SOFTWARE HOUSE "9111"Anti-Bribery, Anti-Corruption & Software Development POLICY

Краткое содержание:

1. Introduction

2. What does your policy cover?

3. Policy statement

4. Who is covered by the policy?

5. Definition of bribery

6. What is and what is NOT acceptable

6.2 Gifts and hospitality

6.6 Facilitation Payments and Kickbacks

6.10 Political Contributions

6.11 Charitable Contributions

7. Employee Responsibilities

8. Software development

9. INTERNATIONAL BUSINESS

10. What happens if I need to raise a concern?

10.2 How to raise a concern

10.4 What to do if you are a victim of bribery or corruption

10.5 Protection

11. Training and communication

12. Record keeping

13. Monitoring and reviewing

1. Introduction

1.1 Whereas, SOFTWARE HOUSE «9111.ru» will base all relationships with its partners and customers exclusively on the principles of mutual respect and trust observing the generally accepted business ethics norms, will adhere to the high international standards and business behavior codes.

1.2 Whereas, SOFTWARE HOUSE «9111.ru» and its affiliated companies constitute a group of Russian entities providing integrated solutions and software and hardware technologies.

1.3 Whereas, the SOFTWARE HOUSE «9111.ru» offers technologically advanced solutions for administrations, governmental, municipal and local authorities and administrations, environmental services and institutions, as well as OEM and VAR partners, private customers and end-users (hereinafter referred to as “the Products”), on a worldwide basis.

1.4 Whereas, SOFTWARE HOUSE «9111.ru», has, as the result of the expenditure of time, skill, effort and money, directly or indirectly, developed valuable intangible assets in the form of information technology consisting of hardware, software and associated ancillary services (the “Technology”). The value of the Technology is created through high quality research, design, development, programming, testing and quality control activities, i.e. activities necessary for creating the marketable Products.

1.5 Whereas, SOFTWARE HOUSE «9111.ru» will contribute in every possible way to the enhancement customer’s and partner’s favorable business reputation.

1.6 Whereas, SOFTWARE HOUSE «9111.ru» will take all the possible efforts for resolving any disputes arising in the processes of carrying out the business without applying to the arbitration system.

1.7 Whereas, SOFTWARE HOUSE «9111.ru» with due regard to the mandatory transnational, international and national law requirements, market opportunities and individual marketing strategy, will provide the most beneficial cooperation conditions for the partners and customers.

1.8 Words and expressions which are defined in the Policy (to the extent applicable) shall have the meanings attributed to them therein when used in this Policy unless otherwise defined or the context otherwise requires.

1.9 The clause and paragraph headings and the table of contents used in this Policy are inserted for ease of reference only and shall not affect construction.

1.10 Except where the context specifically requires otherwise, words importing one gender shall be treated as importing any gender, words importing individuals shall be treated as importing corporations and vice versa, words importing the singular shall be treated as importing the plural and vice versa, and words importing the whole shall be treated as including a reference to any part thereof.

1.11 References to statutory provisions, enactments or USA, EU, Russian laws shall include references to any amendment, modification, extension, consolidation, replacement or re-enactment of any such provision, enactment or USA, EU, Russian laws (whether before or after the date of this Policy), to any previous enactment which has been replaced or amended and to any regulation, instrument or order or other subordinate legislation made under such provision, enactment or USA, EU, Russian laws unless any such change imposes any liabilities or obligations which are more onerous than as at the date of this Policy.

1.12 If any provision of this Policy is held to be invalid or unenforceable by any judicial or other competent authority, all other provisions of this Policy will remain in full force and effect and will not in any way be impaired.

1.13 If any provision of this Policy is held to be invalid or unenforceable but would be valid or enforceable if some part of the provision were deleted, the provision in question will apply with the minimum modifications necessary to make it valid and enforceable.

1.14 This Policy may be executed in any number of counterparts, each of which shall constitute an original, and all the counterparts shall together constitute one and the same Policy.

2. What does your policy cover?

2.1 This anti-bribery and software development policy exists to set out the responsibilities of SOFTWARE HOUSE «9111.ru» and those who work for us in regards to observing and upholding our zero tolerance position on bribery and corruption and faire, agile approach to software development.

2.2 It also exists to act as a source of information and guidance for those working for SOFTWARE HOUSE «9111.ru». It helps them recognize and deal with bribery and corruption issues, as well as understand their responsibilities.

3. Policy statement

3.1 SOFTWARE HOUSE «9111.ru» is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. SOFTWARE HOUSE «9111.ru» has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.