Anti-bribery policy

Introduction

Purpose
The purpose of Brimborg’s anti-bribery policy is to prevent bribery in every respect. The management and staff of Brimborg are strictly forbidden from bribing others or accepting bribes. Bribery by proxy such as through a representative, advisor, or distributor is prohibited.

Scope and field of application
This anti-bribery policy addresses various contexts in which bribery issues may arise. Other aspects of business ethics and corruption, including conflicts of interest and indirect bribery, are also covered.

Rules

Definition
Bribery is the offering, giving, or promising of items of unreasonable value, directly or indirectly, for the purpose of influencing or rewarding someone in order to improve or maintain a business position.

Basic principle
Always ask yourself before offering, giving, or promising anything of value to any party whether the purpose of doing so may be considered unlawful. If yes, you must not perform the action.

Before agreeing to personally accept anything of value, ask yourself whether this is a reasonable act.

Bribery can take many forms, such as offering or giving money or something else of value. It must be kept in mind that common business practices or social activities such as gift-giving may be considered bribery in some circumstances.

Gifts and hospitality
Gifts or hospitality must be modest, fair and infrequent. If a manager or employer decides to give or receive a gift/hospitality at a value above ISK 15,000, he or she must report it to Human Resources, who keeps a record of all such gifts/hospitality.

Promising or offering gifts or hospitality for the purpose of achieve something for Brimborg is never permitted. Accepting gifts or hospitality intended to influence an employee’s business conduct is also never permitted.

Grants, donations, and sponsorship
Brimborg may provide outside parties grants or support, but never for commercial purposes.

Grants and support for political parties
If Brimborg supports political parties, each party must receive an equal donation in accordance with the size of the party.

If political parties wish to present their platform at Brimborg, access must be available to anyone interested.

Protection of interests
Brimborg is authorised to protects its interests and the interests of the industry through active participation in interest organisations. For example, the company prepares and provides information to the benefit of its own cause. However, all bribes are forbidden here as elsewhere.

New entities
When entering into a contract with new suppliers or other commercial entities, it is necessary to ensure that all communication and commerce is normal.

Risk assessment

	Remarks/risk reduction	Assessment
Brimborg employees bribe others
	Risk reduction
Gifts and hospitality	Secure financial accounting, employees not receiving a bonus	Low risk
Grants, donations, and sponsorship	Secure financial accounting, few have the authority to decide	Low risk
Support for political parties	Secure financial accounting, clear rules, few have the authority to decide	Low risk
Protection of interests	Secure financial accounting, few have the authority to decide	Low risk
New entities	Secure financial accounting, few have the authority to decide	Low risk
Brimborg employees accept bribes
Gifts and hospitality	Employees not receiving a bonus, keeping a record of gifts and hospitality	Average risk
Grants, donations, and sponsorship	Few have the authority to decide	Low risk
Support for political parties	Clear rules, few have the authority to decide	Low risk
Protection of interests	Few in communication	Low risk
New entities	Extensive due diligence check	Average risk

 

Implementation

Teaching and training
The director of human resources is responsible for informing all employees of this policy. All new hires receive a copy of the policy to read over and sign upon hiring.

Accounting and recording system
All financial transactions must be accounted for and appear in Brimborg’s books. Nothing may be off the books.

Monitoring
As previously stated, the department of human resources must maintain a record of all gifts that exceed ISK 15,000. The director of human resources must monitor gifts and report and discuss matters with company management as necessary.

The CEO and departmental directors as well as middle management must be attentive of these issues and report if suspicions of possible bribery arise.