Legal document

Complaints Policy

Operator: FIRSTSTONE TRADING sp. z o.o.
Version: 2.0
Effective date: 2026-06-06
Last updated: 2026-08-09
Language: Polish
Legal contact: compliance@purepoint.pl

Store Operator: FIRSTSTONE TRADING spółka z ograniczoną odpowiedzialnością (abbreviation: FIRSTSTONE TRADING sp. z o.o.) KRS: 0001254766 | NIP: 7831958614 Registry court: District Court Poznań – Nowe Miasto i Wilda in Poznań, 8th Commercial Division of the National Court Register (KRS) Date of registration: 17 February 2026 Registered office (KRS): ul. Wierzbięcice 44A/40A, 61-568 Poznań, województwo wielkopolskie Voivodeship Correspondence / Store service address: ul. Wierzbięcice 44A/40A, 61-568 Poznań (100 shares of PLN 50 each), fully paid up Representation: Krystian Dawidowski — Member of the Management Board (sole management board, independent representation) Complaints email: compliance@purepoint.pl | Registry email: k2benterprise.biz@gmail.com e-Delivery address (ADE): AE:PL-21312-60691-FGBFV-19 Store domain: purepoint.pl

Version: 2.0 Effective date: 6 June 2026 Status: In force

General provisions and definitions
Statutory warranty for physical and legal defects (Art. 556–576 of the Civil Code)
Exclusion of the statutory warranty in B2B trade (Art. 558 § 1 of the Civil Code); retention of the regime for consumers and persons holding consumer rights (PnPK)
Non-conformity of a Product batch with the Certificate of Analysis (COA) as a defect
Complaint submission procedure (form, documentation, notification deadlines)
Ladder of remedies for the consumer and PnPK (replacement, repair, price reduction, withdrawal — Art. 560–561 of the Civil Code)
Time limits for examining complaints (Art. 561(5) of the Civil Code; Operator’s declaration in B2B trade)
Independent verification of Product quality (PCA-accredited laboratory)
Out-of-court dispute resolution methods: ADR, ODR platform, WSIH, RPK
Bibliography
Change history
Final clause

§ 1. General provisions and definitions

This Complaints Policy (hereinafter: the “Policy“) sets out the rules and procedure for examining complaints under the statutory warranty for physical and legal defects of Products offered in the online Store under the domain purepoint.pl (hereinafter: the “Store“), operated by FIRSTSTONE TRADING sp. z o.o. (hereinafter: the “Operator“).
The Policy forms an integral part of the legal relationship between the Operator and the Qualified Buyer and should be read together with the Store Terms and Conditions, the Privacy Policy, the Returns Policy and the Compliance Policy.
The Store is operated solely under a B2B/B2Pro model — addressed to Qualified Buyers within the meaning of the Terms and Conditions (natural persons, legal persons or organisational units acquiring Products for a purpose connected with their business, professional, research or academic activity within the meaning of Art. 43(1) of the Act of 23 April 1964 — the Civil Code, consolidated text: Journal of Laws 2024, item 1061, as amended, hereinafter: the “KC“), with the exclusion of consumers within the meaning of Art. 22(1) of the Civil Code.
Notwithstanding the B2B model, the Operator — in the interest of transparency and a high compliance standard — also describes in this Policy the rights that would be available to consumers and to natural persons concluding a contract directly connected with their business activity where it follows from the content of that contract that it is not of a professional nature for them (hereinafter: “PnPK” — Entrepreneur Holding Consumer Rights; Art. 385(5), 556(4), 556(5), 576(5) of the Civil Code and Art. 38a of the Consumer Rights Act).
Definitions used in this Policy: a) Product / Research Material — a movable item sold by the Operator via the Store (a lyophilised peptide in a vial, bacteriostatic water, laboratory accessories), marked with an individual batch number (LOT) and covered by a Certificate of Analysis (COA); b) Defect — a physical or legal defect within the meaning of Art. 556(1) and 556(3) of the Civil Code; c) Physical defect — non-conformity of the Product with the Contract, in particular where the Product does not possess the properties declared by the Operator (including the purity declared in the COA), is not fit for the research purpose of which the Operator was informed, was delivered in an incomplete state or in inadequate packaging protecting against degradation; d) COA (Certificate of Analysis) — the Certificate of Analysis of a Product batch issued by the manufacturer or an independent laboratory, documenting the identity of the substance (HPLC), purity (typically ≥ 98%), net weight, moisture content, and the LOT production and expiry date; e) LOT / Batch — a distinct production series of Research Material covered by a single common COA; f) Qualified Buyer — an entity referred to in § 1 para. 3 above; g) Complaint — a statement made by the Buyer to the Operator in which the Buyer notifies of an established Defect of the Product and demands the exercise of the rights provided for in this Policy or in the provisions of the Civil Code; h) UPK — the Act of 30 May 2014 on consumer rights (consolidated text: Journal of Laws 2024, item 1796, as amended).

