1. Purpose, Scope of Activities and Business Description
Our Company conducts commercial activities in the field of wholesale trade and e-commerce.
The main areas of business include:
- wholesale trading of biomass products, in particular sunflower husk pellets and other solid biofuels,
- wholesale trading of feed materials and agricultural commodities,
- wholesale trading of fertilizers and related agricultural products,
- sale of various consumer and commercial goods through an online store,
- cooperation with domestic and international suppliers, distributors, and logistics partners.
Our Company operates in accordance with applicable national and international regulations governing trade, transport, environmental protection, food and feed safety, and product compliance.
Due to the nature of our activities, we recognize the importance of responsible sourcing, product quality, and supply chain integrity. We are committed to ensuring that all products traded by our Company:
- are legally sourced and compliant with applicable regulations,
- meet safety and quality requirements,
- are properly documented and traceable,
- comply with environmental and sustainability standards where applicable.
We conduct our business with a strong commitment to ethical conduct, transparency, and compliance with international standards, including regulations related to:
- trade and export controls,
- international sanctions,
- anti-money laundering and counter-terrorism financing,
- product safety and regulatory compliance,
- environmental responsibility,
- fair business practices.
This Code applies to:
- employees,
- Management
- contractors,
- subcontractors,
- business partners.
2. Compliance with Laws and Regulations
We comply with all applicable laws and regulations in the countries where we operate, including but not limited to:
- trade and customs regulations
- transport and logistics regulations
- environmental laws
- labor and employment laws
- data protection laws
- international sanctions and export control regulations
We cooperate fully with regulatory authorities and maintain accurate business records.
3. Anti-Bribery and Anti-Corruption
We maintain a zero-tolerance policy toward bribery and corruption.
We strictly prohibit:
- offering or accepting bribes
- facilitation payments
- kickbacks
- improper gifts or benefits
- corruption in any form
All employees and business partners must act with integrity and transparency.
Any suspected corruption must be reported immediately.
4. Anti-Money Laundering and Counter-Terrorism Financing (AML / CTF)
We do not participate in or support money laundering or terrorist financing.
We commit to:
- conducting due diligence on customers and partners
- verifying business counterparties
- monitoring suspicious transactions
- maintaining transaction records
We will not establish business relationships with entities involved in illegal financial activities.
5. International Sanctions and Export Controls
We comply with all applicable international sanctions and trade restrictions, including those issued by:
- the European Union (EU),
- the United Nations (UN),
- the United States (OFAC),
- the United Kingdom (UK).
We strictly prohibit:
- transactions with sanctioned entities
- transactions with prohibited countries
- circumvention of sanctions
All partners and customers may be subject to sanctions screening.
6. Conflict of Interest
Employees and management must avoid situations where personal interests conflict with the interests of the company.
Examples include:
- financial interest in a supplier or customer
- personal relationships affecting business decisions
- outside employment creating risk to company integrity
All conflicts of interest must be disclosed to management.
7. Gifts and Hospitality
Business gifts and hospitality may only be provided if they:
- are reasonable and proportionate
- have a legitimate business purpose
- do not influence decision-making
- comply with applicable laws
We prohibit:
- cash gifts
- excessive entertainment
- frequent gifts to the same party
- gifts intended to gain improper advantage
8. Insider Information and Market Conduct
We do not use confidential or non-public information for personal or business gain.
We strictly prohibit:
- insider trading
- market manipulation,
- misuse of confidential information,
- sharing sensitive commercial data.
All employees must protect confidential business information.
9. Business Communications and Record Keeping
All business communications must be:
- accurate,
- true,
- professional,
- documented, if required.
We maintain complete and accurate records of:
- contracts,
- transactions,
- invoices,
- transport documents,
- financial statements.
Falsification of records is strictly prohibited.
10. Whistleblowing and Reporting Misconduct
We encourage employees and partners to report any suspected:
- illegal activity,
- corruption,
- fraud,
- security breaches,
- unethical conduct.
