1 | Purpose and Scope
MyRest Sp. z o.o. (“MyRest”, “the Company”) is committed to the highest standards of lawful and ethical conduct in all countries where we operate.
This Code of Business Ethics & Anti-Corruption Policy (“Policy”) applies to:
all employees, officers and directors of MyRest,
contract workers, interns and agency staff, and
any third parties acting on MyRest’s behalf, including consultants, distributors and sales agents.
2 | Zero-Tolerance for Bribery and Corruption
MyRest prohibits offering, promising, giving, requesting or accepting anything of value—directly or indirectly—to obtain or retain business advantage.
This Policy implements, at minimum, the requirements of:
U.S. Foreign Corrupt Practices Act (FCPA),
U.K. Bribery Act 2010,
EU Directive (EU) 2017/1371 on the fight against fraud, and
Polish Act on Counteracting Unfair Competition.
3 | Definitions
Government Official – any employee, candidate, or agent of a government body, state-owned enterprise, public international organisation, or political party.
Thing of value – cash, gifts, loans, travel, hospitality, services, offers of employment, charitable or political donations, insider information, or any other benefit.
4 | Gifts, Hospitality and Entertainment
Nominal value threshold: Employees may provide or accept routine promotional gifts or modest hospitality not exceeding €100 per recipient per calendar year.
Prohibited without prior written approval:
Any gift or hospitality for a Government Official.
Anything exceeding the nominal threshold.
Travel, accommodation, or per-diem expenses not directly related to a legitimate business purpose.
Requests for approval must be submitted to [email protected] and logged.
5 | Commissions, Fees and Discounts
Sales-related payments (commissions, success fees, referral bonuses, reseller discounts) may be made only when:
A written agreement exists, reviewed by the Finance and Compliance functions.
Due diligence on the payee has been completed and documented.
Payments are proportionate to legitimate services actually rendered.
6 | Charitable and Political Contributions
MyRest supports charitable giving but:
Contributions of company funds or resources require CEO approval and legal review.
Political donations are prohibited unless explicitly allowed by Polish law and approved by the Board.
7 | Third-Party Due Diligence
Before engaging any third party that may act on our behalf, MyRest will:
Conduct background checks for corruption, sanctions or reputational risks.
Require written acceptance of this Policy or an equivalent code.
Review the relationship at least annually.
8 | Books, Records and Internal Controls
All transactions must be accurately recorded in MyRest’s accounting system in accordance with Polish GAAP.
Creation of unrecorded, off-the-books accounts or false entries is strictly forbidden.
Finance shall maintain documentary evidence (invoices, contracts, approvals) for a minimum of 7 years.
9 | Reporting Concerns and Non-Retaliation
Suspected violations can be reported confidentially to [email protected] or in writing to the COO at the Warsaw headquarters.
MyRest will not tolerate retaliation against anyone who, in good faith, raises or supports a compliance concern.
10 | Investigations and Disciplinary Action
All credible allegations will be investigated promptly. Violations may result in measures up to and including:
termination of employment or contract,
cancellation of agreements, and
referral to competent authorities for criminal prosecution.
11 | Policy Governance
Owner: Chief Operating Officer.
Approved by: Chief Executive Officer.
Effective date: 1 June 2025
Next review: 1 June 2026 or earlier if required by law or business changes.
MyRest Sp. z o.o.
ul. Młynarska 8/12, 00-194 Warszawa, Poland
NIP: 6762554361 KRS: 0000747514 REGON: 381231313
Version 1.0, issued 1 June 2025