§ 2. Statutory warranty for physical and legal defects (Art. 556–576 of the Civil Code)

The Operator shall be liable to the Buyer if the Product sold has a physical or legal Defect, on the terms set out in Art. 556–576 of the Civil Code, subject to the reservations arising from § 3 of this Policy (exclusion of the statutory warranty in B2B trade).
Pursuant to Art. 556(1) § 1 of the Civil Code: “A physical defect consists in the non-conformity of the item sold with the contract. In particular, the item sold is non-conforming with the contract if: (1) it does not possess the properties that an item of that kind should have in view of the purpose specified in the contract or arising from the circumstances or its intended use; (2) it does not possess the properties of whose existence the seller assured the buyer, including by presenting a sample or specimen; (3) it is not fit for the purpose of which the buyer informed the seller at the time of concluding the contract, and the seller did not raise any objection as to such intended use; (4) it was delivered to the buyer in an incomplete state.”
A legal defect (Art. 556(3) of the Civil Code) arises where the Product is the property of a third party, is encumbered with the right of a third party, or where a restriction on the use or disposal of the Product results from a decision of a competent authority.
The Operator declares that the Products are original, originate from verified manufacturers, and that each batch is covered by a current COA available to the Buyer no later than at the time of delivery of the Product.

§ 3. Exclusion of the statutory warranty in B2B trade (Art. 558 § 1 of the Civil Code); retention of the regime for consumers and PnPK

Pursuant to the first sentence of Art. 558 § 1 of the Civil Code, the Operator excludes liability under the statutory warranty in relation to Qualified Buyers being entrepreneurs acquiring Products in direct connection with their business or professional activity of a professional nature (B2B). The exclusion covers all claims under the statutory warranty, including the rights referred to in Art. 560 and 561 of the Civil Code.
The exclusion referred to in para. 1 does not cover cases in which the Operator fraudulently concealed the defect from the Buyer (Art. 558 § 2 of the Civil Code) — in such situations the B2B Buyer retains the full range of claims under the statutory warranty.
The exclusion of the statutory warranty DOES NOT APPLY to: a) Buyers being consumers within the meaning of Art. 22(1) of the Civil Code (the Store formally excludes them, but should a given relationship be deemed consumer in nature, the Operator will not invoke the exclusion under Art. 558 § 1 of the Civil Code); b) PnPK (natural persons concluding a contract directly connected with their business activity where it follows from the content of that contract that it is not of a professional nature for them — Art. 556(4) of the Civil Code in conjunction with Art. 38a of the UPK).
In relation to the entities indicated in para. 3 above, the provisions of Art. 556–576 of the Civil Code and, to the relevant extent, the provisions of the UPK shall apply in full.
Notwithstanding the exclusion of the statutory warranty in B2B trade, the Operator, in good faith, introduces a batch quality guarantee (LOT-Quality Guarantee) — if, as a result of objective, independent laboratory verification, it turns out that a Product batch does not conform to the COA declarations (e.g. purity lower by more than 2 percentage points than declared, incorrect substance identity), the Operator undertakes to replace the Product or refund the price — details in § 4 and § 8 below.

