Introduction

Trimlogic is committed to conducting its business with the highest standards of ethics and integrity. This Business Ethics Policy outlines the principles and guidelines that govern the conduct of our employees and representatives in all aspects of business.

Compliance with Laws and Regulations

We are dedicated to complying with all applicable laws and regulations in the jurisdictions where we operate. Our employees must be aware of and adhere to local, national, and international laws that govern our business activities.

Ethical Decision-Making

Employees are expected to make ethical decisions in their day-to-day work. This includes acting with honesty, integrity, and fairness and avoiding conflicts of interest (look below).

If employees are uncertain about the ethical implications of a decision, they should seek guidance from their supervisor or the Board.

Fair Competition and Anti-Bribery

We are committed to fair competition and prohibit any form of bribery, corruption, or unethical business practices. Employees must not offer, give, receive, or solicit bribes, kickbacks, or any other improper payments.

Our organization is dedicated to maintaining transparent and ethical business relationships with customers, suppliers, and other stakeholders.

For more guidance look at: Trimlogic Code of Conduct

Conflict of Interest

Definition of Conflict of Interest

A conflict of interest arises when an individual’s personal, financial, or other interests could compromise their ability to act in the best interests of Trimlogic.

Conflicts of interest may include, but are not limited to, situations where an individual:

  • Stands to gain personally or financially from a decision made on behalf of the organization.

  • Has personal or familial relationships that may influence business decisions.

  • Holds a position or financial interest in an external organization that may conflict with the interests of Trimlogic.

Disclosure Obligation

All employees and representatives are required to disclose any actual or potential conflicts of interest to their supervisor promptly.

Disclosures should include details about the nature and extent of the conflict and any measures the individual proposes to manage or mitigate the conflict.

Review and Assessment

The designated conflicts of interest committee will review disclosed conflicts to determine the level of risk and potential impact on the organization.

In cases where a conflict is deemed to be significant, the organization may take further steps, including recusal, restructuring responsibilities, or implementing other measures to mitigate the conflict.

Recusal and Avoidance of Conflicts

Individuals with a conflict of interest may be required to recuse themselves from decision-making processes or activities affected by the conflict.

In situations where complete avoidance is not possible, the organization may implement safeguards or restrictions to manage the conflict appropriately.

Confidentiality

All disclosures and related discussions will be treated with the utmost confidentiality. Information about conflicts of interest will only be shared with those who have a legitimate need to know.

Annual Declarations

To ensure ongoing compliance, employees, officers, and representatives will be required to make annual declarations regarding any conflicts of interest.

Anti-Money Laundering

Trimlogic is committed to preventing money laundering and complying with all applicable Anti-Money Laundering (AML) laws and regulations.

Responsibilities

Designated AML Officer: Trimlogic will appoint a designated AML officer responsible for overseeing and implementing the AML program.

Employee Responsibilities: All employees are required to be aware of and comply with AML policies and procedures. Training will be provided to ensure employees understand their roles in preventing money laundering.

Customer Due Diligence (CDD)

Identification and Verification: Trimlogic will establish and maintain procedures for identifying and verifying the identity of customers in accordance with applicable laws and regulations.

Enhanced Due Diligence: Enhanced due diligence measures will be applied to higher-risk customers, transactions, and business relationships.

Monitoring and Reporting

Transaction Monitoring: Trimlogic will implement systems to monitor transactions for unusual or suspicious activities.

Reporting: Employees are required to report any suspicious transactions promptly to the designated AML officer.

Record Keeping

Trimlogic will maintain records of customer identification information, transaction data, and AML compliance efforts for the period required by applicable laws and regulations.

Communication and Reporting to Authorities

Trimlogic will communicate with relevant authorities as required by law and will promptly report any suspicious activities in accordance with applicable regulations.

Confidentiality

Information related to AML efforts, including reports of suspicious activities, will be treated with the utmost confidentiality and shared only with individuals who have a legitimate need to know.

Export Controls and Economic Sanctions

Trimlogic is committed to complying with all applicable export control laws and economic sanctions. This policy outlines the procedures and practices that the organization will follow to ensure compliance with these legal requirements.

Export Controls Compliance

Trimlogic will comply with the export control laws and regulations of all relevant jurisdictions, including but not limited to:

  • Dual-Use Regulation (EU) 2019/2199: This regulation controls the export, transit, and brokering of dual-use items (items that can have both civilian and military applications) within the EU.

