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Integrity policy

Integrity policy of Ethicontrol (hereinafter - the "Company") is aimed at conducting business on the basis of honest and ethical behavior in relations with employees and third parties. As part of this, the Company pursues a policy of zero tolerance for bribery and corruption and strives to act professionally, responsibly and conscientiously in all business relationships and areas of the Company's practice, while observing and ensuring effective mechanisms for preventing occurrences of corruption and combating bribery.  

The company complies with all regulatory and legal acts related to the fight against bribery and corruption both in EU, Estonia, Ukraine (Law of Ukraine "On Prevention of Corruption") and in other jurisdictions in which it operates (U.S. FCPA, UK Bribery Act and others ).

In this policy, the term "Third Party" means any individual or organization with whom we come into contact in the provision of services and business management, and includes existing and potential customers and customers, intermediaries, suppliers, contractors, agents, consultants, as well as state institutions and organizations, local authorities, including their representatives and officials, politicians and political parties.

This policy applies to all employees of the Company at all levels (whether employed on a permanent, temporary or part-time basis), consultants, contractors, interns, volunteers, agents, or any other person who relates to the Company (collectively, hereinafter referred to as "Employees" in this policy).

Anti-bribery

Bribery (illegal benefit) - money, tangible things, advantages, benefits, services, intangible assets that are promised, offered, provided without legal grounds to a person endowed with certain powers to stimulate him using such powers to act in the interests of the person that they conveys or offers. Bribery is a criminal offense and consists of offering or giving, receiving or requesting/demanding a bribe.

The Company is aware of the responsibility assigned to it in matters of combating manifestations of corruption and bribery, and the risks associated with the possible involvement of Employees in such illegal activities.

Gifts and hospitality

This policy does not prohibit normal ethical behavior that involves appropriate hospitality, friendliness, courtesy, including in matters of giving and receiving gifts, treats and providing free services. However, we have specific internal policies and procedures to ensure that Employees have a correct and clear understanding of what should be considered normal ethical behavior within financial constraints and the principles set out below (the guiding principles), namely that any what gifts:

  • must not be made with the purpose of inducing certain actions or inactions, or would lead to an advantage or bias, or could be considered a bribe;
  • must comply with local legislation, customs of business etiquette;
  • must be donated on behalf of an organization and not on behalf of an individual;
  • must not be in the form of cash or other monetary equivalent;
  • must be acceptable and appropriate in the given circumstances;
  • must correspond to the generally accepted understanding (not to cause surprise) regarding the characteristics of such gifts, including valuables, a reason for donating them;
  • must be given as a gift openly, not secretly.

In any case, gifts must not be offered or accepted from persons vested with the authority of state authorities or local governments, or their representatives, or politicians or political parties, without the prior consent of the Company's CEO.

Employees of the Company under no circumstances are allowed to give any gift to a Government official who makes or may make decisions in favor of the Company (for example, members of the tender commission, employees of regulatory and tax authorities, etc.). It is necessary to avoid frequent gifts to the same public servant, as repeated gifts may be a sign of wrongdoing. Examples of acceptable gifts to Government Employees include promotional products with the Company logo, such as calendars, pens, whistles, small flasks, coffee mugs, etc., subject to the restrictions set forth above.  

The following is not acceptable for any Employee (or a person acting on their behalf):

  • give, promise to give, or offer money, a gift, or show excessive hospitality with the expectation or expectation that an advantage will be conferred by it or because such an advantage has already been accorded;
  • transfer, promise to transfer, or offer money, a gift, or show excessive hospitality to public officials, subjects of authority, or their representatives for the "facilitation" or acceleration of routine procedures;
  • to accept payment from Third parties, in respect of which it is known in advance or it can be reasonably assumed that such payment involves the receipt of benefits by them;
  • accept a gift from a Third Party that is known in advance or reasonably believed to be offered with the expectation that the Company will confer some reciprocal advantage on such Third Party;
  • threaten or harass an Employee who refuses to participate in bribery, or discloses such bribery, or expresses concern about compliance with this policy;
  • engage in any activity that may violate this policy.

Payment for "facilitation" and "kickbacks"

We do not pay or accept payments aimed at simplifying formalities, unofficial acceleration of formal procedures or "kickbacks" of any kind, including in the form of small informal payments.

Donation

The company may make donations and make charitable contributions that comply with local laws and moral principles.

Duties and responsibilities

Everyone who works for us or is under our control is responsible for warning, detecting and reporting bribery and other forms of corruption. Employees must avoid any activity that may violate this policy.

The employee is obliged to notify the Company as soon as possible if he believes that a situation is occurring or may occur in the future that is inconsistent with this policy, if a bribe is demanded or offered from him, or if he believes that he is involved in another type of illegal activity

An employee who violates this policy may be subject to disciplinary action, which may result in termination. We reserve the right to terminate our contractual relations with Third Parties if their actions have a corrupt component and may damage the Company's business reputation.

If any person becomes aware of circumstances regarding the actions of our Employees or the activities of Third Parties that have signs of corruption or violation of this policy, he can report such facts directly to one of the directors or co-founders of the Company.

Trainings and communications

For all Employees, group trainings and individual explanatory work on the proper observance of this policy and compliance with its requirements have been implemented. Also, in an appropriate way, we inform Third parties of our application of approaches that involve absolute intolerance to bribery and corruption.

Monitoring and control

The company constantly monitors and controls the implementation of this policy at certain intervals, analyzing its application for appropriateness, adequacy and effectiveness. Internal control systems and procedures are also subject to regular review to ensure that they are effective in combating bribery and corruption.

All our employees are aware that they are responsible for the successful implementation of this policy and must use it to uncompromisingly expose and combat corruption.

Cases of ambiguity and uncertainty

All possible cases of ambiguity and uncertainty in this Policy should be interpreted by Employees in a stricter direction and subject to conservative interpretation.

In case of detection of incidents and situations with employees of the Company, which arose as a result of incorrect or peculiar interpretation of ambiguities of the Policy, such incidents will not be resolved in favor of the employee.