Anti-Bribery and Anti-Corruption Policy

AB Linas Agro Group and its subsidiaries (hereinafter – the Group) are against bribery and corruption of any form, any manifestations of trading in influence, and conflicts of interest. We strive for open competition and ethical terms and conditions of trade, as well as we comply with the legal systems of the countries where we operate.

The major provisions of the Anti-Bribery and Anti-Corruption Policy (hereinafter – the AAP) of the Group are as follows:

1. The Group shall not tolerate bribery or corruption in any form. Corruption is a misuse of entrusted powers while seeking personal gain. It is described as acts or omissions intended for obtaining (either directly or indirectly) material gain or any other kind of gain personally or for another person for the performance or non-performance of their duties or accepting such a gain, as well as offering, promising or granting (either directly or indirectly) material gain or other personal gains to a person for the performance or non-performance of his or her duties. Bribery is offering, giving, authorizing giving, requesting, accepting, or receiving financial or other benefits intended to encourage the inappropriate performance of relevant functions or misuse of a person’s position. Bribery can take various forms, including but not limited to giving cash or valuable gifts, covering travel and entertainment expenses, providing and/or offering career opportunities, leaking valuable and commercially relevant information, etc.
2. Employees of the Group are prohibited from (either directly or indirectly) offering, giving, authorizing giving, requesting, accepting, or receiving a bribe, including through any third party. It is also prohibited to provide financial instruments to other parties in a way that could be considered as negligent financing of corruption. Necessary and appropriate precautions should be taken to ensure that money paid to third parties, such as agents, partners, sellers, and consultants, is not used for corruption purposes.
3. The AAP applies to all employees of the Group (including any persons engaged under civil agreements, as well as any consultants, intermediaries, and other persons engaged to act on behalf of the Group, irrespective of the form of their relations with the enterprise concerned and the applicable remuneration form).
4. In the performance of their duties, the employees of the Group are prohibited from accepting any gifts that may cause a conflict of interest or that may be considered to be exceeding the normal commercial practice and allowing the presumption that the purpose of such a gift is to find favor with the employees or to influence the decisions made by the employees.
5. The Group prohibits offering and presenting gifts in any form, where such gifts are given in order to secure an unfair advantage or to bias the gift recipient’s decisions in respect of the Group.
6. Employees must avoid circumstances and situations in which their private interests could conflict with the interests of the Group. The Group expects its employees to make appropriate and rational decisions in all cases, without seeking their personal gain.
7. Employees of the Group may accept or give official business gifts (e.g., souvenirs), representation gifts, as well as gifts in accordance with international business protocol or traditions, and show or accept business-related hospitality (e.g., participate in business lunches, official dinners, exhibitions, conferences, etc.), if such gifts or hospitality are appropriate in terms of maintaining business relations, have a clearly stated purpose of maintaining business relations, or are aimed at promoting the services provided by the Group, brand awareness and strengthening the image of the Group.
8. In all cases, when giving or accepting business gifts or other benefits offered, employees must follow the principle of reasonableness and assess whether the purpose of such gifts is to make an unlawful influence or not, and whether such gifts or other benefits offered to employees go beyond the normal practices characteristic to fair business relations or not.
9. Support may not be used as a hidden instrument for bribery and/or trading in influence.
10. Trading in influence is understood as unlawful actions of an employee of the Group where the employee, based on his position, powers granted, family relations and/or connections in the workplace environment or any other likely influence, seeks to influence other employees, other companies, institutions or organizations, so that the said persons make actions or, conversely, omissions (lawfully or unlawfully), while exercising their powers.
11. The requirement of the Group is that all procurements are to be carried out in a transparent manner and in line with the equality, non-discrimination, mutual recognition, proportionality, and impartiality requirements, while rationally using the funds for the purchase of goods, services, or works.
12. In the event of a conflict of interest and/or suspicion that such a conflict may arise, an employee of the Group must inform the line manager or his authorized representative immediately and abstain from participation when discussing any issues and taking decisions related to the conflict of interest in question.
13. Necessary and appropriate precautions shall be taken in cooperation with third parties, such as partners, suppliers, and agents. Specific problematic cases shall be investigated and the necessary precautions and actions shall be taken to eliminate or reduce the risk of bribery and corruption related to third parties.
14. Each employee of the Group is personally responsible for compliance with the AAP provisions.
15. The day-to-day implementation of the AAP is a part of the responsibility of the manager of each company of the Group. The manager of each company is responsible for implementing appropriate actions and internal controls to prevent and disclose any instances of bribery and corruption.
16. Employees of the Group are encouraged to reveal any problems. Any employee of the Group who suspects that infringements of this policy are taking place must notify AB Linas Agro Group. The Group gives a clear and unambiguous guarantee of total confidentiality, data protection, non-disclosure and non-victimization for all those giving relevant notice.
17. Any activity or conduct that may be considered to be an instance of corruption or bribery must be corrected immediately, and such activity shall be subject to disciplinary action.