business partners of the Company.

2. General rules

This Code defines the standards of conduct and principles that guide the Company in its operations. Its purpose is to ensure that all employees, associates, persons acting on behalf of the Company, as well as suppliers, contractors, distributors, business partners and all other entities related to the Company act in an honest, responsible, reliable and transparent manner.

The Code applies to all business partners cooperating with the Company, with particular emphasis on entities participating in the supply chain, including in particular:

• suppliers of agricultural and food raw materials, including flour, oils, fats, spices, flavourings and functional components,
• suppliers of unit and collective packaging,
• suppliers of food contact materials,
• suppliers of transport, warehousing and logistics services,
• suppliers of cleaning, security, and pest control services,
• temporary employment agencies,
• entities providing service outsourcing,
• suppliers of chemicals, detergents, disinfectants and technical products,
• suppliers of utilities, waste, environmental and technical services,
• contractors of investments, renovations, installations and construction and technical services.

The Company is committed to creating a working environment based on mutual respect, equality and respect for the dignity of every human being, regardless of race, nationality, ethnic origin, skin color, religion, age, gender, sexual orientation, marital status, family situation, disability or other characteristics protected by law.

All employees, associates, persons acting on behalf of the Company, suppliers, contractors, distributors, business partners and all other entities related to the Company are expected in particular to:

• perform the duties entrusted to them with due diligence, professionalism and commitment,
• use the Company’s assets and resources in accordance with their purpose,
• protection of confidential, sensitive information and data constituting a trade secret,
• comply with applicable laws, internal regulations, policies, procedures and rules applicable in the Company,
• promote a culture of safety, health protection and a responsible working environment,
• treat all persons with respect, dignity and in accordance with the principle of equal treatment,
• counteracting all manifestations of discrimination, mobbing, harassment, violence, intimidation and other behaviour that violates human dignity,
• creating and supporting a working environment free from prejudice, unequal treatment and exclusionary activities,
• conducting business in accordance with the principles of ethical business, honesty, transparency and social responsibility,
• supporting activities for sustainable development, including the rational use of resources, reducing the negative impact on the environment and promoting pro-ecological attitudes,
• taking care of the Company’s good name and reputation in internal and external contacts.

In addition, all suppliers, subcontractors, service providers and business partners of the  Company are obliged to apply the principles of this Code to their sub-suppliers, subcontractors and other entities involved in the performance of supplies or services to the Company.

The Code does not constitute an exhaustive set of rules relating to all possible legal and ethical situations that may arise, for example, during the performance of official duties or during the performance of entrusted tasks. Each person covered by the provisions of the Code should also apply other regulations, policies and procedures applicable to the Company, appropriate to a given area of activity.

In case of doubt regarding the interpretation or application of the provisions of the Code, any person covered by its provisions should consult with their supervisor, a representative of the human resources department or a person responsible within the Company for matters of compliance, ethics or reporting of violations.

Every employee, collaborator, person acting on behalf of the Company, supplier, contractor, distributor, business partner and other entity related to the Company is obliged to familiarize themselves with the provisions of this Code and comply with the rules contained therein. The Company also expects to promptly report any actual or potential conflicts of interest, as well as information regarding possible violations of the law, the Company’s internal regulations or the provisions of the Code.

Reports will be treated with due seriousness and without the risk of retaliation against the reporting person.

3. Standards of work

The Company conducts its business with respect for human rights, the principles of decent work and the highest ethical standards. We are guided by the provisions of the United Nations Universal Declaration of Human Rights, applicable labour laws and internationally recognised standards in the field of employment, safety and equal treatment.

We care about creating a work environment based on mutual respect, cooperation, responsibility and diversity. Our goal is to provide safe, fair and non-discriminatory working conditions for all employees and associates. We do not tolerate any form of unequal treatment, intimidation, violence, stalking, mobbing or harassment.

• Subcontractors and sub-suppliers

The Company expects its suppliers, subcontractors, service providers and business partners not to outsource production, services or supplies relevant to the Company to subcontractors without ensuring adequate supervision of their compliance with legal, quality, ethical, environmental and health and safety requirements.

The Company’s suppliers, service providers and business partners are responsible for ensuring that their sub-suppliers and subcontractors comply with standards equivalent to this Code.