§ 4. Non-conformity of a Product batch with the COA as a Defect

The Operator recognises as a physical Defect within the meaning of Art. 556(1) § 1 point 2 of the Civil Code a situation in which the actual parameters of a Product batch (LOT) deviate materially from the parameters declared in the Certificate of Analysis (COA) attached to that batch.
A material non-conformity is deemed to include, in particular: a) a deviation of the purity confirmed by HPLC by more than 2 percentage points downward relative to the value declared in the COA (e.g. COA = 99.2%, independent laboratory measurement = 96.5% or less); b) non-conformity of the substance identity confirmed by HPLC and/or mass spectrometry — a substance other than the one declared; c) a net weight lower by more than 5% relative to that declared (taking into account the standard measurement uncertainty of the lyophilisate); d) residual moisture exceeding the maximum level permitted by the batch specification (typically ≤ 5%); e) detection of microbiological contamination or endotoxins above the limits declared in the COA for the given batch class.
Minor deviations within the bounds of the measurement method’s uncertainty (typically ± 0.5–1 percentage point for HPLC) do not constitute a Defect within the meaning of this section.
In the event of a notification of non-conformity with the COA, the Operator carries out verification in the manner set out in § 8 (an independent laboratory accredited by the Polish Centre for Accreditation).

§ 5. Complaint submission procedure

A complaint should be submitted in one of the following forms: a) electronically — via the complaint form available in the Buyer’s order service panel or by e-mail to compliance@purepoint.pl; b) in writing — to the Store service correspondence address: FIRSTSTONE TRADING sp. z o.o., ul. Wierzbięcice 44A/40A, 61-568 Poznań; c) via e-Delivery — to the Operator’s ADE: AE:PL-21312-60691-FGBFV-19.
The complaint submission should contain: a) the Buyer’s first name and surname or business name and contact details (e-mail, telephone — if available); b) the order number and the date of purchase; c) the LOT/batch number of the Product complained of (placed on the vial label and visible in the COA); d) a description of the Defect (e.g. deviation from the COA, physical damage, missing component, packaging non-conformity); e) the circumstances and the moment the Defect was established; f) the complaint request (replacement, price reduction, withdrawal from the contract, etc. — to the extent permissible for the given Buyer status in accordance with § 3 and § 6); g) documentation evidencing the Defect — photographs of the outer packaging, the label, the vial, the seal; in the case of submissions concerning non-conformity with the COA — if the Buyer holds their own analytical measurement result, we request that it be attached (this is not a mandatory condition).
Time limit for notifying of the Defect: a) Consumers and PnPK (the statutory warranty regime retained): pursuant to Art. 568 § 1 of the Civil Code, the seller shall be liable under the statutory warranty if a physical Defect is established before the expiry of two years from the day of delivery of the item. Pursuant to Art. 568 § 3 of the Civil Code, a claim for the removal of the defect or the replacement of the item with one free from defects becomes time-barred upon the expiry of one year, counting from the day the defect was established — provided, however, that the running of the limitation period may not end before the expiry of the time limits set out in § 1. b) Consumers and PnPK should notify the Operator of the established Defect within 14 days of the day it was established — this time limit is of an instructional nature and its non-observance does not result in the loss of rights under the statutory warranty, but facilitates the examination of the matter. c) B2B Buyers (covered by the exclusion of the statutory warranty under Art. 558 § 1 of the Civil Code) may submit complaints under the LOT-Quality Guarantee referred to in § 3 para. 5 within 30 calendar days of the day the shipment is received, provided that, for submissions concerning hidden defects confirmed analytically, the time limit runs from the day on which the Buyer could objectively have established the Defect (but no later than 90 days from the date of delivery).
The Operator confirms receipt of the complaint submission by electronic mail within 3 business days of the date of receipt, assigning the submission an individual RMA number.

§ 6. Ladder of remedies for the consumer and PnPK (Art. 560–561 of the Civil Code)

To the extent that this Policy applies to consumers or PnPK, the Buyer has the following rights under the statutory warranty (Art. 560 and 561 of the Civil Code): a) a demand for replacement of the Product with one free from Defects or for removal of the Defect (repair) — pursuant to Art. 561 § 1 of the Civil Code: “If the item sold has a defect, the buyer may demand replacement of the item with one free from defects or removal of the defect.”; b) a statement of price reduction — in the proportion in which the value of the Product with the Defect remains relative to the value of the Product without the Defect (Art. 560 § 3 of the Civil Code); c) a statement of withdrawal from the contract — unless the Defect is immaterial (Art. 560 § 4 of the Civil Code).
The Operator may propose to the Buyer an alternative solution (e.g. replacement instead of repair) if the Buyer’s demand is impossible to fulfil or would require excessive costs; in such a case Art. 560 § 1 and § 2 of the Civil Code shall apply.
Owing to the specific, single-use nature of the Products (lyophilised peptides in single-use vials, secured with a seal, susceptible to degradation once the packaging is breached), the realistic path of exercising the statutory warranty in practice comes down to replacement of the Product with a batch free from Defects or withdrawal from the contract with an obligation to return the Product and a refund of the price — repair is not technically feasible.
In the event of withdrawal from the contract, the Buyer returns the Product (with the packaging, the label, the seal undamaged — in a state enabling verification of the batch), and the Operator refunds the sale price together with the delivery costs incurred by the Buyer (if the withdrawal concerns the entire order) within 14 days of the day the statement of withdrawal is received, using the same method of payment, unless the Buyer consents to a different method that does not involve any costs for them.

