1. Goal

The aim of our Anti-Bribery and Anti-Corruption Policy is to set out the anti-bribery and anti-corruption policies of EAE Lighting, which are included in the Code of Business Conduct.

2. Scope

Anti-Bribery and Anti-Corruption Policy applies to:

• EAE Lighting Board of Directors and all EAE Lighting employees,
• The companies that supply us with goods and services and their employees, suppliers, consultants, lawyers, external auditors and all people and organisations (business partners) working on behalf of EAE Lighting.

This Policy is an integral part of

• the corporate management principles approved and practised by EAE Lighting, the Code of Business Conduct,  
• the principles we pledged to uphold by joining the UN Global Compact,
• and our Human Resources

Practices.

3. Definitions

Corruption: The direct or indirect abuse of authority possessed due to one’s position for the purpose of gaining any kind of profit.

Bribery: Providing, offering or promising benefits directly  or through intermediaries in order to do, have done, not do, expedite, or slow down a job related to the performance of a person’s duty: to solicit or receive such; to provide benefits to oneself or the party requesting it, or to someone else due to this relationship under the agreement reached with another person to act contrary to the requirements of one’s duty by means such as mediating for them.

Bribery and corruption can take many forms, including;

• Cash payments,
• Political or other donations,
• Commissions,
• Social benefits,
• Gifts, hospitality,
• Other benefits,

To name but a few.

Conflict of Interest: This refers to all kinds of benefits provided to themselves, their relatives, friends or the persons or organisations they are in contact with and have any material or personal interest in, which may or may not affect the impartial performance of their duties.

Stakeholders: These are the governance components that interact economically, socially and environmentally throughout the value chain.

4. Duties and Responsibilities

The Board of Directors has the authority to implement and update the Anti-Bribery and Anti-Corruption Policy, and it is their duty and responsibility to do this. As such, it is responsible for:

• Advising company executives to establish an ethical, reliable, lawful and monitored working environment,
• Determining risks, making assessments and establishing the necessary control mechanisms in line with the principles set by the Board,
• Monitoring whether the activities of EAE Lighting Are carried out safely and in compliance with legal regulations within the purview of the Board of Directors, Company Executives, and Ethics Committee,
• Determining and implementing notification, review and enforcement mechanisms in case of non-compliance with policies, rules and regulations.

Furthermore, all EAE Lighting employees are responsible for

• Complying with the policies set out by the Board of Directors,
• Effectively managing the risks associated with their own areas of activity,
• Working in accord with the relevant regulations and EAE Lighting practices,
• Complying with general company policy and reporting any conduct, activity or practice they encounter in violation of this policy to the

Ethics Committee.

5. Companies and Business Partners that Buy and Sell Goods and Services

The companies and business partners that buy and sell goods and services must comply with the Policy principles and other applicable regulations, and those that do not shall have their contracts terminated.

 

 

5.1 Selection of Companies and Business Partners

When selecting the companies and business partners for buying and selling goods and services, we consider such criteria as experience, financial performance, technical competence, as well as their level of conduct and having a positive history in this area. We do not work with companies or business partners that fail vetting for bribery or corruption, even if they meet the other criteria. As such, the onus is on the company executives to do the necessary research before entering into any business relationship. The Board of Directors shall determine in their audits whether these points are being complied with. 

 

5.2 Making Agreements with Companies and Business Partners

The contracts and agreements to be made with companies and business partners that vet positively and meet the other criteria shall include the following:

• Full compliance with the principles set out in the Policy and other applicable regulations,
• Their employees must adopt these principles and comply with them,
• Their employees must be given regular training in the Policy,
• Regularly reminding employees about their reporting obligations and the Ethics Committee and encouraging them to report any

misconduct they encounter. They shall include provisions to terminate the work and contracts in force in the event of any non-compliance or contravention of the Policy.

6. Policy and Procedures

6.1 Bribery and Corruption

EAE Lighting Is opposed to all kinds of bribery and corruption. Regardless of its purpose, it is totally unacceptable to take or give a bribe.

A business relationship with 3rd parties that want to do business with EAE Lighting through bribery and corruption should be discontinued.

 

6.2 Gifts

A gift is a product that does not require financial payment and is usually given as a thank you or commercial courtesy by people of customers with whom there is a business relationship.

Any gift offered or given by EAE Lighting to 3rd parties must be offered publicly, in good faith and unconditionally. Gifts that cannot be given in this context and the principles regarding their registration are covered in the article on Accepting and giving Gifts in the EAE Lighting Code of Business Conduct.

The same principles apply to accepting gifts, and gifts should not be accepted except as symbolic gifts that do not have a high financial value, as stated in these principles. Furthermore, even if it does fall within this context, gifts should not be accepted frequently, and the recipient should notify the HR and the Board of Directors through his/her line manager about the gifts received.

 

6.3 Facilitation Payments

Facilitation payments are not offered to the people and organisations covered by this Policy to secure or expedite a routine transaction or process (obtaining permits and market authorisation, certificates, etc.) with government agencies.

 

6.4 Donations

EAE Lighting does not support charitable organisations with the amounts collected by its employees outside of their work; such a practice falls outside of the company’s Donation and Relief practices. However, the principles in the EAE Lighting Code of Business Conduct, apply here.  

7. Error-Free Record Keeping

The points related to the accounting and bookkeeping system that EAE Lighting has to comply with are regulated by law. Accordingly, 

• All kinds of accounts, invoices and documents pertaining to relations with 3rd parties (customers, suppliers, etc.) must be filed and maintained in full, accurately, and reliably.
• No accounting or similar commercial records relating to any transaction may be falsified and no fact may be distorted.

8. Training and Communication

The Anti-Bribery and Anti-Corruption Policy is announced to all EAE Lighting employees and can always be accessed easily on the QDMS.

Training is a key tool for increasing employee awareness. As such, the HR Department designs training programmes that all employees must attend.

9. Reporting Policy Violations

If it is thought or suspected that an employee or person acting on behalf of EAE Lighting acted in violation of this Policy, this should be communicated to the Ethics Committee at [email protected].  

EAE Lighting encourages an honest and transparent approach, supports any employee or person acting on behalf of the company who expresses genuine concern and keeps their reports confidential. No employee can be pressured or punished for reporting what they believe to be a Code of Conduct violation to the Ethics Committee, and no change can be made to the scope of that person’s duties or their location without the written approval of the Ethics Committee. 

If the reporting person is subjected to such treatment, they must report this to the Ethics Committee. 

The companies or business partners from which goods and services are purchased are required to remind their employees regularly about how to contact the Ethics Committee and encourage them to report any misconduct they encounter. This matter is guaranteed by the contracts made.

EAE Lighting employees are periodically reminded about the issues related to the Code of Business Conduct.

10. Policy Violations

In cases that are or likely to violate the Policy, the matter shall be examined by the Ethics Committee and the necessary sanction shall be applied in case of misconduct.

The contracts made with the companies for buying and selling goods and services or with people and organisations working on behalf of EAE Lighting include provisions for the company to justly and unilaterally terminate the work/contract if attitudes, behaviours or activities in violation of the Policy are detected, and these provisions shall be applied without exception in cases of policy violation.