• Human rights and employment practices

The Company is committed to conducting its business with respect for fundamental human rights and to adopting responsible employment practices.

In particular, the Company:

• employs only persons authorized to perform work in accordance with the applicable law,
• ensures equal opportunities in terms of employment, professional development, promotion, access to training and working conditions,
• makes personnel decisions solely on the basis of competences, experience, qualifications and business needs,
• supports the professional development of employees and creates opportunities for improving qualifications and acquiring new skills,
• respects the right of employees to express their opinions, dialogue and participate in organisations representing their interests,
• ensures the right to rest and complies with working time regulations,
• ensures remuneration paid on time and in accordance with applicable laws, contracts and adopted standards,
• ensures working conditions corresponding to the requirements of occupational health and safety,
• respects the privacy of employees and protects their personal data in accordance with applicable laws.

The Company does not engage in or tolerate any form of forced, slave, compulsory labor or human trafficking. The Company does not benefit from such practices and does not knowingly cooperate with entities that use them.

The Company’s suppliers, subcontractors, service providers and business partners may not use forced, compulsory or slave labour. Employees must be guaranteed the right to freely terminate their employment in accordance with applicable law and the terms of the contract.

It is prohibited to impose recruitment fees and employment-related costs on employees.

It is also unacceptable to keep identity documents, work permits, or collect any deposits as a condition of employment.

The Company’s suppliers, subcontractors, service providers and business partners are obliged to employ employees in accordance with the applicable law. Each employee should receive clear, understandable and lawful terms and conditions of employment, communicated in writing or in any other form required by law.

The Company’s suppliers, subcontractors, service providers and business partners are obliged to ensure the legality of employment of all their employees, including domestic and foreign employees, as well as temporary and seasonal workers and persons referred to work in the Company by temporary employment agencies.

Due diligence must be exercised to confirm that the Company’s suppliers, subcontractors, service providers and business partners employing employees are acting in accordance with the law and comply with workers’ rights.

The Company’s suppliers, subcontractors, service providers and business partners are obliged to comply with the applicable legal regulations concerning remuneration and working time, including the payment of remuneration at least at the minimum level specified by law, in a timely, transparent and documented manner. Employees should receive information regarding the components of remuneration, deductions, overtime, bonuses and benefits. Overtime work must be lawful, properly recorded and properly remunerated, and deductions from remuneration may only be made in accordance with applicable law.

• Human rights in the supply chain

The Company expects its suppliers, subcontractors, service providers and business partners to identify and mitigate the risk of human rights violations throughout the supply chain, especially in areas related to:

• seasonal work,
• migrant workers,
• agricultural raw materials,
• transport and warehousing services,
• production in high-risk countries or regions.

The Company’s suppliers, subcontractors, service providers and business partners should take measures to prevent forced labour, illegal employment, abuses against workers and violations of fundamental labour rights.

• Prohibition of child labour

The Company strongly opposes the exploitation of child labour and complies with the applicable regulations on the minimum age of employment.

We do not hire people under the minimum age required by applicable law, subject to exceptions provided for vocational training or legally permitted internships.

The Company’s suppliers, subcontractors, service providers and business partners are not permitted to employ children or use child labour in any area of their business or supply chain.

The minimum age of employment must comply with applicable laws and international labour standards. Juvenile workers, employed in accordance with the law, must not perform work that is dangerous, night, excessively burdensome or that could adversely affect their health, safety, education or development.

In the event of becoming aware of a possible violation of the rules concerning child labour, the Company takes appropriate investigative and protective actions, in particular:

• verifies the circumstances of the event,
• documents the findings,
• takes corrective and preventive actions,
• prioritizes the well-being and safety of the child,
• analyzes the compliance of activities, including within the supply chain and business partnerships.

The Company expects its suppliers, subcontractors, service providers and business partners implement appropriate procedures for verifying the age of employees and have corrective action mechanisms in place if cases of child labour are identified at any stage of the supply chain.

• Equality, diversity and non-discrimination

The Company provides a working environment free from discrimination and unequal treatment. We respect diversity and consider it an important value supporting the development of the Company.

