ANTI-CORRUPTION POLICY of keeeper sp. z o.o.

Keeeper sp. z o.o. strictly applies a zero-tolerance policy towards any activities that have the appearance of corruption. As a responsible and trustworthy Company, we want to actively participate in building the trust of our business environment. The zero-tolerance policy on corruption applies to all employees of the Company, its co-workers as well as business partners of our company.

The management of keeeper sp. z o.o. is responsible for the acquisition, implementation and creation of an organisational culture in which corruption will not have the slightest chance of occurring and will be unacceptable in any form.

The Anti-Corruption Policy should be widely communicated and promoted to employees and business partners to ensure that it is properly understood, implemented and adhered to.

The purpose of the Anti-Corruption Policy is to establish uniform rules of conduct for all employees, business partners and entities in business relations with the Company. The Anti-Corruption Policy is designed to prevent and counteract abuses carried out to the detriment of the Company, and in the event that such abuses are detected, it establishes uniform rules of conduct. The procedure also aims to ensure the transparency of the Company’s actions towards its partners in the business environment.

It is our responsibility to create a safe market environment and to take measures to prevent all forms of corruption.

The Anti-Corruption Policy shall be communicated to all stakeholders of keeeper sp. z o.o. (including customers, suppliers, representatives, subcontractors and other business partners).

Definition of corruption or paid patronage

Corruption is requesting, offering, giving or accepting, directly or indirectly, a bribe or any other undue advantage or promise of advantage, which distorts the proper performance of any duty or conduct required of the person receiving the bribe, undue advantage or promise thereof. Offences of a corrupt nature are defined in the Criminal Code as actions that fulfil the elements of the offences set out in Articles 229, 230 and 230a of the same Code.

Other economic malpractices should be understood as actions that do not constitute corrupt activities, but nevertheless are contrary to the principle of fair competition or good business morals, and which constitute economic crimes or offences.

In the light of the Anti-Corruption Policy, corruption is, in particular, bribery and the legalisation of the proceeds of such practices.

Bribery is the offer, promise or giving (active form), soliciting, coercing, agreeing to receive a bribe, i.e. selling (passive form) in any form, of any value, which may be regarded as a case of inducement to bribe (active or passive), which is contrary to accepted principles of conduct, is illegal, bears the hallmarks of corruption and is unethical and violates the law.

Paid patronage/influence peddling is the invocation of influence in an institution with public funds or the inducement of a belief or reassurance in another person of the existence of such influence by offering (active paid patronage) or seeking (passive paid patronage) an intermediary to arrange a matter in exchange for a pecuniary or personal benefit (e.g. a job, contract, financial support) or the promise thereof.

 

Principles of the Anti-Corruption Policy

We act fairly, honestly, honourably and strive to act in a modern, dynamic and friendly manner. We are committed to openness and transparency in our actions. Thanks to this attitude, our entire business environment, in particular both our customers and suppliers, perceive us as a responsible and trustworthy Company.

We act in accordance with applicable laws. Keeeper Ltd. adopts a zero-tolerance policy on corruption and paid patronage in all aspects of its business.

In accordance with the adopted Policy, the following actions are prohibited at all times and in any form, whether indirect or direct, both within our company and with its stakeholders

  • bribery,
  • extortion or inducement,
  • paid patronage,
  • legalising the proceeds of corruption.

A person who reports a suspicion of wrongdoing or refuses to engage in corruption or paid patronage will not face negative consequences for his or her decision.

Compliance with applicable laws and international conventions

In most countries, the act of bribery or attempted bribery is treated as a criminal offence with significant criminal sanctions in the form of fines or imprisonment, applicable to both companies and employees.

Some of these laws are international acts of universal application aimed at combating bribery and corruption (e.g. the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, the United Nations Convention against Corruption).

Corruption risk areas (corruption risks)

Legitimate gifts and invitations (meals, events, entertainment) can support the process of making,
maintaining and developing meaningful business relationships.
It is keeeper’s intention that its employees should not feel exposed in such situations to accusations of maintaining business relationships by engaging in behaviour that does not comply with applicable standards and regulations. Giving or receiving gifts in a manner deemed inappropriate may expose both our employees and the Company to accusations of violating corruption laws.

Therefore, before you accept a gift or before you offer it to someone, you should make sure that your action is in accordance with the rules adopted at keeeper sp. z o.o..

