Last updated on September 1, 2025
1. INTRODUCTION
Burvix sp. z o.o., company incorporated under number 0001131882, having its registered address at ul. Żurawia 43, lok. 8a, 00-680 Warszawa, Republic of Poland (hereinafter – “Company”, “We”, “Our”), is committed to conducting business with honesty, integrity, and transparency. We maintain a zero-tolerance policy toward corruption, fraud, market abuse, or any other unlawful or unethical conduct.
This Whistleblower Policy (hereinafter – “Policy”) provides a safe and confidential channel for anyone to report concerns about potential misconduct related to Our business.
2. WHAT CAN BE REPORTED
We encourage reporting of any suspected misconduct, including but not limited to:
- bribery, kickbacks, or any form of corruption;
- fraud, misappropriation of funds, or other financial misconduct;
- market abuse, including insider trading or market manipulation;
- breaches of laws, regulations, or Our internal policies;
- serious unethical or improper behavior.
3. WHO CAN REPORT
Reports may be submitted by anyone – including employees, clients, business partners, and other third parties – who become aware of potential misconduct connected to Our business.
4. HOW TO REPORT
You can report concerns by sending an email to legal@burvix.io.
Reports may be submitted anonymously, although the Company encourages you to provide contact details to allow effective follow-up. Please use only Our official reporting channel – personal communication channels are not permitted.
5. CONFIDENTIALITY AND HANDLING
All reports will be reviewed independently and treated with strict confidentiality. We will not tolerate any retaliation against individuals who raise concerns in good faith. If misconduct is confirmed, the Company will take appropriate action in line with Our policies and applicable laws.
6. INVESTIGATION
The Company shall acknowledge receipt of the report within two (2) business days of receiving it, unless the report is submitted anonymously.
The Company aims to complete the investigation process within ten (10) business days from the date of acknowledgment. This includes conducting initial assessments, collecting relevant evidence, conducting interviews (where applicable), and preparing a written response.
Where the matter involves significant complexity, cross-border implications, or necessitates referral to external regulatory or enforcement authorities (e.g. KNF, or law enforcement), the investigation timeline may be extended. In such cases:
- the whistleblower shall be informed of the delay (unless anonymity prevents contact);
- the Company will aim to provide periodic status updates without compromising confidentiality or investigative integrity.
7. RECORD-KEEPING
The Company is responsible for maintaining centralized, secure storage of all documents related to internal policies and procedures.
All access to whistleblower-related records must follow “need-to-know” principles.
All records and associated materials shall be retained for a minimum of five (5) years, calculated from January 1st of the year following the final resolution or closure of the business relationship to which the documentation pertains. If requested by a competent authority before the expiry of this term, the retention period shall be extended up to seven (7) years. Retention beyond this period may be permitted or required in specific circumstances, such as pending litigation or investigations.
Records maintained under this Policy shall be made available:
- to competent authorities upon lawful request;
- to Clients, upon formal request, subject to confidentiality safeguards and applicable legal limits.
The Company commits to ensuring that its recordkeeping practices remain auditable, transparent, and aligned with all obligations arising from EU and Polish legal frameworks.
8. CHANGES TO THE POLICY
This Policy will be reviewed annually to ensure that it remains up to date with any regulatory, operational, or legal changes relevant to the scope of this Policy.
This Policy shall also be reviewed in case of material regulatory, structural, or operational changes or following findings from internal or external audits.