CORRUPTION PREVENTION POLICY

AKVATERA LT, UAB (hereinafter referred to as the Company) opposes all forms of bribery, corruption, trading in influence and conflicts of interest. We strive for open competition and ethical trading conditions, we comply with the norms of the legal systems of the countries in which we operate.

 

The main provisions of the Corruption Prevention Policy (hereinafter referred to as the CPP):

 

The Company does not tolerate any manifestation of bribery or corruption.

 

Corruption – the abuse of power for personal gain. It is an act or omission which directly or indirectly seeks to receive or accepts property or other personal gain for oneself or another person in the performance of one’s duties, or directly or indirectly offers, promises or provides a material or other personal benefit to a person for the performance or non-performance of one’s duties.

 

A bribe – the offer, giving, permission to give, request, acceptance or receipt of a financial or other benefit in order to encourage the improper performance of a function or the abuse of a person’s position. Bribery can take many forms, including but not limited to cash transfers, valuable gifts, travel, entertainment payments, career opportunities and / or promises, leaks of valuable, commercially important information, etc.

 

A bribe is the offer, giving, permission to give, request, acceptance or receipt of a financial or other benefit in order to encourage the improper performance of a function or the abuse of a person’s position. Bribery can take many forms, including but not limited to cash transfers, valuable gifts, travel, entertainment payments, career opportunities and / or promises, leaks of valuable, commercially important information, etc.

 

The CPP applies to all employees of the Company (including persons employed under employment contracts, consultants, intermediaries and other persons acting on behalf of the Company, regardless of the form of their relationship with the respective company and remuneration).

 

The Company only accepts and provides business gifts and hospitality that do not exceed the standards of normal business relations and transparency. The Company does not tolerate any gifts, payments or hospitality that encourage or reward a decision or thus seek to gain favour or exclusivity in any activities related to the Company.

 

Invitations to free events, meals and entertainment are accepted by the Company only if there are important business reasons. Travel, accommodation and other expenses associated with the provision of such free services are always paid for by the Company. The Company may establish rules for accepting gifts.

 

Employees must avoid circumstances and situations where their private interests could conflict with those of the Company. The Company expects that employees will make appropriate, rational decisions in all cases and will not seek personal gain in the performance of their duties.

 

Employees of the Company may accept or provide official business gifts (such as souvenirs), gifts for representation, as well as gifts in accordance with international business protocol or traditions, and display or accept business hospitality (e.g., attend business lunches, formal dinners, exhibitions, conferences, etc.), if such gifts or hospitality are appropriate for business relations, have a clear purpose of business relations, are intended to promote the Company’s services, brand awareness and strengthen the Company’s image.

 

In all cases, employees should exercise prudence in evaluating or accepting business gifts and other benefits offered to them and evaluate whether they are intended to have an unlawful effect and whether such gifts or other benefits offered to employees go beyond normal fair business practice.

 

Support may not be used as a disguised means of bribery and / or a measure to affect trade.

 

Impact trading is defined as the illegal actions of an employee of the Company in the exercise of his or her duties, powers granted and kinship and / or acquaintances in the work environment, or other likely influence to influence other employees, other companies, institutions or organizations to act lawfully or unlawfully (or, conversely, to not act) using their powers.

 

The Company shall require that all its procurements be carried out in a transparent manner, in accordance with the requirements of equality, non-discrimination, mutual recognition, proportionality and impartiality, and the rational use of funds for the procurement of goods, services or works.

 

In the event of a conflict of interest and / or suspicion that such a conflict may arise, the Company’s employee must immediately inform his / her line manager or his / her authorized person and withdraw from the discussion and decision-making related to the conflict of interest.

 

Necessary and appropriate precautions shall be taken in cooperation with third parties, such as partners or suppliers. Specific problematic cases are investigated and the necessary precautions and actions are taken to eliminate or reduce the risk of bribery and corruption involving third parties.

 

Each employee of the Company is personally responsible for compliance with the provisions of the CPP.

 

The daily establishment of the CPP is part of the responsibility of the Company’s head. The head of the Company is responsible for the implementation of appropriate actions and internal control measures to prevent and detect bribery and corruption.

 

Employees of the company are encouraged to express concerns. Any employee of the Company who suspects violations of this policy must inform the director of AKVATERA LT, UAB about them. The Company clearly and unambiguously provides a guarantee of complete confidentiality, data protection, non-disclosure and non-dismissal guarantee to all notifiers.

 

Any acts or conduct that may be considered corruption or bribery must be corrected immediately.