ANTI-BRIBERY AND ANTI-CORRUPTION POLICY
Policy objectives
The Company is committed to the highest levels of integrity. All employees are expected to conduct their relationships with each other, the Company, its clients, suppliers and other stakeholders with objectivity and honesty, making sure that their business judgment and decision making are not influenced by undue personal interests. Therefore, this Policy aims to:
Promote a culture of transparency, integrity, and ethical conduct within the organisation.
Prevent and detect corruption and bribery in all company operations.
Ensure compliance with national anti-corruption laws and international standards.
Safeguard the reputation and business interests of the Company.
Policy Principles
We believe in a world in which businesses use technology to have a meaningful impact on the way we live, work, and do business.
Acting lawfully and with integrity is the main basis for maintaining the trust of clients and business partners, as it enhances Company`s reputation and contributes to its business success over the long term. Therefore, acting lawfully and with integrity is an essential requirement for all Employees. Corruption and bribery in any form damages the business relationships between the Company and its clients and business partners and, therefore, is unacceptable.
The Company is committed to maintaining and promoting an anti-bribery culture at all levels. The Management Board, top management and managers shall demonstrate active, visible, consistent and sustained commitment to integrity, transparency and zero tolerance for bribery. Behaviour that compromises anti-bribery shall not be tolerated, regardless of seniority, role or business importance.
Performance targets, bonuses and other incentive arrangements for positions exposed to bribery risk shall be reviewed to verify that reasonable safeguards exist to prevent them from encouraging bribery or concealment of bribery risks.
The following are Company’s generic anti-bribery and anti-corruption guiding principles:
Zero Tolerance:The Company has a zero-tolerance approach to corruption and bribery in all its forms.
Ethical Conduct:All employees and stakeholders are expected to uphold the highest ethical standards.
Compliance:We will comply with all applicable national anti-corruption laws and international regulations.
Prevention:We will take proactive measures to prevent corruption and bribery.
Whistleblowing ReportingWe encourage the reporting of suspected corruption or bribery, ensuring confidentiality and protection for reporters (whistleblowers).
Accountability:Violations of this Policy will result in appropriate disciplinary action and/or further actions in accordance with applicable law.
This Policy is documented, implemented, maintained, and every two years reviewed to ensure its continuing suitability, adequacy, and effectiveness.
This Anti-Bribery and Anti-Corruption Policy is an integral part of our commitment to ethical business conduct, as stated in the Code of Conduct. By adhering to its principles, we can create a workplace that upholds the highest standards of integrity and ensures the long-term success of our organization.
This Policy is also part of Accesa’s ESG strategy where climate change is being taken into consideration for the improvement of Company’s carbon footprint. The overall assessment of climate change impact is considered under ESG strategy and associated actions, and it is periodically assessed.
Purpose
The purpose of this policy is to set the relevant principles and rules for preventing, detecting or managing bribery, fraud and other forms of corruption, and to support compliance with applicable anti-bribery laws and contractual obligations in relationships with clients and business partners.
The Anti-Bribery and Anti-Corruption Policy complies with GDPR provisions, ensuring transparency, security, and protection of personal data used in preventing and detecting corrupt practices. It establishes clear measures, provides staff training, and outlines audit procedures. In the process of vetting potential partners, the Company will pay special attention to safeguarding sensitive or special data according to GDPR, ensuring that all processing is done in compliance with personal data protection regulations and according to the dispositions included in the GDPR Management Policy.
Roles and responsibilities
The Company shall establish, implement, maintain and continually improve an anti-bribery management system designed to prevent, detect and respond to bribery and corruption risks across its operations, in alignment with applicable legal requirements and binding Group standards, where these set an equivalent or higher standard. Responsibilities shall be allocated in accordance with the three lines of defence model.
The Management Board Responsibilities
The Management Board has ultimate accountability for the effectiveness of the Anti-Bribery and Anti-Corruption framework within the Company.
The Management Board shall set the tone from the top, approve this Policy and any material related standards, ensure adequate governance, resources and oversight, and promote a culture of integrity and zero tolerance for bribery and corruption.
It shall ensure that bribery and corruption risks are appropriately identified, assessed, managed and escalated.
First Line - Operational Management
Operational management and business owners are responsible for managing bribery and corruption risks on a day-to-day basis within their areas of responsibility.
