code of conduct

We are a trading company specializing in transactions in the food, feed, industrial chemistry and FMCG industries. Foodcom was founded in 2013 by the current CEO Aleksander Paciorkiewicz, whose mission was to create a place where ambition, motivation and diligence count. Guided by the principles described in this document, Foodcom has achieved a recognizable position on the international market.

Foodcom attaches particular importance to achieving the highest standards of social, ethical and environmental responsibility. We expect that as our Partner you will act in accordance with the provisions of this Code of Conduct, which defines the principles and standards of our business – ethically, honestly, with mutual respect and in accordance with applicable regulations. Therefore, we invite you to familiarize yourself with the content of the Code of Conduct, as failure to comply with its provisions may be grounds for terminating cooperation.

1. Legal Compliance

We expect our Partners to be aware of and comply with the laws that apply to them and their businesses, including, but not limited to, privacy laws, human trafficking laws, anti-corruption laws, antitrust laws, and environmental laws.

We also require our Partners to maintain complete records of their businesses to ensure that their businesses are in compliance with the law. In particular, we expect our Partners to:

• maintain books and records that reflect all transactions in an accurate, fair, and timely manner;
• have appropriate quality and compliance audit processes in place for matters such as product safety, food and feed safety, employee health and safety, and labor and employment.

We expect you to report any irregularities if you become aware of them, which allows Foodcom to better comply with applicable laws.

2. Respect for human rights

We require our Partners to respect human rights, in particular the provisions of the UN Universal Declaration of Human Rights, which include, among others, freedom of opinion and religion, equality and the prohibition of discrimination on any ground.

At the same time, Foodcom firmly states that it does not tolerate any complicity in violations of international humanitarian law and other crimes against the human person, including war crimes, crimes against humanity, genocide, torture, enforced disappearances, hostage-taking and extrajudicial, summary or arbitrary executions.

3. Working conditions and respect for workers‘ rights

We expect our Partners to comply with the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work and its Supplementary Actions, as well as the conventions covered by the aforementioned declaration.

Our Partners should treat their employees fairly and ensure that they are not subject to any form of harassment, discrimination or abuse in any form, including verbal, physical or sexual. Foodcom does not allow any form of humiliation, insults, sexual harassment or other forms of discrimination against employees based on race or other ethnicity, gender, religion or belief, disability, age or sexual identity. At the same time, we support diversity in the workplace and cooperation with employees and co-workers representing different cultures, ways of thinking or nationalities.

We require Partners to pay employees at least the minimum wage, including overtime, resulting from applicable national and international laws. Wages should be paid on time and no deductions from wages are allowed (except for those permitted by law).

We expect that agreed working hours will be respected and that employees will be provided with the required daily and weekly rest. We do not tolerate the use of forced labor, compulsory labor or child labor that is against the law.

Our Partners must respect the freedom of association and the right to collective bargaining of their employees.

We require Partners to provide a safe and healthy workplace for their employees, including compliance with health and safety regulations at work. If necessary due to the type of work performed, employees should be provided with appropriate protective clothing. We expect our Partners to apply appropriate internal procedures to achieve zero accidents at work, and each incident related to this will be subject to appropriate control, the findings of which will serve to further improve working conditions.

4. Environment

We are aware that our current business operations may sometimes impact the environment and we work to reduce the harmful effects that may result from this. We expect the same from our Partners.

We require our Partners to comply with all environmental laws and take actions to minimize environmental impacts, including in particular the effective and efficient use of natural resources and raw materials. We expect our Partners to reduce their environmental impacts through activities such as ending deforestation, minimizing greenhouse gas emissions and waste, and protecting water resources, using the least amount of water possible and avoiding water pollution. Our Partners should have procedures to identify, prevent, limit and correct harmful environmental impacts associated with their operations and supplies.

5. Protection of personal data and confidential information

In its activities, Foodcom recognizes how important it is to ensure the protection of personal data, as well as to ensure the confidentiality of confidential information, i.e. information that is not publicly available and concerns Foodcom, its employees, associates and Partners, is expressed in any form (including written, electronic, verbal, graphic) and concerns in particular trade secrets, trade information, ideas, discoveries, names of customers, suppliers, business associations, costs, revenues, any transactions or other financial agreements or contracts concluded.

Foodcom provides documentation on its website regarding the principles of processing, including sharing, personal data, which documentation takes into account the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (GDPR). We expect our Partners to comply with the above-described regulation, as well as with the relevant national regulations in order to ensure the protection of personal data to a degree at least appropriate for Foodcom. The procedures used by Foodcom allow access to personal data only to the extent necessary and only to authorized persons, while at the same time ensuring that the processing of personal data is subject to the application of appropriate security measures against unauthorized access.

All confidential information concerning Foodcom must be protected and may not be transferred to third parties (within legal limits) without prior written consent, unless the obligation to disclose confidential information results from generally applicable legal provisions. This also applies to intellectual property rights. Foodcom requires its employees and associates to keep confidential information secret. We require our Partners to act and protect confidential information received from Foodcom in the same way as Foodcom does with it.

6. Fair competition

Foodcom cooperates with Partners who share our desire to build business relationships. This requires honest communication, mutual responses and fulfillment of commitments, so we expect our Partners to honor business commitments and manage unexpected events in a proactive, timely and open manner.

At the same time, we require that cooperation with Partners is based on the principles of fair competition, so we expect compliance with all applicable national and international laws regulating fair competition and antitrust.

We also expect our Partners to respect sanctions imposed by international organizations and relevant national laws in this area.

7. Prevention of corruption and bribery

Foodcom takes the position that bribery and corruption, as well as blackmail or illegal business transactions (in particular, insider trading, money laundering) are unacceptable and must be actively combated in any form. Therefore, Foodcom never offers or accepts bribes, kickbacks, inappropriate gifts or other improper incentives in connection with its activities. At the same time, employees and associates of the Foodcom Company are obliged to avoid any potential conflicts of interest regarding financial interests or other arrangements that could be considered inappropriate.

In connection with the above, we expect our Partners not to engage in any form of illegal corruption, bribery or extortion, whether in relation to public authorities and officials, in relation to their business partners or in relation to third parties. Employees of Partners – whether on their own behalf or on behalf of their employers – may not accept or offer any kind of free indirect or indirect benefits that are or may be intended to promote illegal activities.

8. Product Safety

Due to the nature of the business conducted by Foodcom, we give priority to the safety of the goods in our offer. Products supplied by Foodcom must meet all reasonable expectations of Partners and end users in terms of product safety, compliance with applicable regulations or safety standards.

In connection with the above, we require our Partners to also make every effort to provide a safe product that meets all standards and complies with regulations. In particular, we expect appropriate testing and quality assurance of the product. In the event of an actual problem, or knowledge of a potential problem with the quality or safety of the product, we require that Foodcom be immediately informed and actions taken to minimize, eliminate or prevent such problems.

9. Changes

The application of this Foodcom Code of Conduct is subject to continuous monitoring and enforcement. In connection with the above, its provisions may be subject to changes, and we will inform you about all updates on an ongoing basis. In addition, to familiarize yourself with the latest version of the Code of Conduct, we invite you to visit our website https://foodcom.pl/.

Taking into account the above principles, Foodcom will evaluate its Partners in terms of meeting the requirements resulting from this Code of Conduct. Foodcom reserves the right to conduct audits of Partners and request information and documentation from Partners in order to verify compliance, including information on production and sources of supplied raw materials and goods. At the same time, we are committed to sharing best practices in the field of sustainable development, environmental practices and human rights in the workplace.