ANTI-BRIBERY AND ANTI-CORRUPTION POLICY
Preamble
brainit.sk,s.r.o. ID: 52577465, Veľký Diel 3323, Žilina 010 08, Slovakia
is committed to conducting its business operations with the highest standards of ethics, integrity, and transparency. The Company recognizes the damaging effects of corruption on society, the economy, and fair competition, and is dedicated to preventing and combatting corruption in all its forms.
Objective
This Anti-Corruption Policy (the “Policy”) sets forth the principles and guidelines that all employees, directors, officers, contractors, and business partners of the Company must adhere to in order to prevent corruption and maintain a culture of integrity.
Definition of Corruption
For the purpose of this Policy, corruption refers to any abuse of entrusted power for personal gain or to obtain an unfair advantage. It includes, but is not limited to, bribery, embezzlement, fraud, money laundering, kickbacks, extortion, and any other illicit or unethical behavior.
Prohibition of Corruption
The Company strictly prohibits any form of corruption, whether committed directly or indirectly, by its employees, directors, officers, contractors, or business partners. This includes actions taken in the name of the Company or using its resources.
Compliance with Laws and Regulations
All individuals associated with the Company are required to comply with all applicable laws and regulations related to anti-corruption, including international laws and other relevant anti-corruption legislation.
Gifts, Hospitality, and Entertainment
The Company recognizes that gifts, hospitality, and entertainment can be a normal part of business relationships. However, it is essential to ensure that such activities do not create conflicts of interest or serve as a disguise for bribery or improper influence. All individuals must exercise good judgment and adhere to the Company’s policies and procedures regarding gifts, hospitality, and entertainment.
Conflicts of Interest
Individuals associated with the Company must avoid any actual or perceived conflicts of interest that could compromise their objectivity, independence, or decision-making. Any potential conflicts of interest must be promptly disclosed to the appropriate authority within the Company.
Reporting and Whistleblower Protection
The Company encourages all individuals to report any suspected or actual instances of corruption promptly. A reporting mechanism, such as a confidential hotline or dedicated email address, is provided to facilitate the reporting of concerns or violations. The Company is committed to protecting whistleblowers from retaliation and ensuring confidentiality to the fullest extent permitted by law.
Due Diligence on Business Partners
The Company conducts appropriate due diligence on its business partners, including suppliers, agents, consultants, and contractors, to mitigate the risk of engaging with entities involved in corruption or other illicit activities. The Company expects its business partners to adhere to similar anti-corruption standards and may terminate relationships with those who fail to comply.
Training and Awareness
The Company provides regular training programs to educate employees, directors, officers, and other relevant stakeholders about anti-corruption laws, regulations, and the Company’s policies. This ensures a high level of awareness and understanding of the risks and consequences associated with corruption.
Non-Retaliation
The Company strictly prohibits retaliation against individuals who report suspected or actual corruption in good faith. Any form of retaliation is considered a violation of this Policy and will result in appropriate disciplinary action.
Policy Review and Amendments
The Company periodically reviews and updates this Policy to ensure its effectiveness and alignment with evolving legal and regulatory requirements. Any amendments to this Policy will be communicated to all relevant individuals within the Company.
Effective Date
This Anti-Corruption Policy shall come into effect on 23.05.2023.
Signed:
Conventions binding on the Slovak Republic:
- The Criminal Law Convention On Corruption of the Council of Europe
- Additional Protocol to the Criminal Law Convention omn Corruption
- Civil Law Convention on Corruption
- Convention Draw up on the basis of Article K.3 (2) (C) of the Treaty on European Eunion on the Fight Against Corruption Involving Officials of the European Communities or Officials of the Memner States of the European Union
- Protocol drawn up on the basis of Article K.3 of the Treaty on European Union
to the Convention on the protection of the European Communitiesí financial interests - Council Framework Decision 2003/568/JHA of 22 July 2003 on combating corruption in the private sector
- United Nations Convention against Corruption
- Convention on combating bribery of foreign public officials in international business transactions
Legal Acts in Slovak Republic related to anti-corruption, such as:
- Act No. 300/2005 Coll. Criminal Code
- Act No. 301/2005 Coll. Code of Criminal Procedures
- Act No. 91/2016 Coll. on Criminal Liability of Legal Entities and on Amendments and Supplements of Certain Acts
- Act No. 211/2000 Coll. on Free Access to Information and Amendments of Some Acts
- Act No. 55/2017 Coll. on Civil Service and Amendments of Some Acts
- Act No. 552/2003 Coll. on Execution of Work of Public Interest
- Act No. 553/2003 Coll. on remuneration of some employees at the work performance in public interest and on the change and supplement to some acts as amended by subsequent provisions
- Act No. 357/2004 Coll. on on Protection of Public Interest during Performance of Public Function Officials as amended by Constitutional Act no. 545/2005
- Act No. 71/1967 Coll. on Administrative Proceedings
- Act No. 369/1990 Coll. on Establishment of Municipalities as amended by later regulations
- Act No. 301/2001 Coll. Laboure Code as amended by later regulations
- Act No. 343/2015 Coll. on Public Procurement and on the Amendment of Certain Acts, as amended
- Act No. 528/2008 Coll. on Aid and Support provided from the European Community funds
- Act No. 315/2016 Coll. on Register of Partners for Public Sector and on Amendment of Certain Acts