We do not tolerate and strongly oppose all forms of discrimination based on:

• gender,
• age,
• race,
• nationality,
• ethnic or social origin,
• religion or worldview,
• sexual orientation,
• gender identity,
• marital or family status,
• disability,
• health condition,
• political views,
• any other characteristic protected by law.

All processes related to recruitment, employment, remuneration, job evaluation, promotion, training or termination of cooperation are carried out in the Company according to uniform and objective criteria.

The Company expects its suppliers, subcontractors, service providers and business partners to ensure equal treatment of employees and not to apply any form of discrimination in employment and employee relations, in accordance with applicable law.

The Company’s suppliers, subcontractors, service providers and business partners should respect the right of employees to associate, join workers’ organizations, engage in social dialogue and collective bargaining, in accordance with applicable law.

• Prohibition of harassment, mobbing and the use of any other forms of violence

Every person cooperating with or associated with the Company has the right to work in an environment free from mobbing, harassment, mental or physical violence and other behaviour that violates human dignity.

The Company does not accept and strongly opposes:

• intimidation, humiliation or degradation,
• verbal or physical aggression,
• persistent criticism or harassment,
• excluding an employee from the team or isolating them,
• dissemination of false or offensive information,
• using an advantage of service,
• sexual or psychological harassment,
• activities that violate personal rights or privacy.

Any violation of these rules should be reported immediately in accordance with the procedures in force at the Company or with the Company’s business partner.

The Company expects its suppliers, subcontractors, service providers and business partners to provide a working environment free from violence, threats, bullying, mobbing, harassment, intimidation and all forms of mistreatment of employees.

The Company’s suppliers, subcontractors, service providers and business partners should have mechanisms in place to report such cases and ensure that those reporting violations are not exposed to retaliation.

• Privacy and data protection

The Company respects the privacy of employees, associates, customers and business partners and is committed to the responsible processing of personal data.

In particular, the Company:

• collects and processes only the data necessary to conduct business,
• ensures appropriate measures to protect data and confidential information,
• restricts access to data only to authorized persons,
• complies with applicable laws on the protection of personal data and confidential information.
• Safety and health

The safety and health protection of employees and employees is one of the Company’s priorities. We strive to create a safe working environment and continuously improve occupational health and safety standards.

Each person performing work for the Company or cooperating with the Company is obliged, in particular, to:

• comply with occupational health and safety rules,
• report dangerous situations, defects and potential threats,
• promptly inform about accidents, injuries and incidents,
• perform work only within the scope of their competences and authorizations,
• participate in the required safety training,
• be familiar with emergency procedures and rules of crisis management,
• take care of their own physical and mental well-being while performing their duties.

The Company takes measures to prevent accidents at work and reduce risks that may affect the health, life and safety of people staying at the workplace.

The Company expects its suppliers, subcontractors, service providers and business partners to  provide employees, subcontractors and persons staying on the premises of the plant with a safe and hygienic working environment, as well as to identify hazards, assess occupational risks and implement appropriate preventive and protective measures, including personal protective equipment.

• OHS training

The Company expects its suppliers, subcontractors, service providers and business partners to provide employees with appropriate OHS trainings before starting work and periodically during employment. Trainings should be understandable to workers, including foreign, temporary and seasonal workers, and therefore conducted in a language that they understand, including the documents provided to such workers.

Trainings should include at least: safe work rules, operation of machinery, use of personal protective equipment, handling of emergency situations and fire protection.

• Machinery, equipment and infrastructure

The Company expects its suppliers, subcontractors, service providers and business partners to ensure that machinery, equipment and tools are safe, technically sound, properly maintained and compliant with applicable laws, as well as equipped with the required safeguards, markings and instructions for safe operation, as well as the required attestations and certificates.

• Personal protective equipment

The Company’s suppliers, subcontractors, service providers and business partners should provide employees with appropriate personal protective equipment – at no cost – required for a given job position. These equipment should be properly selected, efficient, available and used as intended.

• Accidents and emergencies

The Company expects its suppliers, subcontractors, service providers and business partners to implement procedures for dealing with accidents, including accidents at work, fire, leakage of hazardous substances, technical failures, evacuation and other emergencies. All accidents, incidents and near-misses should be recorded and analyzed, and corrective actions should be implemented to prevent their recurrence. The Company is entitled to verify in the above scope.

