Anti-Corruption Policy - Alza.hu

This Anti-Corruption Policy was written originally in Hungarian language. The original document can be found here.

Basic information

Anti-Corruption Policy is a document that:

1. is binding for all employees, business partners or other persons acting on behalf of or in the interest of the Company;
2. represents the company externally and its content is publicly available;
3. is in full compliance with the Code of Ethics and the Global Rules;
4. is an important part of the company's compliance program;
5. was accepted and approved by the entire Board of Directors of Alza.hu;
6. takes effect on 1.7.2020.

Content

ANTI-CORRUPTION POLICY - Alza.hu Kft.

Preamble

The Board of Directors of Alza.hu Kft., registered at Jankovcova 1522/53, 170 00 Prague 7, Company Registration Number 270 82 440, entered in the Commercial Register kept by the Municipal Court in Prague, Section B, Insert 8573, (hereinafter the “Company”) declares that is firmly committed to preventing corruption and corrupt practices in any form. To this end, the Company publishes its anti-corruption policy applicable to employees, associates, and business partners of the Company.

We are committed to doing business with utmost honesty, fairness, and transparency, and we believe in the principle of zero tolerance for corruption.

It is in the Company's interest to combat corruption effectively and efficiently. Our fundamental rule is that even the most lucrative business is not worth compromising our Company and losing the good name and credibility of the Company as a whole or its employees.

In all circumstances, we ensure compliance with the highest ethical standards and strive to respect and honour the good name of the Company while upholding corporate culture and moral principles.

Article I - Objectives

The anti-corruption policy is formulated and applied in order to promote fair, honest, appropriate, and transparent business in accordance with the valid legislation of the Czech Republic and internal values of the Company.

The formulations of the anti-corruption policy are based on general experience, follow the rules defined by the law of the Czech Republic and aim to achieve:

1. zero tolerance of corrupt practices in business relations,
2. establishment of transparent and fair conditions for all business relations,
3. creation of active procedures limiting the emergence of a corrupt environment,
4. prevention and detection of corrupt practices,
5. regular training of employees,
6. reporting and evaluation of suspicious behaviour.

Article II - Scope

This policy is binding on all employees of the Company, business partners or other persons acting on behalf of or in the interest of the Company. The policy expresses the Company's attitude towards corruption, fraudulent or coercive practices. These practices may include, but are not limited to, bribery, fraud, theft or misappropriation of Company assets, falsification of accounts to disguise the transfer of funds to private accounts, abuse of trust, disclosure of Company internal information to third parties or other conduct in violation of applicable legal provisions. .

Article III - Definitions

Corruption

Bribery

Direct or indirect solicitation, promise, offer of a bribe or any other impermissible advantage or prospect thereof which interferes with or affects the proper performance of any obligation or conduct required of the recipient of the bribe, whether or not bribery occurs through personal interaction or through a third party or entity.

Accepting a bribe

Accepting a bribe or other inadmissible advantage or performance in violation of this anti-corruption policy, be it personally or through a third party or entity.

According to this anti-corruption policy, accepting or offering a gift in the form of financial payment is always considered bribery and is strictly prohibited.

Gift

A gift is defined as gratuitous transfer of property to someone else with his or her consent. It may also be any benefit, service, or privilege provided by a third party to an employee of the Company or, conversely, by an employee of the Company to a third party, done without expectation of any further consideration and without intending to give the recipient a sense of obligation. For the purposes of this policy, a gift is any implementation or benefit that does not take the form of a financial reward. The Company clearly defines the form and maximum value of the gift that the employee can accept or offer.

Article IV - Prohibition of corrupt practices

The company applies a policy of zero tolerance for corrupt practices or bribery. Any violation of the Company's anti-corruption policy will be sanctioned in accordance with applicable legislation and labour laws.

In particular, it is prohibited to:

1. Encourage, tolerate or accept corrupt practices in the Company.
2. Request or accept any payment, service, benefit, or privilege that is in direct conflict with the Company's anti-corruption policy.
3. Conceal, distort or downplay conduct that is contrary to the Company's anti-corruption policy or its interests.

Article V - Conflict of interests

All employees are primarily responsible to the Company when it comes to business activities and must avoid any activities that may even seemingly interfere with this responsibility. All business decisions must be made in accordance with the Company's internal regulations.