They shall implement and operate effective financial controls proportionate to bribery risk, including segregation of duties, due diligence, approval authorities, supporting documentation, accurate books and records, restrictions on cash payments, verification of services rendered and promptly escalate any concerns, incidents or control weaknesses.
Managers shall lead by example and provide clear guidance to employees under their supervision.
Second Line - Control Functions
Control functions, including Compliance and such other functions as may be assigned control responsibilities, shall establish the ABAC framework, issue guidance, support the business in interpreting and applying this Policy, monitor compliance, review of significant transactions, advise on higher-risk situations, and oversee training, reporting and remediation.
The Compliance Office (compliance@accesa.eu) shall serve as the primary point of contact for questions, interpretation issues, approvals where required by this Policy, and the escalation of suspected breaches.
Third Line- Internal Audit
Internal Audit shall independently assess the design and operating effectiveness of the ABAC governance, risk management and control framework. It shall provide independent financial review or audit at planned intervals and report its findings, recommendations and follow-up status to the competent governance bodies and remain independent from the activities it reviews.
Employees responsibilities
All employees are required to understand and comply with this Policy, complete required training, exercise sound judgment, and avoid any conduct that may constitute or appear to constitute bribery or corruption. Employees shall promptly report without delay any suspected or actual breach, request, offer or indication of improper conduct, and shall seek guidance from their manager or the Compliance Function in cases of doubt.
All organizational functions and /or offices must diligently and attentively adhere to both general and specific duties, for which are both accountable and responsible. These are detailed in the ‘’Responsibilities and Implementation’’ section of the Conflicts of Interest Policy.
Risk Management
All significant risks related to bribery and corruption shall be identified, documented, and managed in accordance with the Company’s Risk Management & Internal Controls Policy.
These risks should include all events that could:
have a financial impact on the Company;
trigger business disruption or reputational damage;
result in losses caused by inadequate or failed internal processes, people, and systems, or from external events.
Risk management principles shall be appliedthroughout the entire process lifecycle, including risk identification, assessment, treatment, monitoring, and periodic review. Bribery risk assessment is performed quarterly within Quarterly risk assessment exercise and is included in the Enterprise Risk Register. Bribery risks shall be assessed in accordance with the Company’s risk management process or whenever significant changes occur (e.g., entry into new markets, engagement with new third parties or changes in regulatory environment). During the assessment the bribery risks are analyzed and assessed and evaluated the suitability and effectiveness of existing controls.
Appropriate controls and mitigation measures shall be designed and implemented to address identified risks, and their effectiveness shall be monitored in accordance with the Company’s internal control framework.
The Company shall plan actions to address bribery risks and anti-bribery risk management opportunities, integrate those actions into relevant business and processes, and evaluate their effectiveness. Opportunities may include improvements to controls, training, reporting channels, due diligence, automation, monitoring, culture initiatives or business-associate management.
Internal activities/processes with increased risk of corruption
The following rules contain the effective company-wide principles to avoid corruption and bribery.
Acceptance or granting benefits and gifts
Employees should not receive or offer any gift or anything else of significant value for the purpose of influencing the actions or decisions of the Company or the recipient. Gifts exceeding a threshold of EUR 100 VAT included or equivalent received from suppliers and consultants must be declined.
Gifts may be considered acceptable if received under the above-mentioned threshold as part of normal business practice, usually on Christmas and Easter Holidays (e.g., bottle of wine, chocolates, flowers, branded items, invitations to events etc).
Benefits shall not be offered, accepted or approved (irrespective of their value) during or close to tenders, negotiations, contract awards, supplier selection, public-sector interactions or approval decisions where they may create an improper perception.
If an employee believes there is an appropriate reason to make an exemption to this policy for an individual situation, he or she should contact the Risk &Compliance Lead prior to giving or accepting the gift.
All employees who receive gifts or benefits with a value over 100EUR VAT included must inform the Compliance Function immediately (compliance@accesa.eu). Irrespective of any tax obligations that may result from the acceptance of benefits, the granting and acceptance of benefits must be documented in dedicated registry (Gifts Received Register) held by the Compliance function.
The Procurement function maintains the Gifts Granted Register for all gifts provided to clients, suppliers, and consultants, ensuring continuous transparency regarding the timing, occasion, provider, and recipient of any benefit.
The granting and acceptance of benefits in secret is not permitted.
