Anti-Bribery Policy
1. INTRODUCTION
Evelors Solutions BV (hereinafter ‘Evelors’ or ‘the company’) is committed to conducting its business with the highest ethical standards and in compliance with all applicable anti-bribery and anti-corruption laws. This Policy outlines Evelors’ approach to preventing and prohibiting bribery and corruption in all aspects of company’s business operations.
2. DEFINITION
Bribery within Evelors is defined as the offering or accepting of gifts, loans, payments, rewards, or advantages for personal gain, with the intent to encourage dishonest, illegal, or trust-breaching actions in the course of business.
Corruption, characterised by the misuse of office or power for private gain, encompasses bribery, involving the exchange of money, gifts, meals, entertainment, or other valuable items to induce dishonest or illegal conduct.
Recognising bribery as a criminal offence, Evelors strictly prohibits any form of bribery. The company mandates compliance with the highest ethical standards and applicable anti-bribery laws from all individuals associated with the company’s business.
Upholding integrity and transparency, Evelors maintain a zero-tolerance stance towards corrupt activities, whether initiated by its employees or third parties acting on its behalf.
3. PURPOSE
The purpose of this Policy is to convey to all employees and interested parties of Evelors the rules of the company in relation to its unequivocal stance towards the eradication of bribery and corruption and the company’s commitment to ensuring that Evelors conducts its business in a fair, professional and legal manner.
4. ZERO TOLERANCE FOR BRIBERY
Evelors has a zero-tolerance Policy for any form of bribery or corruption. All employees, contractors, consultants, and third parties acting on behalf of the company are strictly prohibited from engaging in bribery or corrupt activities.
5. OFFENCE
Engaging in certain actions constitutes a criminal offence under the law, including:
- Offering a bribe;
- Accepting a bribe;
- Bribing a foreign official;
- Failing, as a commercial organisation, to prevent a bribe.
It is important to note that being found guilty of bribery in court may result in severe consequences, including up to 10 (ten) years of imprisonment and/or an unlimited fine for individuals. Additionally, the company itself could face prosecution and be subject to financial penalties. All personnel are expected to remain informed of applicable laws and maintain full compliance at all times.
6. APPLICABILITY
This Policy applies to all individuals working for Evelors Solutions BV, including employees at all levels, directors, officers, contractors, consultants, and any other parties acting on behalf of the company. It also extends to anyone working for or on Evelors’ behalf, e.g. including those on a self-employed basis or an agency arrangement.
Evelors will encourage the application of this Policy where its business involves the use of third parties, e.g. suppliers, contractors.
7. PREVENTION OF CORRUPTION
All employees, regardless of their position, are responsible for preventing corruption. This includes:
a) Distinguishing between gifts and bribes:
Employees should understand the difference between acceptable business gifts and entertainment and improper bribes. See the attached guidelines for examples;
b) Recognising types of corruption:
Employees shall familiarise themselves with various forms of corruption that may occur in the business context, including bribery, extortion, embezzlement, and money laundering;
c) Avoiding conflicts of interest:
Understand and adhere to the rules regarding conflicts of interest, and take appropriate steps to avoid or address potential conflicts.
8. POLICY
It is prohibited, directly or indirectly, to offer, give, request or accept any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or company in order to gain commercial, contractual or regulatory advantage for Evelors, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.
It is further prohibited to influence any individual in their capacity as a foreign public official. Personnel and third parties acting on behalf of Evelors must not make any payments to a third party at the request of, or on behalf of, a foreign public official.
If Evelors personnel are offered a bribe, or if a bribe is solicited from them, they must refuse the offer unless their immediate physical safety is in jeopardy. In any such event, the individual must immediately contact their direct superior or the Compliance Officer so that appropriate action can be taken. A written account of the events may be required.
Any employee, contractor, or person working on behalf of Evelors who suspects that an act of bribery or attempted bribery has taken place — even if not personally involved — is expected to report the matter immediately to their direct superior or the Compliance Officer.
Appropriate checks will be made before engaging with suppliers or other third parties of any kind to reduce the risk of Evelors’ business partners breaching the company’s anti-bribery rules.
The company will ensure that all its transactions, including any sponsorships or donations made to charity, are conducted transparently and in a legitimate manner.
Evelors takes any actual or suspected breach of this Policy extremely seriously and will carry out a thorough investigation should any instances arise.
Evelors will uphold laws relating to bribery and will take disciplinary action against any employee, or other relevant action against persons working on the company’s behalf or in connection with it, should it be found that an act of bribery, or attempted bribery, has taken place. This action may result in dismissal for employees or the cessation of the arrangement for those who are self-employed, agency workers, contractors, etc.
9. RISKS AND CONSEQUENCES
Failing to prevent corruption poses serious risks to Evelors business and reputation. Violations of this Policy may result in disciplinary action, including termination of employment, legal action, and potential damage to the company’s reputation.
10. MONITORING AND REVIEW
Evelors is committed to regularly monitoring and reviewing this Policy to ensure its effectiveness. The company encourages employees to report any concerns or potential violations through its confidential reporting mechanism (further details of which are available from the Compliance Officer).
11. REDUCING AND CONTROLLING RISKS
The company will continually assess and implement measures to reduce and control the risks of bribery and corruption. This includes periodic risk assessments, training programmes, and the implementation of internal controls.
12. GIFTS, HOSPITALITY, AND DONATIONS
Employees must not solicit or accept gifts, hospitality, or donations that could compromise their integrity or create a perception of impropriety. Any offers of such items must be reported to an appropriate contact.
Evelors recognises that giving and receiving gifts and hospitality — where no reciprocal favour is expected — helps form positive relationships with third parties where it is proportionate and properly recorded. This does not constitute bribery and, consequently, such actions are not considered a breach of this Policy.
Gifts include: money; goods (flowers, vouchers, food, drink, event tickets when not used in a hosted business context); services or loans provided or received as a mark of friendship or appreciation.
Hospitality includes: entertaining; meals or event tickets (when used in a hosted business context), provided or received to initiate or develop relations. Hospitality is reclassified as a gift if the host is not present.
No gift must be given, and no hospitality may be offered by an employee or anyone working on Evelors’ behalf to any party in connection with the company’s business without receiving prior written approval from a direct superior. Similarly, no gift or offer of hospitality must be accepted by an employee or anyone working on Evelors’ behalf without receiving prior written approval from a direct superior.
A record will be made of every instance in which gifts or hospitality are given or received.
As the law is constantly changing, this Policy is subject to review, and the company reserves the right to amend this Policy without prior notice.
13. BUSINESS CONDUCT GUIDELINES
All employees are expected to conduct business in a manner that upholds the highest ethical standards. This includes proper handling of contracts, accurate reporting, and interpretation of offered hospitality.
Evelors is steadfast in maintaining the highest standards of integrity and ethical conduct. This Policy serves as a guide for employees to align their conduct with Evelors’ commitment to preventing bribery and corruption.