§ 7. Time limits for examining complaints

Consumers and PnPK: pursuant to Art. 561(5) of the Civil Code: “If a buyer being a consumer has demanded replacement of the item or removal of the defect, or has made a statement on price reduction, specifying the amount by which the price is to be reduced, and the seller has not responded to that demand within fourteen days, the demand is deemed to have been recognised as justified.” The 14-day time limit runs from the day a complete complaint submission is delivered to the Operator.
B2B Buyers: notwithstanding the exclusion of the statutory warranty in B2B trade, the Operator declares that it will examine complaints submitted under the LOT-Quality Guarantee within 14 business days of the date a complete submission is delivered. In particularly complex cases requiring independent laboratory analysis (§ 8), this time limit may be extended to 30 business days, of which the Buyer will be informed together with an indication of the anticipated date of completion of the verification.
The Operator’s complaint decision is delivered to the Buyer at the e-mail address indicated in the submission or — in the case of written submissions — by traditional post. The decision contains a substantive justification, including reference to the results of the independent laboratory analysis, if one was carried out.
Failure by the Operator to respond to a consumer’s or PnPK’s demand within the time limit referred to in para. 1 means recognition of the demand as justified (the legal effect under Art. 561(5) of the Civil Code). In relation to B2B Buyers, this regulation — owing to the exclusion of the statutory warranty — does not apply, but the Operator endeavours to observe the time limits declared in para. 2.

§ 8. Independent verification of Product quality

In the event of a complaint submission based on an allegation of non-conformity of a Product batch with the COA (§ 4), the Operator is entitled to send the reference sample of the same batch retained in the archive — or, where necessary, a sample of the Product returned by the Buyer — to an independent, external analytical laboratory accredited by the Polish Centre for Accreditation (PCA) in the scope of liquid chromatography (HPLC) and mass spectrometry (MS) methods.
The Operator bears the costs of the laboratory verification in full if the non-conformity with the COA is confirmed. In the event of confirmation that the batch conforms to the COA — and a simultaneous finding that the submission was manifestly unfounded — the Operator reserves the right to charge the Buyer with the costs of the analysis solely in B2B trade, on the basis of a separate calculation submitted to the Buyer for acceptance before the analysis is commissioned.
The results of the independent laboratory analysis are binding on both parties as regards the objective conformity of the Product batch with the COA declarations. The Operator provides the Buyer with the full analytical report (date of analysis, method, results, laboratory reference) together with the complaint decision.
In the event of confirmation of a material non-conformity with the COA, the Operator: a) replaces the Product with a batch free from Defects, or b) refunds the purchase price together with the delivery costs and any documented losses remaining in an adequate causal connection with the Defect — in the scope of the consumer and PnPK on the general terms of the Civil Code, and in the scope of the B2B Buyer subject to the limit of liability set out in the Terms and Conditions (a cap up to the value of the order increased by shipping costs).
The Operator maintains a register of complaint submissions and of the results of the quality verification of Product batches. This register — in a depersonalised scope — may be used for compliance reporting, including within the framework of communication with batch manufacturers and with pharmaceutical supervision authorities (GIF) in the event of a quality incident of broader scope.