• Social conditions

 The Company requires suppliers, subcontractors, service providers and business partners to provide employees with access to drinking water, toilets, resting places, social facilities and first aid.

When providing accommodation, housing conditions should be safe, hygienic, in accordance with applicable laws and provide decent living conditions.

4. Ethical business

In its business relations, the Company is guided by the principles of honesty, transparency and responsibility. We comply with applicable laws, the principles of fair competition and antitrust regulations. We do not take any actions to gain a market advantage in an unfair or unlawful manner.

The Company does not enter into agreements with competitors, customers or suppliers that could affect the restriction of competition, price fixing, market sharing, customers or suppliers, or distort the results of tender procedures. The Company obtains information about competition only from legal and ethical sources. 

When cooperating with suppliers, contractors, distributors, business partners and other entities related to the Company:

• we act reliably and honestly,
• we take care of the transparency of the terms of cooperation,
• we select suppliers and contractors on the basis of objective economic, quality and legal criteria,
• we expect compliance with the principles of ethical principles and applicable laws,
• we protect confidential information and data provided to us,
• we respect cultural, worldview and religious diversity.

The Company strives to cooperate only with entities operating in accordance with the law and the standards of responsible and ethical business. Therefore, the Company expects suppliers, subcontractors, service providers and business partners to conduct their business in accordance with applicable laws and requirements relating to the products and services offered.

In particular, the Company expects its suppliers, subcontractors, service providers and business partners to have all legally required permits, registrations, certificates and administrative decisions necessary to conduct business and provide supplies and services to the Company.

In addition, the Company expects compliance with the provisions of this Code and the immediate implementation of appropriate corrective actions in the event of any non-compliance and reporting of the implemented solutions to the Company.

• Data protection and information security

We treat personal data protection and information security as one of the key elements of responsible and ethical business conduct. We collect, store, use and share personal data only in accordance with applicable law.

The Company protects both information constituting a trade secret and data provided to it by customers, suppliers and business partners. To this end, it implements appropriate organisational and technical measures, in particular:

• protection against loss or unauthorized access to data,
• control of access to systems and premises,
• solutions to protect against cyber threats,
• information security and business continuity management systems,
• activities to raise awareness of employees in the field of information security and personal data protection.

We expect the same standards in terms of information security, personal data protection, legal compliance and business ethics from our associates, suppliers, contractors and other business partners. We cooperate with entities that conduct their business in a responsible, transparent and compliant manner with applicable regulations, and respect the principles of confidentiality and protection of entrusted information.

Suppliers are obliged to protect confidential information, commercial and technical data, recipes, specifications, personal data and other information provided by the Company.

This information may be used only for the purpose of cooperation and may not be disclosed to third parties without the prior consent of the Company, unless the obligation to disclose it arises from the provisions of law.

• Documentation and transparency

The Company’s suppliers, subcontractors, service providers and business partners are obliged to keep reliable, complete and in accordance with the applicable provisions of law business, financial, quality, production, environmental and employee documentation.

It is prohibited to falsify documents, conceal information and in any way manipulate the results of inspections, certificates, laboratory analyses or records concerning production and delivery.

• Counteracting corruption, fraud, and money laundering

We do not accept any form of bribery, corruption, abuse, or actions that violate the law or principles of business ethics.

The Company strongly opposes:

• offering, giving, promising or accepting undue material or personal benefits,
• influencing business or administrative decisions in an unauthorised manner,
• using a relationship or position to achieve private gain.

Employees, associates, suppliers, contractors, distributors, business partners and other entities related to the Company are obliged to:

• not to give money or other benefits to representatives of public administrations, clients or business partners in order to obtain favorable decisions,
• not accepting material or personal benefits that may affect the impartiality of the decisions taken.

The Company does not provide any benefits to public officials or political entities. The Company does not finance political parties.

The Company also does not accept money laundering or terrorist financing activities. It does not engage in cooperation with entities suspected of conducting illegal activities or using funds from illegal sources.

The Company expects its suppliers, subcontractors, service providers and business partners to implement appropriate corruption prevention mechanisms and ensure effective procedures for responding to cases of breaches. The Company is entitled to verify in the above scope.