Public officials are not allowed to receive any benefits or gifts, either directly or indirectly from the Company, that could cast doubt on their independence, therefore the employees of the Company are not allowed to offer any benefits or gifts, either directly or indirectly to public officials or other people who may exert influence on them, as these might be perceived as bribery.
Donations and sponsoring
Within the scope of the applicable laws and its corporate purpose, the Company may support education, science, art, culture, social affairs, vulnerable social groups, sports, emergency situations relief and the environment, as well as the operations of authorities whose purpose is, indicatively, to promote social security, wellbeing, and welfare by making donations, always taking into consideration the provisions of national legislation according to Company’s Sponsoring and Donations Policy, and CSR Framework.
No donations are to be made to private individuals, personal accounts, and individuals or organizations if they could prove harmful to the reputation of the Company, regardless of whether such donations are lawful or not.
Also, the Company may engage in sponsoring in areas related to its business interests The Company uses sponsoring as one of its tools in corporate communications. Sponsoring activities are permitted only if the sponsoring partner or event organizer provides reasonable and verifiable corporate communication and marketing services.
Decisions on the granting of donations or the conclusion of sponsoring agreements, including the subsequent benefits, which should be verifiable and rightful, shall be documented at every stage. Donations or sponsoring services made in secret are always forbidden. Improper motives, namely personal preferences, may not be pursued when granting donations and sponsorships. Regardless of the recipient or the recipient’s organization, donations and sponsorships may not be offered, promised, or granted for the purpose of influencing the decisions of business partners or members of the public sector.
Benefits extended in the political sphere
Sponsorships and donations to political parties, members of Parliament and to other elected officials are strictly forbidden. This also applies to the working groups, youth organizations, and associations etc. of political parties, but not to independent institutions not affiliated with any political party and which use sponsorships for their own social purposes.
Consultants/Agents
To ensure the targeted use of business assets and to minimize the risk of corruption, bribery and conflicts of interest, special care must be taken in selecting and monitoring consultants, agents, and comparable external intermediaries who are involved in the business activities. All the relevant contracts should include provisions on the avoidance of corruption.
Consultants are defined for the purpose of this Policy as natural persons and/or legal entities which provide consulting/advising services (except for legal services and software development and IT consultancy services) for the implementation of the Companies’ projects.
Agents are defined for the purpose of this Policy as natural persons and/or legal entities who act as an intermediary for the Company in relation with state-owned companies.
Reporting
If there is reasonable cause to suspect acts of corruption, bribery, or other forms of corruption as defined in this Policy, the circumstances shall be investigated regardless of the suspect’s reputation or position within the Company.
Any employee/external partner who discovers a potential violation of applicable laws or this Policy is required to report their suspicion promptly through the whistleblowing reporting channel .
Employees who report potential misconduct or who provide information or otherwise assist in any inquiry or investigation of potential misconduct will be protected against retaliation.
Confidentiality: Reports of suspected corruption or bribery will be handled with the utmost confidentiality. The Company will maintain strict confidentiality to protect the identities of reporters (whistleblowers).
Non-Retaliation: The Company is committed to non-retaliation against whistleblowers. Any form of retaliation against an employee who reports a concern in good faith will be met with disciplinary action.
Reporters will not suffer retaliation, discrimination or disciplinary action (e.g. by threats, isolation, demotion, preventing advancement, transfer, dismissal, bullying, victimization, or other forms of harassment) for:
refusing to participate in, or turning down, any activity in respect of which they have reasonably judged there to be a more than low risk of bribery that has not been mitigated by the organization; or
concerns raised or reports made in good faith, or on the basis of a reasonable belief, of attempted, actual or suspected bribery or violation of the anti-bribery policy or the anti-bribery management system (except where the individual participated in the violation).
Investigation: Upon receiving a report, the Company will conduct a thorough and impartial investigation. The investigation will involve a designated team made of the Risk & Compliance Lead, Head of Legal and Internal Auditor, for evaluating the allegations, interviewing relevant parties, and collecting evidence.
Reporting to Authorities: In cases where the investigation reveals criminal wrongdoing or a breach of the law, the Company will cooperate fully with law enforcement authorities, providing evidence and support for legal action, if required.
Consequences
The Company may suspend or terminate a transaction, project, activity or relationship where bribery risks cannot be adequately managed or where bribery is reasonably suspected or established.
The Company will also cooperate with authorities in the investigation and prosecution of corrupt practices when required by law.