Anti-Bribery and Corruption Policy – Arctic Inbound

1. Introduction

This Anti-Bribery and Corruption Policy outlines the commitment of Arctic Inbound AB to maintain the highest level of integrity and ethical standards in all business practices. We are dedicated to combating bribery and corruption in any form and ensuring compliance with all applicable laws and regulations.

2. Purpose

The purpose of this policy is to:

  • Define what constitutes bribery and corruption.
  • Set out the responsibilities of employees, management, and third parties.
  • Provide guidelines to prevent, detect, and report bribery and corruption.
  • Ensure compliance with relevant anti-bribery and anti-corruption laws.

3. Scope

This policy applies to all employees, directors, agents, consultants, contractors, and any other third-party representatives of Arctic Inbound.

4. Definition of Bribery and Corruption

Bribery is the offering, giving, receiving, or soliciting of any item of value to influence the actions of an official or other person in charge of a public or legal duty.

Corruption is the abuse of entrusted power for private gain. This can include bribery, extortion, fraud, nepotism, cronyism, patronage, embezzlement, and money laundering.

5. Policy Statements

5.1. Prohibition of Bribery and Corruption

  • Arctic Inbound AB strictly prohibits bribery and corruption in any form, whether direct or indirect.
  • Employees and representatives must not offer, promise, give, request, or accept any bribes.

5.2. Compliance with Laws

  • All business activities must be conducted in compliance with all applicable anti-bribery and anti-corruption laws; however, there are currently no specific rules under Swedish law forbidding private commercial bribery, irrespective of whether it concerns domestic or foreign entities or circumstances.

5.3. Gifts and Hospitality

  • Employees and representatives must not offer or accept gifts or hospitality that could influence or be perceived to influence a business decision.
  • All gifts and hospitality must be reasonable, proportionate, and for legitimate business purposes.

5.4. Charitable Donations and Sponsorships

  • Charitable donations and sponsorships must not be used as a subterfuge for bribery.
  • All such activities must be transparent and properly recorded.

5.5. Political Contributions

  • Arctic Inbound does not make political contributions.
  • Employees must not use company funds or resources to make contributions to political parties or candidates.

6. Responsibilities

6.1. Management

  • Ensure the implementation and enforcement of this policy.
  • Provide training and resources to employees on anti-bribery and anti-corruption practices.
  • Monitor compliance and take appropriate action in case of violations.

6.2. Employees

  • Comply with this policy and all relevant laws and regulations.
  • Report any suspected or actual instances of bribery or corruption.
  • Participate in training and awareness programs.
  • 6.3. Third Parties

    • Must comply with this policy when acting on behalf of Arctic Inbound.
    • Ensure that all agreements with third parties include clauses that adhere to anti-bribery and anti-corruption standards.

    7. Reporting and Investigation

    • Employees and third parties must report any suspected or actual instances of bribery or corruption to the Compliance Officer or through the company’s whistleblowing mechanism.
    • All reports will be investigated promptly, thoroughly, and confidentially.
    • No retaliation will be tolerated against anyone who reports in good faith.

    8. Training and Awareness

    • Anti-bribery and anti-corruption policies are set out in a new staff handbook and are shared before starting any new role.
    • The policy will be communicated to all third parties acting on behalf of the company

    9. Record Keeping

    • Accurate and detailed records of all business transactions and expenses must be maintained.
    • All records must be kept in accordance with applicable laws and company policies.

    10. Enforcement

    • Violations of this policy may result in disciplinary action, up to and including termination of employment or contracts.
    • Legal action may be taken against individuals or entities involved in bribery or corruption.

    11. Review and Monitoring

    • This policy will be reviewed annually and updated as necessary to ensure its effectiveness.
    • Regular audits will be conducted to monitor compliance with this policy.

    12. Contact Information

    For any questions or concerns regarding this policy, please contact the Compliance Officer at [email protected]

    By adhering to this Anti-Bribery and Corruption Policy, Arctic Inbound AB commits to conducting all business activities with integrity, transparency, and accountability.