§ 9. Out-of-court dispute resolution methods (ADR / ODR) — consumers only

Preliminary note: the out-of-court dispute resolution paths (ADR/ODR) described in this section are available only to consumers within the meaning of Art. 22(1) of the Civil Code. Owing to the Store’s B2B model (Qualified Buyers), these paths do not apply in relation to most Buyers. The Operator describes them for full transparency, in the event that a particular legal relationship is deemed consumer in nature.
A consumer has the option of using the following out-of-court methods for examining complaints and pursuing claims: a) Mediation conducted by the Voivodeship Trade Inspectorates (WIIH) — an application for mediation is submitted to the WIIH competent by reason of the entrepreneur’s registered office. Details: www.uokik.gov.pl; b) Permanent arbitration courts at the WIIH — free or low-cost examination of the dispute on the basis of an arbitration agreement; c) Consumer Rights Ombudsman (municipal / district) — free assistance in consumer disputes, including the drafting of pleadings and pre-litigation mediation; d) Permanent Consumer Arbitration Courts at the Voivodeship Trade Inspectorates (WSIH) — they examine disputes over property rights arising from sales contracts and contracts for the provision of services concluded between consumers and entrepreneurs.
ODR (Online Dispute Resolution) platform: pursuant to Regulation (EU) No 524/2013 of the European Parliament and of the Council of 21 May 2013 on online dispute resolution for consumer disputes (OJ EU L 165 of 18.6.2013, p. 1), a consumer has the right to use the EU ODR platform available at https://ec.europa.eu/consumers/odr/. The platform constitutes an entry point enabling out-of-court resolution of disputes arising from contracts concluded online between consumers and entrepreneurs established in the EU. The Operator’s e-mail address for contact in ODR matters: compliance@purepoint.pl.
The use of out-of-court methods for examining complaints and pursuing claims is voluntary — the Operator may, but is not obliged to, accede to a particular procedure.
Full, current information on out-of-court methods of resolving consumer disputes is available on the website of the President of the UOKiK: www.uokik.gov.pl.

§ 10. Bibliography

The Act of 23 April 1964 — the Civil Code (consolidated text: Journal of Laws 2024, item 1061, as amended), in particular Art. 22(1), 43(1), 385(5), 556–576, 556(4), 556(5), 568, 561(5), 576(5).
The Act of 30 May 2014 on consumer rights (consolidated text: Journal of Laws 2024, item 1796, as amended), in particular Art. 38, 38a.
The Act of 6 September 2001 — the Pharmaceutical Law (consolidated text: Journal of Laws 2025, item 750, previously Journal of Laws 2024, item 686, as amended), in particular Art. 124 para. 1 — whoever places a medicinal product on the market without the required authorisation shall be liable to a fine, a penalty of restriction of liberty, or deprivation of liberty for up to 2 years.
The Act of 6 June 1997 — the Criminal Code (consolidated text: Journal of Laws 2024, item 17, as amended), in particular Art. 233 — liability for making a false statement.
Regulation (EU) No 524/2013 of the European Parliament and of the Council of 21 May 2013 on online dispute resolution for consumer disputes (OJ EU L 165 of 18.6.2013, p. 1).
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR, OJ EU L 119 of 4.5.2016, p. 1).
Website of the President of the Office of Competition and Consumer Protection: www.uokik.gov.pl.
European Commission ODR platform: https://ec.europa.eu/consumers/odr/.

§ 11. Change history

Version	Date	Scope of changes	Author
1.0	2026-05-22	First drafting of the Complaints Policy (pre-launch draft).	FIRSTSTONE Compliance
1.0a	2026-05-24	Editorial revision, addition of the COA section, preliminary ADR/ODR paths.	FIRSTSTONE Compliance
2.0	2026-06-06	Full integration of the Qualified Buyer (B2B) model; exclusion of the statutory warranty in B2B trade pursuant to Art. 558 § 1 of the Civil Code; standardisation of terminology (Operator, Buyer, Product/Research Material); introduction of the LOT-Quality Guarantee as a voluntary quality guarantee; correction of errata (Art. 124 of the Pharmaceutical Law — penalty up to 2 years, not 8 years); expansion of the section on independent verification at the PCA-accredited laboratory; reorganisation of ADR/ODR with a note that they concern consumers only; update of Journal of Laws references; integration with the Compliance Policy v2.0.	FIRSTSTONE Compliance

§ 12. Final clause

In matters not regulated by this document, the mandatory provisions of Polish and European Union law shall apply. In the event of doubts as to interpretation, please contact compliance@purepoint.pl.

This document is in force as of 6 June 2026. Operator: FIRSTSTONE TRADING sp. z o.o., KRS 0001254766. Representation: Krystian Dawidowski — Member of the Management Board.