Anti-Corruption Policy
I. Introduction
- The Company follows a strict zero-tolerance approach towards any form of corruption, meaning any unlawful or unethical conduct.
- The Anti-Corruption Policy, together with the Company’s Code of Ethics, forms a core document within the Company’s framework for managing the prevention of corrupt behaviour. Its purpose is to set out the key principles the Company upholds in this area.
- This Anti-Corruption Policy applies to all Company coworkers as well as to third parties, in particular the Company’s business partners.
- The policy is further supported by internal Company guidelines, including the internal anti-corruption directive through which the Company implements the objectives defined in this Policy, and the internal guideline for business partner due diligence.
The Company maintains a zero-tolerance stance towards corruption and criminal activity. It does not tolerate any form of unlawful or unethical conduct and condemns such behaviour.
II. Objectives of the Anti-Corruption Policy
- The main objective of the Anti-Corruption Policy and its related internal guidelines is to define the required standard of conduct in relation to corruption, bribery, unlawful behaviour and conflicts of interest, in particular by:
- setting binding rules of conduct that the Company and its coworkers must follow when performing their duties or in connection with them, as well as in dealings with third parties;
- establishing the responsibilities of the Company and its coworkers with respect to corruption, bribery, conflicts of interest and general legal compliance;
- expressing the Company’s commitment to its business partners and third parties regarding compliance with legal requirements, the fight against corruption and bribery, and observance of conflict-of-interest rules;
- providing coworkers with information necessary to identify and address issues related to corruption, bribery and conflicts of interest;
- describing the consequences of failing to comply with the Company’s anti-corruption requirements;
- informing the Company’s business partners of the principles of the Company’s anti-corruption management system and requiring adherence to the same standards.
- Additional specific objectives are regularly defined in cooperation with the Company’s management and are monitored and evaluated.
The primary objectives of the Company’s anti-corruption management system include setting mandatory rules for the prevention of corruption and bribery, defining rules on conflicts of interest, and establishing the responsibilities of coworkers, their obligation to comply with these principles, and the consequences of non-compliance.
III. Anti-Corruption Policy Principles
- In accordance with general ethical principles and within the scope of its business activities, the Company always acts in compliance with legal regulations and ethical standards and rejects any form of corruption. The Company maintains a zero-tolerance policy toward corruption and bribery. For this reason, the Company does not tolerate any form of corruption, including bribery and extortion
- The Company ensures compliance with legal obligations regarding the anti-corruption management system and measures against the Company’s criminal liability.
- The Company guarantees the continuous improvement of the anti-corruption management system within the Company. The anti-corruption policy is reviewed at least once a year by the Company’s management.
- The primary guarantors of the anti-corruption policy are the members of the Company’s statutory body, who are responsible for implementing the anti-corruption policy into the Company’s processes, for fulfilling its objectives, and for monitoring and reviewing the achievement of these objectives.
- To ensure impartial, fair, and objective investigations related to the anti-corruption policy, the position of compliance officer has been established to oversee compliance with anti-corruption rules.
- The Company commits to:
- always acting professionally, fairly, and honestly under all circumstances and complying with the legal frameworks and regulations of all countries in which it operates;
- to promote an effective system for combating corruption and bribery.
- The Company expects its employees to always act in accordance with the anti-corruption policy, legal regulations, internal company regulations, ethical standards, and good morals in the course of their work, while maintaining professionalism and the highest level of professional care.
- Employees are required, to the extent possible, to ensure compliance with the defined provisions and, where applicable, with equivalent or comparable regulations issued by third parties with whom the Company maintains business relationships (suppliers, customers, partners, non-profit organizations, etc.), and which require this commitment within the framework of their relationship with the Company, provided that they have been duly informed of such requirements.
- The Company expects its business partners to adopt a similar zero-tolerance approach to corruption and bribery and to familiarize themselves with the Company’s anti-corruption policy.
IV. Reporting Violations of Anti-Corruption Rules
- The Company encourages its coworkers and third parties to report any suspected violations of anti-corruption rules. The Company provides full support to coworkers and third parties in doing so. Reports may be made, among other options, to the statutory body or through the (Compliance Officer), either under one’s name or anonymously, in accordance with the reporting system described at Information about the Unicorn Vysoká škola Group's reporting system.
- The Company treats any breach of anti-corruption rules with utmost seriousness and applies appropriate consequences for each violation.
- Retaliation against individuals who submit a report is strictly prohibited.
