1. Introduction
EXALTO LTD(hereinafter referred to as the “Company”) has committed to maintaining high ethical standards and strongly upholds the integrity of its business practices worldwide. The Company will not engage in bribery and/or corruption.
The purpose of this document is to define the Company’s policy regarding bribery and corruption. This policy applies strictly to all employees, directors, agents, consultants, contractors, and all other persons or entities associated with the Company, in all regions, areas, and functions.
It is important that you read and understand this document and act in accordance with the policy set out herein.
2. Scope
This policy applies to all individuals working at all levels within the Company, including partners, consultants, employees (permanent, fixed-term, or temporary), contractors, interns, home workers, or any other person associated with the Company, regardless of their location (hereinafter referred to as workers or employees).
3. Policy and Procedures
Prohibitions
All forms of bribery and corruption are prohibited. The Company will not tolerate any acts of bribery or corruption. Giving gifts in any form is prohibited – even the promise to give gifts or agreeing to receive them is forbidden. Any violation of this policy or local legislation may result in disciplinary action, which may ultimately lead to dismissal.
Bribery
The Company does not participate in acts of corruption, paying bribes, or receiving bribes, directly or indirectly. The Company prohibits its employees from any involvement in acts of corruption, paying bribes and/or kickbacks, as well as accepting bribes and/or kickbacks from public officials and private individuals, such as the staff of companies with which the Company collaborates in business.
Gifts, Hospitality, and Expenses
Under various global anti-corruption laws, it is illegal to provide money or items of a similar nature (such as gifts, business lunches, dinners, or entertainment) to individuals with the aim of initiating or maintaining business, or to secure any improper advantages. These laws do not prohibit reasonable and customary business gifts, food, and entertainment.
Excessively generous gifts or hospitality, whether given or received, are unacceptable as they may create the impression that the Company is attempting to create or gain a favourable business relationship by providing personal benefits to certain individuals. Furthermore, gifts and hospitality can in themselves be considered bribery. Ensure that all gifts and any hospitality relate to normal and reasonable purposes consistent with the course of ordinary business activity.
Facilitation Payments
The Company does not make and will not accept facilitating payments or bribes of any kind. If you are authorised to make a payment on behalf of the Company, you must always be clear about what the payment is for and whether the requested amount is proportional to the goods or services provided. You must always request a receipt that specifies the reason for the payment. If you have any suspicions, concerns, or questions regarding a payment, you must raise these issues with the manager.
All workers must avoid any activity that could lead to such a payment, or for which they suspect that a payment will be made or accepted by the Company.
Conflict of Interest
Company employees must avoid situations or transactions where their personal interests might conflict with, or be in conflict with, the interests of the Company. This includes: using any customer information related to their association with the Company for personal gain; providing such information to a third party; or acting in a way that could be interpreted as insider trading.
A conflict of interest may arise if individuals have a personal interest in business transactions related to the Company. Personal interests can be direct or indirect, relating not only to the employee’s own interests but also to those of their family members and friends. If there is a likelihood of conflict, the Company’s interests must take precedence. Employees must disclose any personal conflict of interest or apparent conflict to their direct supervisor.
4. Records
The Company maintains financial records and conducts appropriate internal audits that verify the business reasons for making payments to third parties.
All accounts, invoices, and other documents and records related to relationships with third parties, such as customers, suppliers, and business contacts, must be prepared and maintained with strict accuracy and completeness.
5. Responsible Persons
o If you have doubts about the application of this policy, please contact the manager
o Consult the manager if you suspect that a Company employee is involved in bribery, corruption, fraud, or any other form of unacceptable or unethical behaviour.
6. Applicable Legislation
All national laws related to bribery and corruption apply to the Company, particularly those in the jurisdictions of the countries where the Company has office(s) or conducts its activities.
In defining the principles included in this policy, special attention has been paid to the requirements of EU anti-corruption acts. Compliance with EU requirements is mandatory for many of the Company’s clients and is fully accepted by the Company.
7. Summary
· You must ensure that you have read and understood this document and comply with this policy at all times.
· Preventing, detecting, and reporting bribery and/or other forms of corruption is the responsibility of all employees working for the Company or under its control. All workers are obliged to avoid any activity that offers or could lead to a breach of this policy.
· You must notify your manager as soon as possible if you are convinced or even suspect that there is a conflict with this policy or that one may arise in the future.
· Any employee who violates this policy may be subject to disciplinary action, which may lead to dismissal in cases of serious breach.
· The Company reserves the right to terminate its contractual relationships with workers if they violate this policy.