Anti-corruption policy

3.1 Prohibition of Bribery

Bribery and corruption can take many forms: they can be overt, such as monetary bribes, or more subtle, such as job offers, commission payments, and excessive gifts or hospitality. To ensure compliance with the law and this Policy, our anti-bribery management system has developed the following rules and guidelines to be followed by all Employees and Business Partners Employees and Business Partners are prohibited:

• • make, support, offer or authorize, promise, request, agree to receive, approve and/or receive any payments, financial or non-financial benefits (directly or indirectly);
  • directly or indirectly (including through intermediaries) promise, pay, give, transfer, offer or provide Tangible or intangible items in any form to Public Officials for reasons not expressly permitted by law (e.g., statutory and reasonable payments provided to Public Officials for services rendered are not prohibited). Employees and Business Partners must always exercise caution when communicating with Government Officials;
  • Transfer directly or indirectly (including through third parties) any Tangible or Intangible Goods to a State Official’s children, spouse, other immediate family members or associates, or any other person to whom the State Official has entrusted such transfer for purposes not expressly provided by law (and if Employees or Business Partners offer to transfer Tangible or Intangible Goods to such persons, even if expressly provided by law, they must nevertheless receive a p
  • make Incentive Payments or kickbacks of any kind, unless such payment is required to avoid risk to life or limb (in such circumstances, the payment must be reported to the Supervisor as soon as possible, and properly maintained in the appropriate primary reporting).
  • Certain administrative or expedited review fees are permissible and will not be considered Incentive Fees, as long as they are permitted or specifically required by local law. However, payments that are made in accordance with customary practices or cultural practices that are contrary to established law are not acceptable.

The above prohibitions apply regardless of whether Altegio funds are used to offer or receive Bribes, Tangible or intangible items and regardless of whether they are promised, given or offered, directly or indirectly, through third parties (e.g. agents, consultants, sales managers, distributors, resellers and subcontractors). If a bribe is required or requested, the Employee or Business Associate must:

• refuse to pay or provide a Bribe and explain that Altegio does not make such payments or provide improper advantages under any circumstances because they are contrary to the provisions of applicable law, Altegio’s business ethics policies and guidelines and internal rules;
• explain that this waiver is final;
• not use nonverbal means of communication, including gestures and postures, and not give any hints that imply an understanding of actions that are inconsistent with this Policy;
• In the case of an Employee, notify your superior, in the case of a Business Partner, notify the contact person at Altegio, who will be obliged to inform your superior
• in the case of a partner or person representing Altegio , explain that they are not authorized to make payments or provide any other benefit on behalf of Altegio and that the relationship with them will be terminated if such payment is made or benefit is provided.

3.2 Inadmissibility of fraud

Fraud can take many forms. For example, it can include falsifying invoices, financial statements or inventory information, giving false statements of expenses, and committing fraudulent transactions.

All Employees and Business Partners shall:

• not participate in (directly or indirectly) or otherwise contribute to any fraud;
• protect Altegio’s property and use it faithfully and with care; and
• Understand internal management and control mechanisms and know and follow procedures relevant to your work that are designed to reduce the risk of committing fraud.

3.3 Expenses, gifts and donations All expenses (including hospitality and entertainment), gifts and donations must:

• be for a legitimate business purpose directly related to Altegio’s business, be consistent in nature and cost with industry standards in the place of transfer or receipt, and be reasonable and appropriate. Costs may vary by country or region, so you should always be aware of the risk that even a small expense in one location may not be acceptable in another;
• are not permissible if they could be construed as Bribes;
• not to put you or Altegio in an uncertain or difficult position;
• not be used to improperly influence or attempt to improperly influence you or anyone else with the intent to improperly obtain or retain business or any advantage;
• not be offered to or accepted from a person or organization with a reputation for dishonest, unethical or illegal conduct;
• not be offered to or accepted by any party with whom Altegio participates in public tenders or bidding procedures;
• be ad hoc or infrequent;
• not lead to a Conflict of Interest;
• not violate any policy, local law, rule or regulation applicable to you or the person giving or receiving it. It is your responsibility to verify this;
• be pre-approved in writing by your supervisor before an expense, gift or donation is made, purchased or accepted if its value exceeds $100 or the equivalent amount in another currency, but all expenses related to government employees must be approved regardless of value (see below);
• be evidenced by receipts, checks (if possible) and must be timely and fully recorded in the appropriate Altegio primary reporting in accordance with applicable legal and accounting requirements. Gifts should never be made in cash or its equivalent (such as a gift card). Any gifts or hospitality received from or offered to Public Officials (if permitted by applicable law) must (regardless of value) be subject to prior written approval by the Manager. As a clarification, items of small value (not exceeding $10 or the equivalent amount in another currency) intended for advertising (which usually have a printed Altegio or business partner logo) are not considered gifts and may be given to Public Officials without prior approval, provided they are for legitimate business purposes and are properly recorded in Altegio’s books and records. Charitable donations to outside organizations may not be used to influence customer purchasing decisions, Government officials or third parties to gain business or other advantages. Charitable donations may only be made to registered charities and must be appropriately recorded in Altegio’s books and records.

