The purpose of this Anti-Corruption Policy is to detect and prevent corruption related to Appmore Ltd. Appmore Ltd has a zero-tolerance approach towards all forms of corruption. This approach is already established and set out in Appmore Ltd’s Code of Conduct.
This policy shall be applied to the board of directors, partners, and managers as well as all employees of the Appmore Ltd. This policy supplements the Code of Conduct and policies, rules, and task-specific instructions regarding gifts, hospitality, and entertainment.
Where applicable this policy shall comply with legislation and separate instructions.
Corruption is a specific form of fraud that is defined as the abuse of entrusted power for private gain.
A facilitation payment is any facilitating or expediting payment to a foreign official, political party, or party official the purpose of which is to expedite or to secure the performance of routine governmental action, such as obtaining permits, licenses, or other official documents or processing governmental papers, such as visas and work orders. All Stakeholders are prohibited from directly or indirectly giving, promising, authorizing, or offering money or anything else of value to anyone in connection with business dealings in order to obtain an improper advantage. Facilitation payments are a form of corruption and are strictly prohibited.
Business gifts, charity, and other donations as well as a political activity are regulated in Appmore Ltd’s Code of Conduct and other guidelines.
The Board of Directors conducts oversight of this policy.
This policy is approved by The Board of Directors based on CEO’s proposal. Directors and managers are responsible for introducing and communicating this policy to all employees. The security manager is accountable for the interpretation and evaluation of this policy as well as annual anti-corruption training for all employees.
Accountability for implementing this policy in daily business is with respective management. Members of the respective management teams need to be familiar with the types of bribery and corruption that might occur within his/her area of responsibility and be alert for any indication of irregularity.
The respective management is responsible for ensuring that an adequate system of internal controls exists within areas of responsibility and that such controls operate effectively.
All employees are required to:
conduct themselves in accordance with legislation, Appmore Ltd’s Code of Conduct, this policy, and all other company policies
act with propriety and integrity
inform via supervisor or via Appmore service portal immediately when violations are discovered or suspected.
To ensure independence, any employee who suspects a violation of this policy is not allowed to personally conduct investigations related the corruption.
The products and services of third parties are needed in Appmore Ltd business activities. As Appmore Ltd may be liable for a third party’s improper action, it is essential to perform adequate due diligence on third parties. The appropriate level of due diligence will be estimated case by case based on the business relationship.
Contracts with third parties must be in writing and recorded. For new business relationships, due diligence report should be created if applicable.
Payments made to third parties should represent no more than an appropriate. No payments shall be made without a detailed invoice that accurately describes the services provided and expenses incurred.
All information received related to the investigation will be treated with confidence. The results of the investigation will not be disclosed or discussed with anyone other than those who have a legitimate need to know.