Reports may be made confidentially.
We strictly prohibit retaliation against any person who reports misconduct in good faith.
11. Health and Safety
We are committed to providing a safe and healthy working environment.
We comply with:
- occupational health and safety regulations
- transport safety standards
- workplace safety procedures.
We continuously assess risks and implement preventive measures.
12. Environmental Responsibility
We operate in an environmentally responsible manner and aim to reduce our environmental impact.
We commit to:
- proper waste management,
- responsible fuel handling,
- pollution prevention,
- compliance with environmental regulations.
13. Labor Standards and Human Rights
We respect internationally recognized human rights.
We prohibit:
- child labor,
- forced labor,
- human trafficking,
- discrimination,
- molestowania.
We provide:
- fair remuneration,
- safe working conditions,
- equal employment opportunities.
14. Date Protection and Confidentiality
We protect personal and business data in accordance with applicable data protection laws.
We provide:
- secure storage of data,
- restricted access to sensitive information,
- confidentiality of customer and partner information.
Unauthorized disclosure of confidential information is prohibited.
15. Third-Party Due Diligence
Before entering into business relationships, we conduct reasonable due diligence on:
- clients,
- suppliers,
- subcontractors,
- business partners.
This includes verification of:
- verification of legal registration,
- determination of ownership structure,
- analysis of compliance history,
- sanctions screening,
- checking insolvency status and bankruptcy and restructuring proceedings,
- verification of counterparties in debtor registers and economic information databases, e.g., KRD, BIG, public registers,
- assessment of financial risk and the counterparty's ability to fulfill obligations.
16. Compliance Responsibility
Management is responsible for:
- implementation of this Code,
- monitoring compliance,
- organizing training,
- responding to violations.
All employees are responsible for following this Code.
17. Enforcement
Violation of this Code may result in:
- application of disciplinary measures,
- termination of contract,
- reporting the matter to the relevant authorities,
- taking legal action.
18. Acknowledgment
We confirm our commitment to comply with this Code of Conduct and to conduct business in an ethical and lawful manner.
19. Training and Awareness
The Company ensures that employees and relevant business partners are aware of this Code of Conduct and understand their responsibilities.
We commit to:
- providing periodic training on compliance, ethics, and legal obligations
- ensuring understanding of rules regarding corruption, sanctions, and security,
- promoting a culture of integrity and responsible decision-making.
Employees are expected to participate in mandatory training when required.
20. Monitoring, Audits and Continuous Improvement
The Company regularly reviews and monitors compliance with this Code of Conduct.
We may conduct:
- internal compliance controls,
- assessment of suppliers and partners,
- risk analysis,
- corrective actions.
We are committed to continuously improving our compliance systems and business practices.
21. Record Retention
The Company maintains business records in accordance with applicable legal and regulatory requirements.
Records are retained for appropriate periods and may include:
- contracts and commercial documents,
- financial and accounting documentation,
- transport and logistics documents,
- product and quality documentation,
- compliance documentation.
Records must not be destroyed, altered, or concealed in violation of legal obligations.
22. Supplier and Partner Compliance
The Company expects all suppliers, contractors, and business partners to comply with the principles set out in this Code of Conduct..
We reserve the right to:
- requests for declarations of conformity,
- conducting due diligence verification,
- suspension or termination of cooperation in case of serious violations,
- requiring corrective actions from partners.
Business partners may be required to confirm compliance with applicable laws, ethical standards, and international sanctions regulations.
23. Compliance Contact
Questions regarding this Code of Conduct or reports of suspected violations may be directed to:
Person responsible for regulatory compliance
E-mail: zefirtrade.info@gmail.com
Phone: +48 571 916 770
24. End of Code of Conduct
This Code of Conduct reflects our commitment to ethical business practices, legal compliance, and responsible conduct in all areas of our operations.
Change log
| Version | Date | Change description |
| 1.0. | 15.12.2023 | Document issuance |
| 1.1. | 05.06.2025 | Address data update |