3.4 Political contributions, lobbying, commercial sponsorships, and commissions

Any political contributions, commercial sponsorships or commission payments may never be used as bribes and must not result in any business advantage for Altegio. All such payments, if permitted by applicable law, must be appropriately recorded in the appropriate Altegio books and records.

You may not make political contributions or participate in lobbying activities without prior written permission from the Manager.

Any political activity you engage in for personal purposes must be conducted separately from Altegio. You may not link to or use Altegio’s resources.

Any Commercial Sponsorship and commission payments must be in the form of a legally binding agreement and recorded in the appropriate books and records. Prior written approval for these payments must be obtained from the Manager, regardless of their amount.

3.5 Conflict of Interest

Employees and Business Partners should strive to avoid any relationship, influence or activity that may adversely affect their ability to perform their jobs or to make fair, objective and appropriate decisions in Altegio’s best interest. Business transactions with related parties, such as spouses, children, parents and others who have close personal relationships, for example, may be adversely affected. In the event of a Conflict of Interest, Employees and Business Partners shall:

• Immediately report the situation to the Supervisor before entering into any commercial transaction;
• Perform any action required by the Manager to resolve a Conflict of Interest.

3.6 Primary reporting

Altegio’s employees and Business Partners are required to follow established accounting and reporting procedures to accurately reflect each transaction and maintain a system of internal accounting controls and record keeping in the ledgers and records.

All transactions and payments (including gifts) must be properly, faithfully and accurately recorded on general ledgers and all source documents, including invoices, receipts and disbursements. These requirements are designed to prevent Bribery and Fraud.

4. Responsibilities 

4.1 Employee Responsibilities

Employees are required to:

• read, understand and comply with this Policy and any other documents designed to implement it;
• Always demonstrate ethics, honesty and responsibility and expect the same from others;
• Refer any questions, concerns, or information about any known or suspected violations of this Policy through the channels described in the Speak Up Policy;
• notify Business Partners of the requirements of this Policy and apply the Due Diligence Policy as part of their job duties.

4.2 Responsibilities of Supervisors

In addition to the above, it is the responsibility of supervisors to ensure that Employees and Business Partners follow the requirements and guidelines set forth in this Policy and receive ongoing training on the requirements of this Policy.

5. Freedom of notification

Any Employee who knows or suspects a violation of this Policy or an event or circumstance that suggests another Employee or Business Partner has violated the laws of Bribery, Corruption or Fraud must report that information in accordance with the Whistleblowing Policy. Employees and Business Partners may report concerns anonymously (although it is recommended to do so formally). How Employees respond to these issues is critical to Altegio’s ability to prevent Bribery, Corruption and Fraud and to maintain its ethical principles and business reputation. Altegio’s senior management will fully support any Employee or Business Associate who refuses to engage in Bribery, Corruption or Fraud or who reports in good faith any concerns in accordance with the Whistleblowing Policy. Negative reactions following a good faith report under the Problem Reporting Policy are unacceptable. Employees and Business Partners will not be penalized for reporting in good faith, even if their concerns are unfounded, and those who allow negative reactions will be subject to disciplinary action.

6. Liability for non-performance (improper performance) of THIS POLICY

If Altegio learns of any violations of this Policy, or of an event or circumstance indicating a violation of any Bribery, Corruption or Fraud laws, an internal investigation will be initiated, involving law enforcement and other competent persons as appropriate. Since Alegio may be subject to sanctions for the involvement of its Employees, counterparties and others in corrupt activities, official investigations will be initiated for each reasonable suspicion or instance of corruption to the extent permitted by applicable law. Persons guilty of violating the requirements of this Policy may be held disciplinarily, administratively, civilly or criminally liable at the initiative of Altegio, law enforcement agencies or other persons in the manner and on the grounds provided for by law, local regulations and employment contracts. All Employees and Business Partners are responsible for compliance with this Policy and other documents designed to implement it. Failure to comply with this Policy will be grounds for disciplinary action, up to and including termination of employment or termination of the business relationship. In addition, persons who violate the laws of bribery, corruption or fraud may be subject to civil or criminal penalties. Any questions about the Policy can be emailed to [email protected].

7. Expected results

It is expected that as a result of the implementation of the Altegio Anti-Corruption Policy, the anti-corruption systems will be improved, effective mechanisms to prevent corrupt practices will be formed, and the risks of involvement of Altegio and its employees in corrupt activities will be minimized. The implementation of this Anti-Corruption Policy is aimed at raising the legal and civic consciousness of Altegio’s employees by shaping a negative attitude towards corrupt practices, involving each employee in the implementation of measures to prevent corruption. As a result of implementation of measures of the present Anti-Corruption Policy, Altegio Europe KFT will establish effective systems of monitoring of corruption factors and suppression of corrupt practices, which will lead to minimization of risks of property and reputational damage to Altegio.