The basic principles described in this policy are emanating from ABTs commitment to integrity and sustainable way of doing business. Through this Policy, the General Manager explicitly demand ABT to adhere to the fundamental values of integrity, transparency and accountability, consistently throughout ABT and in all locations where the consultancy and training business is conducted, and to foster the culture of compliance in which bribery and corruption is never acceptable.

ABT has zero tolerance towards acts of bribery and corruption and prohibits them in any form, both direct and indirect. ABT will not tolerate its Employees or Third parties in any kind of relationship with ABT being involved in acts of bribery and corruption.

By committing to zero tolerance to bribery and corruption ABT commits that every behaviour in breach of the principles of this Policy and every concern raised as for possible act of bribery and corruption will be assessed and where appropriate investigated and disciplinary action will be taken in addition to the sanctions contained in the applicable regulations. No Employee will suffer demotion, penalty, or other adverse consequences for refusing to pay acts of corruption or reporting actual or attempted acts of corruption even if such refusal may result in the Group losing business. We encourage raising concerns in good faith, or on the basis of a reasonable belief in confidence, without fear of reprisal.

The above principle is enforced by an adequate risk management processes and implementing a group-wide Anti-Bribery Management System according to the requirements of ISO 37001. The strategic and key objective is „zero bribery incidents” which needs to be achieved on a continuous basis.

ABT commits to proactively combat bribery and corruption in the environment we operate.

ABT shall do this by promoting integrity and bribery and corruption-free way of doing business among the wide range of its stakeholders.

ABT is striving to be an industry role model by implementing best anti-bribery and anti-corruption standards and practices, investing into training and awareness of its Employees.

ABT is making best efforts to prevent bribery and corruption by its Third parties including deeper up or down the supply chain of our Third parties. ABT reserves the right to refrain from relationship with a Third party when doubts of possible corruption or bribery committed exist.

ABT commits to comply with local law and regulation where we operate.

ABT commits to satisfy anti-bribery management system requirements and to continually improve the anti-bribery management system.

The Anti-Bribery Representative has the authority, independence and responsibility with the supervision of the anti-bribery management system.

Date: 01.09.2018 General Manager

antibriberypolicy abt