Anti-Corruption Policy

Anti-Corruption Policy

 

Preamble

This document describes the Company’s policy to prevent and deter practices of corruption, fraud, collusion, and bribery in its activities.

  1. Introduction and Purpose of this Policy

The maintenance of high standards of morality, in compliance with national and international laws, is the guiding principle of the Company and possesses all its activities and functions. The Company is committed to the implementation of its operations and activities in accordance with the provisions of applicable national and EU legislation and fair trade practices and this commitment is incorporated into this Code. The Company considers that, at the company level, participation in corruption negatively affects the reputation, the credibility of the company itself in the market, causes criminal consequences, civil liability and other legal risks and financial damage (in case of fines), increases the operational costs, affects the loyalty and faith of staff, creates negative attitudes and culture, and excludes potential business opportunities. Moreover, banning corruption practices is a benchmark in general for the proper functioning of the economy, growth and development.

For this reason, the Company implements its professional activity with strict ethical compliance procedures, demonstrating zero tolerance to Bribery and Corruption practices and complete professional integrity in its business dealings, relationships and transactions.

The purpose of this Anti-Corruption and Bribery Code, therefore, is the full compliance of the company, its employees as well as its external associates with the relevant applicable legislation at the national and EU levels.

Make sure you read, understand, and comply with this Policy.

  1. Who is covered by the Policy

The Policy of this Code applies to all persons who work on behalf of the Company or on its behalf at all levels or are related to it in any way.

  1. Definitions

Corruption practices are the abuse of a public or private position for personal gain.

Bribery practices are the offering, promise or payment of money, gifts or anything offered to a person with a position of influence, in order to influence his behavior, decisions, beliefs or gain an irregular advantage.

Fraud is an act or omission, including distortion of facts, in which someone, knowingly or through negligence, misleads or attempts to mislead someone for financial or other gain or to avoid liability (including tax fraud).

Collusion is the practice in which two or more parties enter into an agreement to achieve an unlawful purpose, including unlawfully influencing the actions of another.

  1. Requirements

Corruption undermines public trust and confidence, threatens national and global economic and social development, and poses significant barriers to fair trade.

Therefore, the prevention, detection, and reporting of corruption and other forms of corruption is a priority and responsibility of all those who work for us or are under our control. All Personnel should avoid any activity that could lead to a breach of this Policy, either by Personnel or by business partners.

The Company and its employees are committed to following ethical business practices, behaving in a transparent and reliable manner, and complying with both applicable national and EU laws, and regulations, as well as with global policies aimed at preventing risk of corruption.