The following are examples of actions that we consider unacceptable:

  • giving, promising to give, offering or soliciting a gratuity in the form of payment, a gift, a trip, an invitation or any other benefit in order to achieve a specific business advantage or as a thank you for achieving a business advantage,
  • giving, promising to give, offering a gratuity in the form of payment, a gift, a trip, an invitation (meals, entertainment) or any other consideration to a government official or intermediary for the purpose of facilitating or speeding up the performance of a routine procedure,
  • promising to pay or accepting payment from a third party where you suspect or have reason to believe that they expect a specific business advantage in return,
  • accepting or promising to accept gifts, trips, invitations (meals, parties, entertainment) or other benefits from third parties.

We do not accept or give bribes (financial gratuities). Such gratuities are usually monetary amounts to guarantee or speed up the routine actions of administrative staff. If you find yourself in a situation where you have no choice but to give a bribe, due to the threat to your life, health or freedom do whatever is necessary to protect yourself and then report the incident to your supervisor as soon as possible. We expect third parties to apply the principles of our Policy with due diligence.

 

Measures to prevent corruption and paid patronage

Awareness raising and training

The Anti-Corruption Policy as one of the elements of the management system is communicated both internally and externally.

Keeeper sp. z o.o. conducts awareness-raising and regular employee training, including mandatory training for employees most at risk of corruption, regardless of their position.

The company provides its managers, employees and co-workers with appropriate guidelines to identify and prevent the risk of corruption in their relations with business partners (representatives, consultancies, suppliers, distributors, subcontractors, contractors’ collaborators).

Obtaining advice and information

If you are unsure of how to act in a situation where there is a risk of corruption or paid patronage, you should contact your supervisor, the Management Violations Officer appointed by the Board of Directors.

The prevention, detection and reporting of bribery as well as other forms of corruption and cases of paid patronage is our responsibility as well as the responsibility of those who work under our supervision. All keeeper employees are obliged to avoid any action that could lead to a breach of this principle.

If you suspect that such a violation has occurred, or may occur in the future, you should immediately report it to your supervisor, or the Board’s designee.

Fraud reporting mechanism

keeeper Ltd. has a mechanism for reporting corruption and paid patronage and crimes or fraud related to accounting, internal control and auditing. Suspected violations of keeeper sp. z o.o.’s Anti-Corruption Policy or other laws can be reported through the same channel used to report all kinds of
unethical conduct:

  • ask your supervisor directly and, if necessary, the Board of Management’s Violations Officer.
  • Another form of reporting available is by e-mail to the confidential e-mail address: naruszenie.prawa@keeeper.pl.

Employees of keeeper sp. z o.o. , acting in good faith, may report their concerns or seek advice in the event of a suspected violation of the Anti-Corruption Policy or other laws, without fear of reprisals, acts of discrimination or disciplinary proceedings. Reports are treated confidentially and investigated with due diligence.
Reports made in bad faith may expose the author to disciplinary and legal consequences.

Data from which the identity of the reporting person can be established may be disclosed only with the consent of that person, unless they are disclosed at the request of an authorised authority acting under the law, in particular at the request of a court or a public prosecutor.

Data from which the identity of the person named in the report can be established may be disclosed only when the report is considered legitimate, unless they are disclosed at the request of an authorised authority acting on the basis of the law, in particular at the request of a court or a public prosecutor.

Record keeping, transparency and audit procedures

Keeeper`s sp. z o.o. procedures to guarantee the integrity of its books and records ensure that financial statements cannot be used to conceal corrupt or paid patronage activities.

All books, invoices, notes and other documents relating to transactions with third parties such as customers, suppliers and other business partners must be prepared, stored and audited to the highest level of accuracy and completeness.

An employee in a situation where payments are made on behalf of the company must always be aware of the purpose of the payment and assess whether it is proportionate to the product or service. It is incumbent on the employee to always obtain a receipt or invoice indicating the reason for the payment.

If the employee has any doubts or questions regarding payments, he or she should contact his or her supervisor or the Board’s designee.

Procedures are in place at keeeper sp. z o.o. to ensure the secure storage of documents indicating the correct implementation and effective application of the anti-corruption and influence trading rules.

Risk mapping

At keeeper sp. z o.o., corruption risk mapping is applied and regular updates are made in this respect.

Management of the Anti-Corruption Policy

The Management Board of keeeper sp. z o.o. is responsible for ensuring that the Anti-Corruption Policy is in line with the legal system, good practices and accepted standards of business ethics, and that the provisions of the Policy are properly implemented and adhered to by employees.

The Management Board reviews the effectiveness of the anti-corruption measures on an ongoing basis, but at least once a year and depending on the needs and cases that arise.

 

____________________ ____________________
Grzegorz KICERMAN
Board member
Managing Director
Tomasz WOŹNIAK
Board member
Managing Director Sales and Marketing