  • Council Regulation (EC) No 428/2009: This regulation establishes a Community regime for the control of exports, transfer, brokering, and transit of dual-use items.

All employees involved in export activities must be aware of and comply with applicable export control laws and regulations. Training programs will be conducted to ensure understanding.

Economic Sanctions Compliance

Trimlogic will comply with economic sanctions imposed by relevant jurisdictions, including but not limited to:

  • United Nations (UN) Sanctions: Adherence to sanctions imposed by the UN Security Council.

  • European Union (EU) Sanctions: Complying with sanctions imposed by the EU.

All employees must be aware of and comply with applicable economic sanctions laws and regulations. Training programs will be conducted to ensure understanding.

Restricted Parties Screening

Trimlogic will implement a rigorous screening process to identify and screen against restricted parties, entities, and individuals as listed in relevant sanctions lists.

Licensing and Authorizations

No exports or transactions subject to export controls or economic sanctions shall proceed without the necessary licenses or authorizations from the relevant authorities.

Record Keeping

Trimlogic will maintain accurate and up-to-date records related to export control and economic sanctions compliance for the period required by applicable laws and regulations.

Reporting Obligations

Employees must promptly report any actual or potential violations of export controls or economic sanctions to the designated compliance officer. (Look at Trimlogic Compliance Procedure)

Confidentiality and Data Protection

Employees are responsible for safeguarding confidential information and respecting the privacy of individuals. Unauthorized disclosure of confidential information is strictly prohibited.

We comply with data protection laws and regulations, ensuring the lawful and ethical handling of personal information.

Workplace Respect and Diversity

Trimlogic values diversity and is committed to providing a workplace free from discrimination, harassment, and retaliation. We respect the dignity and rights of every individual.

All employees are expected to treat each other with respect, fairness, and consideration, fostering a collaborative and inclusive work environment.

For more guidance look at: Trimlogic Human Rights & Working Conditions Policy

Environmental Responsibility

We recognize the importance of environmental sustainability and commit to minimizing our environmental impact. Employees are encouraged to support environmentally friendly practices and initiatives.

For more guidance look at: Trimlogic Environmental Policy

Gifts and Entertainment

Accepting or offering gifts and entertainment should be in compliance with applicable laws and industry standards. Employees must avoid gifts that could influence or be perceived as influencing business decisions.

Reporting Violations, Whistleblowing and Protection Against Retaliation

Employees are encouraged to report any suspected violations of this Business Ethics Policy promptly. Concerns may include, but are not limited to, fraud, corruption, safety violations, harassment, discrimination, or any other unethical behavior.

Reporting mechanism

Reports can be made using the following mechanisms:

  • Directly to a supervisor or manager,

  • Utilizing Complaints Procedure (For more guidance look at: Trimlogic Complaints Procedure,

  • Sending anonymous mail to email: tell_trimlogic@trimlogic.pl

Protection Against Retaliation

Trimlogic strictly prohibits retaliation against any individual who, in good faith, reports concerns or participates in an investigation. Retaliation includes, but is not limited to, intimidation, harassment, discrimination, or adverse employment actions.

Employees who believe they are experiencing retaliation should report the matter promptly to Katarzyna Walenczak.

Investigation process

Reports of concerns will be promptly and thoroughly investigated. The investigation will be conducted impartially, protecting the confidentiality of the whistleblower to the extent allowed by law.

Trimlogic will take appropriate corrective action if wrongdoing is substantiated. Disciplinary actions against individuals involved in wrongful conduct will be determined based on the severity of the violation.

Confidentiality

While Trimlogic will make every effort to protect the confidentiality of the whistleblower, absolute confidentiality cannot be guaranteed. However, information will only be disclosed on a need-to-know basis.

False reports

Making false or malicious reports with the intent to harm someone’s reputation is a violation of this policy. Individuals found to be making false reports may be subject to disciplinary action.

Non-Retaliation Assurance

Trimlogic assures all employees that they will not face retaliation for reporting concerns in good faith. This assurance extends to individuals who cooperate in investigations.

Consequences of Violations

Violations of this Business Ethics Policy may result in disciplinary action, up to and including termination of employment. Legal action may be pursued if the violation involves criminal activities.

Training and Communication

Trimlogic will provide training on this Business Ethics Policy to ensure that all employees understand their responsibilities. Updates and communications related to business ethics will be periodically shared.

Review and Revision

This Business Ethics Policy will be reviewed periodically to ensure its continued relevance and effectiveness. Revisions will be made as necessary to address changes in laws, regulations, or business practices.