• Conflict of interest

A conflict of interest occurs when the private interest of an employee, associate or persons associated with him may influence or give the impression of influencing the objectivity of the business decisions made.

Employees and associates of the Company are obliged to avoid situations that may lead to conflict of interest and to immediately report such cases to their superiors, HR representatives or persons responsible within the Company for matters of compliance, ethics or reporting violations.

In particular, a conflict of interest may concern:

• family or personal relationships with customers, suppliers, competitors or associates,
• additional employment or competitive activity,
• equity shares and investments,
• the use the Company’s assets, information or resources for private purposes.

The Company’s assets and resources may only be used for their intended purpose and in a manner that does not violate the Company’s interests.

Suppliers, subcontractors, service providers and business partners are obliged to immediately inform the Company of any personal, financial or organizational ties that may affect the impartiality of business decisions.

• Intellectual property protection

We respect intellectual property rights and protect solutions created as part of the Company’s operations.

Intellectual property includes among other things:

• copyrights,
• trademarks,
• patents and industrial designs,
• know-how,
• software,
• documentation, marketing materials, and digital content.

Employees and associates of the Company use only legal software, materials and tools to which the Company has the appropriate rights or licenses.  Intellectual property created with the use of the Company’s resources is the property of the Company and is subject to appropriate protection.

We expect our suppliers, contractors and business partners to also only use legitimate software, materials and tools to which they have the appropriate rights, licenses or authorizations, and to respect the principles of intellectual property protection.

• Compliance with trade regulations and applicable sanctions

We comply with applicable laws governing controls on trade, import, export and international sanctions.

The Company’s suppliers, contractors and business partners are obliged to comply with the applicable provisions of economic and commercial law, including imposed economic sanctions, customs, export and import regulations and regulations on counteracting money laundering and terrorist financing.

It is prohibited to carry out supplies or services using entities, products, raw materials or transactions subject to applicable sanctions, if this would violate the provisions of law.

The Company does not undertake cooperation or transactions that violate applicable trade restrictions, embargoes or economic sanctions. We take care of the compliance of our activities with the requirements for export, import, customs and tax fees.

In case of doubts regarding the legality of the planned transaction or cooperation, the Company uses appropriate legal and expert support.

5. Sustainable development and environmental protection

The Company conducts its business in accordance with the principles of sustainable development, treating environmental protection as an integral element of the Company’s business responsibility and organizational culture. We are aware of the impact of our activities on the natural environment and take action to protect it and support permanent and sustainable development.

We carry out our services and business processes taking into account the requirements related to environmental protection, complying with applicable laws, standards and regulations concerning climate and environmental protection. We strive to minimize the negative impact of the Company’s operations by using responsible processes, procedures and practices that support the efficient use of resources and the reduction of pollution.

In its daily operations, the Company:

• rationally and economically uses natural resources, electricity, heating, water and consumables,
• takes actions aimed at reducing the amount of waste generated, its reuse and recycling,
• supports initiatives that reduce greenhouse gas emissions and reduce the negative impact on air quality,
• takes care of the proper organization of work and logistics, which allows to limit the number of business trips and trips to customers’ locations, which minimizes the amount of smog emitted,
• involves employees and associates in activities related to environmental protection and raising environmental awareness.

In the case of contact with chemicals, the rules of safe handling determine appropriate occupational health and safety procedures.

All employees and associates of the Company are obliged to comply with the applicable environmental protection rules, comply with the Company’s internal regulations and participate in activities and trainings to raise environmental awareness.

We also expect our suppliers, contractors and business partners to conduct their business in accordance with applicable environmental laws, principles of sustainable development, and the responsible use of natural resources, taking steps to reduce the negative impact of their operations on the natural environment.

The Company’s suppliers, subcontractors, service providers and business partners should have all legally required current permits, decisions, notifications and registrations related to their business. The Company is entitled to verify in the above scope.

• Minimizing environmental impact

 

The Company expects its suppliers, subcontractors, service providers and business partners to take actions aimed at reducing the negative impact on the environment, in particular by:

• rational consumption of energy and water,
• reducing greenhouse gas emissions,
• waste reduction,
• increasing the level of recycling,
• reducing the loss of raw materials and products,
• proper storage of chemicals,
• preventing leakage and pollution.
  