A conflict of interest occurs when an employee's interest conflicts with the interests of the Company or its customers. For example, when a person obtains an undue advantage as a result of his or her position in the Company, or when such a person is bound by other obligations that are or appear to be incompatible with the interests of the Company. A conflict of interest may also arise when a person's position or responsibility to the Company offers an opportunity for him or her to benefit beyond the scope of normal employee benefits, or when a person's personal or family interests are, or appear to be, incompatible with the Company's interests, creating conflicting relationships of loyalty and obligation.

Conflicts of interest are strictly prohibited. Any potential conflict of interest must be reported at the earliest opportunity and steps must be taken to resolve the situation fairly.

In particular, it is prohibited to:

1. Deliberately enter into a relationship that the employee knows in advance or assumes will be in conflict with the interests of the Company. If an employee discovers a conflict of interest only after the establishment of such a relationship, he or she is obliged to immediately notify their superior, who will bring the relationship in line with the Company's anti-corruption policy.
2. As an employee, being responsible for transactions that represent a conflict of interest or a resemblance of one. The employee must not be personally involved in a way that could influence his or her objective and independent judgment.
3. Provide orders, purchases, or commissions to the Company from parties owned or managed by employee relatives or their close associates or friends, unless such cooperation is approved by the Company's management.
4. Enter into employment relationships, participate in business shares, or otherwise cooperate with the Company's business partners.
5. Use the Company's business contacts, contacts, data or other information for your own benefit or for the benefit of a third party.
6. Conceal or distort any personal or professional relationships that may adversely affect transparent and fair business relationships.

Article VI - Gifts

Giving and receiving a gift must done be in accordance with the Company's internal rules. Employees are entitled to keep the gift if:

• The total value of the gift does not exceed the amount of CZK 1,000 incl. VAT.
• The gift is food or beverages or other products with a short expiration time.
• The gift is a promotional item. That is, the item is marked with the gifter's logo.

In the event that an employee of the Company is offered a gift that does not comply with the Company's internal rules, it is necessary to inform the responsible person of the gift immediately after receiving it in accordance with Alza.hu's internal regulations.

The employees may not accept a gift in the form of any stay, tour, trip, or invitation to a cultural and other social event. Exceptions are subject to official approval in accordance with the Company's internal rules.

Employees are prohibited from promising, offering, or providing to the Company's business partners or third parties any financial or material gifts to which they are not contractually entitled.

The employee tasked with this particular duty may donate Company goods to a pre-approved competition or for the purposes of a sales promotion. Any such cooperation must be carried out on the basis of a contract and is approved by the manager responsible.

Promising or giving any gifts or benefits to officials is in direct violation of applicable law and is strictly prohibited.

Article VII - Commercial negotiations and tenders

The Company employees are obliged, in all business negotiations and tenders, to avoid discrimination, maintain equality when dealing with all business partners, and to act transparently and in the interest of the Company.

Corruption risks are a significant factor that affect the initiation or continuation of a relationship with a business partner. The Company's business partners must be trustworthy, solvent and share the same ethical and moral values in the area of anti-corruption policy throughout the entire period of cooperation. All agreements with business partners include an anti-corruption clause declaring that the business partner will refrain from any form of corruption or conduct that is contrary to the Company's anti-corruption policy.

Article VIII - Verification and background checks

When selecting candidates, especially for key and managerial positions and jobs that involve an increased security risk, the Company, based on the informed consent of the candidate, shall verify the information provided by the candidate and assess general risks. Human resource risk assessment is an ongoing security process that is limited by the validity of informed consent.

Article IX - Reporting corrupt practices

Any information about potential corruption, unfair or unethical conduct of an employee or person cooperating with the Company must be reported immediately and will be duly and diligently verified by the Company. Upon notification, which can be made anonymously and is always considered confidential by the Company, the notifiers are guaranteed full legal protection at the Company's expense and assured that their complaints will be given due consideration and will be properly investigated. Any complaints about violations of the Company's anti-corruption policy can be made electronically to the e-mail address [email protected]. The sender will be transparently informed of the receipt/settlement of his or her complaint. All suggestions and information are always processed transparently in accordance with the applicable internal compliance guidelines of the Company's team.

Article X - Consequences of breaching the anti-corruption policy

Violation of the Company's anti-corruption policy will be considered a gross violation of internal rules and its values and may result in termination of the business, contractual, employment, or other relationship with the Company or criminal liability.

Article XI - Anti-corruption policy validity

This anti-corruption policy takes effect on 01.07.2020 and shall remain valid until it is amended by an informed change or update.