Guidelines for corruption and bribery risk prevention

In order to ensure a proper risk management of corruption, bribery and conflicts of interests, Altum have created an internal control system that ensures a preventive risk management and a control environment that is focused on preventing corruption risks eliminating conflict of interests and corruptive dealings and bribery in decision taking and work environment in general.

• ALTUM ethical principles are laid down in the Code of Ethics and they are relevant to all ALTUM employees. The Code of Ethics provides the professional ethical guidelines of ALTUM employees – justice and honesty, respect and tolerance, loyalty and responsibility, neutrality and non-amenability – as well as the action of employees in case of conflict of interests, behaviour when communicating with representatives of any interest groups as well as the recommended action and attitude in case of receiving a gift, entertainment offer, acts of favours and gratitude which can be taken as gift.

ALTUM have zero tolerance for bribery and corruption activities and prohibits it in any form, directly and indirectly. ALTUM shall prevent its employees and relevant third parties from getting involved in cases of bribery and corruption.

ALTUM reserve the rights to waive a relationship with a third party, if there is suspicion about possible corruption or bribery case.

ALTUM do not make donations but support organizations, events, projects and programmes according to the public support guidelines.

ALTUM acknowledge that giving gifts and ensuring company’s hospitality in order to pay respect, recognition or gratitude is normal and legal part of business. However, in cases when gifts or company’s hospitality values can be described as non-proportional or irrelevant to circumstances, it can seem that the gift or hospitality badly affects or can affect the recipient. Such practice can be taken as bribery or corruption. In order to prevent it, ALTUM have laid out gift acceptance principles.

One of the goals of ALTUM’s corruption and bribery risk prevention programme is to create and maintain an environment in which bribery and corruption is not acceptable in any cases. Therefore, ALTUM promotes the awareness and knowledge on aforementioned matters and action consequences.

In order to detect any possible bribery or corruption activity, any violation of corruption prevention laws and regulations, ALTUM rely on their employees, clients, cooperation partners and other third parties sharing business with in order to investigate the issues and report about any suspicion of possible bribery as soon as possible. For this purpose, ALTUM ensure several safe and protected channels, see Whistleblowing.

ALTUM guarantee full confidentiality of the informant’s identity, if it is authorized by legislative acts, as well as full protection against discrimination or revenge to the employees who report the issues.

ALTUM undertake to assess and, if appropriate, to investigate every action violating the guidelines of the Code of Ethics and standards of the Rules for the prevention of corruption and conflict of interest and every issue laid down as possible action of bribery and corruption as well as carry out corresponding disciplinary activities.