• Waste and packaging materials

Suppliers, subcontractors, service providers and business partners of the Company  should conduct waste management in accordance with the applicable law. Waste should be segregated, stored, transported and handed over only to authorized entities.

Packaging suppliers should strive to use materials that comply with legal requirements, as well as the requirements specified for contact with food, recyclable or responsibly sourced.

• Chemicals

The Company expects its suppliers, subcontractors, service providers and business partners to ensure safe storage, proper labelling and the correct use of chemicals. Safety data sheets should be up-to-date and accessible to employees.

Hazardous substances should be stored in a way that prevents leaks, contamination of products, environmental pollution and health risks to workers.

6. Products

The essence of the Company’s activity is the manufacture, sale and distribution of products that meet the applicable legal requirements, industry standards and the Company’s internal procedures in the field of quality and safety. We operate on the principle of continuous improvement, and we treat the development of our products and identifying and responding to market needs as an important element supporting the development of both domestic and international industry.

Guided by our responsibility towards our business partners and consumers, we make every effort to provide safe and high-quality products, in accordance with the highest market standards. We rigorously comply with applicable laws, industry requirements and the principles of our internal quality management system.

We regularly improve the qualifications of employees and associates through training and development activities, ensuring that we maintain a high level of competence in terms of quality, safety and compliance with applicable regulations is maintained. We care about the highest quality of the products and services we offer at every stage of our business.

We expect our suppliers, contractors, distributors, business partners and all other entities related  to the Company to be guided by the same principles, in particular in the areas of quality, safety, legal compliance and reliability in conducting business.

7. Knowledge and availability of the Code

Any person covered by this Code, including the Company’s employees, associates, contractors, business partners, suppliers and supply chain participants, is obliged to comply with it.

Violation of the provisions of the Code, knowingly making false statements, intentionally formulating false or malicious allegations or providing false information may result in the application of appropriate legal measures and sanctions. Depending on the nature of the relationship they may include, in particular: disciplinary actions, termination of employment, termination of commercial cooperation or other types of business relationship, as well as taking legal action in accordance with applicable law, including the Labor Code, the Company’s internal regulations and the regulations applicable to a given business partner.

Contractors, suppliers and representatives of the Company’s business partners must be aware that, in the event of any abuse or significant violations, their relationship with the Company may be terminated immediately.

The Company emphasizes that it is crucial to ensure that the principles set out in the Code are fully understood and complied with by all its addressees.

New employees, associates, contractors, suppliers and other business partners of the Company are obliged to familiarize themselves with the content of the Code as part of the process of employment or establishing cooperation with the Company, and its contents are discussed with them as needed.

The Code in electronic version is available to all employees, associates, suppliers and business partners on the Company’s website: www.turka.pl.

The Code has been drawn up in two language versions – Polish and English, and in the event of any discrepancy, the Polish version of the Code shall be decisive.

8. Reporting complaints and irregularities

Any person associated with the Company, including its employees, associates, contractors, business partners, suppliers and participants in the supply chain, has the right to report violations of the law, the principles of ethics or the provisions of this Code.

The company ensures that those who make reports are protected from any retaliation. Any form of retaliation against persons reporting irregularities or participating in an investigation is a serious breach of this Code. It is also prohibited to obstruct the making of reports, block them or put pressure on persons who report violations or irregularities.

All employees, associates, suppliers, contractors, business partners and participants in the supply chain are required to comply with the principles set out in the Code and to respond to any violations that are identified.

Reports may be made orally or in writing, and in justified cases also anonymously. A person who reports or witnesses a breach can use the following channels:

• directly to the supervisor,
• directly to the HR representative,
• to the person responsible for compliance, ethics or reporting issues in the Company – i.e. a compliance specialist,
• via a dedicated e-mail address – i.e. etyka@turka.pl,
• by correspondence to the address of the Company’s registered office – i.e. Turka Invest Sp. z o.o. with its registered office in Tarczyn, Aleja Krakowska 10, 05-555 Tarczyn,
• in the case of anonymous applications – via the application box located at all facilities.

