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Anti Bribery and Corruption

Version 3.0

Effective date: 31st July 2023

Netstock Operating LLC, its subsidiaries and its associates (“Netstock”, “us”, “we”, or “our”) operates the https://www.netstock.com/, https://www.inventoryadvisor.co websites and SaaS applications (the “Service/s”).

1. Purpose

This page informs you of our policy regarding observing and upholding our zero-tolerance position on bribery and corruption.

2. Scope

2.1 This policy applies to all employees (permanent or temporary), consultants, contractors, or any other person or persons associated with Netstock Operating LLC, its subsidiaries and its associates “the company” (including third parties), no matter where they are located. The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.

2.2 In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public Parties.

2.3 Any arrangements our company makes with a third party is subject to clear contractual Terms.

3. Applicable Laws

This policy seeks to comply with the requirements of the following laws:

3.1 FCPA
3.2 Bribery Act 2010
3.3 Australian Criminal Code
3.4 German Criminal Code

4. Objectives

4.1 To communicate our commitment to observing and upholding a zero-tolerance position on bribery and corruption.

4.2 To provide information to employees, customers, partners, suppliers and other relevant parties with information to help recognise and deal with bribery and corruption issues

4.3 To help employees understand their responsibilities with regards to maintaining our zero-tolerance position.

5. Commitment:

5.1 The company is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented.

5.2 The company has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, in whichever territory we operate.

5.3 The company will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate.

5.4 Bribery includes corruptly offering, promising, authorising or paying anything of value to any foreign official, any foreign political party or official thereof, any candidate for foreign political office, or any other third party in order to influence them for the purpose of obtaining or retaining business, or securing some other improper advantage.

5.5 We commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously.

6. Accounting: Books and Records and Internal Controls:

6.1 The Company is required to maintain a system of internal accounting controls and make and keep accurate books and records which, in reasonable detail, fairly reflect transactions and dispositions of assets.

6.2 False, misleading or incomplete entries in such records or in other documents are prohibited as a matter of Company policy and may violate law.

6.3 No undisclosed or unrecorded fund or account may be established for any purpose.

6.4 A system of accounting controls shall be maintained that provides reasonable assurances that:

6.4.1 transactions are executed in accordance with management authorisation;
6.4.2 transactions are recorded so as to permit preparation of accurate financial statements and to maintain accountability for assets;
6.4.3 access to assets is permitted only in accordance with management authorisation;
6.4.4 appropriate auditing functions are conducted.

7. Gifts and Hospitality:

7.1 This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties.

7.2 Employees are prohibited from accepting gifts or giving a gift to a third party in the following situations.

7.2.1 It is made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.
7.2.2 it is given in the employee’s name and not in the name of the Company.
7.2.3 It includes cash or a cash equivalent ( e.g. a voucher or gift certificate ).
7.2.4 It is not of an appropriate type and value and given at an appropriate time (eg. during a tender process).
7.2.5 It is given in secret and not openly.

7.3 We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another.

7.4 The test to be applied is whether in all the circumstances the gift or hospitality is reasonable, justifiable and is proportionate. The intention behind the gift should always be considered.

8. Facilitation Payments and Kickbacks:

8.1 The company does not accept and will not make any form of facilitation payments of any nature.

8.2 We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action.

8.3 We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.

8.4 The company does not allow kickbacks to be made or accepted.

8.5 We recognise that kickbacks are typically made in exchange for a business favour or advantage.

9 Political Contributions:

9.1 The company will not make donations, whether in cash, kind, or by any other means, to support any political party or candidates.
9.2 We recognise this may be perceived as an attempt to gain an improper business advantage.

10 Forbidden conduct:

10.1 give, promise to give, offer or accept a payment, gift or hospitality with the expectation or hope that a business advantage will be received or provided, or to reward a business advantage already given;

10.2 give, promise to give, or offer, a payment, gift or hospitality to a Public Official or third party to ‘facilitate’ or expedite a routine procedure;

10.3 threaten or retaliate against anyone who has refused to commit a bribery offence or who has raised concerns under this policy;

10.4 engage in any activity that might lead to a breach of this policy or perceived breach of this policy.

11 Responsibilities:

11.1 Compliance with this policy and the prevention, detection and reporting of any form of Bribery & Corruption is the responsibility of all parties including employees, customers, partners, suppliers and other relevant parties. Concerns can be reported by sending an email to Legislations@netstock.co.

11.2 It is the employee’s responsibility to comply with the Company’s more detailed internal policy.

11.3 Any Employee who breaches the policy will face disciplinary action, which could result in dismissal for gross misconduct.

12 Protection:

12.1 Employees who refuse to take part in bribery or corruption, or report in good faith under this policy their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future, and will be protected from detrimental treatment/retaliation.

12.2 Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

13 Training:

13.1 Employees must be provided with training to assist them to comply with this Policy.

13.2 This training must be included in the onboarding process for new employees.

14 Risk

Failure to formally implement and comply with controls to prevent bribery and corruption may lead to criminal sanctions against companies and culpable employees and/or penalties for the same or similar misconduct.