The Company ensures the confidentiality of information relating to the reporting person and takes all reasonable steps to protect their identity. Reports made, even if they turn out to be unconfirmed, cannot constitute the basis for any repressive actions.

The protection of the whistleblower and persons participating in the investigation applies regardless of whether they are employees of the Company or belong to the group of business partners or participants in the supply chain.

The Company expects its suppliers, subcontractors, service providers and business partners to implement mechanisms enabling employees, associates and stakeholders to report violations of law, ethical principles, OHS, labor rights, environmental protection or food safety, including violations of this Code. These mechanisms should be accessible, confidential, understandable and provide protection against any retaliation.

9. Audits, evaluation and the right to verification

The Company reserves the right to verify the compliance of suppliers, subcontractors, service providers and business partners with this Code by among other things::

• conducting self-assessment surveys of suppliers, subcontractors, service providers and business partners,
• reviewing and verifying documents concerning and provided by suppliers, subcontractors, service providers and business partners,
• conducting an audit, announced or unannounced, remote or on-site, conducted by the Company or independent audit entities,
• requiring suppliers, subcontractors, service providers and business partners to present and implement corrective action plans.

The Company’s suppliers, subcontractors, service providers and business partners undertake to cooperate with the Company during audits, provide the required documentation, allow interviews with employees, associates and provide access to relevant areas of the plant, as long as this is in accordance with the law and safety rules.

10. Non-compliance and corrective actions

In the event of non-compliance with this Code suppliers, subcontractors, service providers and business partners are obliged to develop and implement a corrective action plan within the time frame agreed with the Company. These actions should be effective, documented and aimed at eliminating the causes of non-compliance and preventing their recurrence.

In the event of serious violations, such as among others, child labour, forced labour, endangering the life or health of employees, intentional falsification of documentation, corruption, significant food safety violations or serious violations of environmental law, the Company may take immediate actions, including suspension or blocking of supplies, termination of cooperation or reporting the matter to the competent authorities.

11. Continuous improvement

The Company expects its suppliers, subcontractors, service providers and business partners to take actions aimed at continuous improvement in the field of quality, food safety, working conditions, OHS, environmental protection, business ethics and responsible supply chain.

Suppliers, subcontractors, service providers and business partners should actively identify risks, implement preventive measures and develop management systems appropriate to the scale and nature of their business.

12. Confirmation of reading and acceptance of the Code

The condition for starting cooperation with the Company is the prior review and acceptance of the terms of this Code (Appendix No. 1 to the Code).

By signing the statement of reading and accepting this Code,  the supplier, subcontractor, service provider, business partner of the Company confirms that:

• they have read the content of the Code,
• accepts the content of the Code,
• undertakes to comply with the Code,
• will ensure that the obligations arising from the Code are communicated to its employees, subcontractors and subcontractors,
• will cooperate with the Company in verifying the compliance of actions with the Code and implementing possible corrective actions.

The Company may waive the requirement for formal acceptance of the Code in the case of one-time suppliers, low-risk suppliers, or administrative purchases, provided that they do not affect food safety, production continuity, working conditions, or the environment.

The Company has developed its own risk-based classification system for its suppliers, subcontractors, service providers, and business partners. This is an internal document that defines the scope of requirements based on the nature of the collaboration, the type of products or services provided, and their potential impact on food safety, production continuity, working conditions, the environment, and the Company’s reputation.

The scope of required actions regarding the Company’s suppliers, subcontractors, service providers, and business partners depends on the risk category assigned by the Company.

The Company requires suppliers, subcontractors, service providers, and business partners in the critical category – and, where applicable, the high-risk category – to submit a written statement (Appendix No. 1 to the Code), in accordance with the Company’s decision.

This approach is intended to ensure appropriate oversight while avoiding excessive administrative requirements for low-risk or one-time suppliers.

The Company determines the risk category.

For the Company’s suppliers, subcontractors, service providers, and business partners classified as low- or medium-risk, it is sufficient for the aforementioned entities to familiarize themselves with the content of the Code made available by the Company on its website or in another publicly accessible location, without the need to submit to the Company the statement constituting Appendix No. 1 to the Code.

__________________________

SADULLAH YALÇIN

President of the Management Board

of Turka Invest Sp. z o.o.