Anti-corruption programme

The activities of GRIFS AG are intended to prevent the possibility of corruption at the company, promoting honesty, openness and responsibility among its employees, business partners, clients and suppliers.

The company has developed a combined approach towards anti-corruption measures that includes reinforcing the company values, coordinating the understanding the destructive consequences of corruption, and taking appropriate measures to prevent it. The company has developed and implemented an anti-corruption programme, which is made known to all company employees. Prevention of corruption comprises certain ethics-based principles at all levels of decision making, business transactions, company communication with its workers, business partners, media outlets, clients and other parties. The anti-corruption programme is based on two key principles:

  • The company prohibits all kinds of bribes, both direct and indirect!
  • The company has implemented a system of measures for combatting corruption!

The anti-corruption programme includes provisions that complement the Ethics Code, clearly defining the attitude and actions of company employees, management and owners in situations that can lead to corruption.

In order for the anti-corruption programme to comply with the needs of GRIFS AG and to solve the corresponding problems, the company carries out bribery risk assessments. The goal of such assessments is to determine the areas of company activity that are subject to the highest risk of corruption.

The anti-corruption principles are communicated to company employees through the binding internal documents. The anti-corruption programme stipulates that employees that engage in corruption activities are subject to disciplinary penalties in accordance with the company code of conduct and the law of the Republic of Latvia.

Conflict of interest

All decisions are taken at GRIFS AG in the interests of the company, based on the binding regulatory documents of GRIFS AG. The decision-making process at the company is not carried out by any single person. Actions to be taken by company employees to prevent conflicts of interest:

  • Company employees do not engage in any additional work or positions that would negatively affect their ability to fulfil their work duties professionally and responsibly, and that would create the suspicion of possible apparent or real conflicts of interest.
  • Company employees are required to inform the employer of any possible conflicts of interest, after which the management of GRIFS AG takes decisions on further actions.

Bribery

A bribe is a benefit or any item of material value that the briber gives to the recipient of the bribe with the purpose of the latter using their position to take or not take certain actions in the interests of the briber or other parties.

GRIFS AG forbids its employees from giving, offering, demanding or receiving any bribes, or from acting as intermediaries in such actions. This includes any remuneration or gifts for signing contracts or any other cooperation activities, services, provision of information etc.

Political donations

Political donations are defined as supporting certain political goals with free funding, products or services.

  • It is prohibited to use the funds of GRIFS AG to make any direct or indirect donations to political organisations, parties, politically engaged persons.
  • GRIFS AG employees are only allowed to support political organisations, parties and politically engaged persons as private individuals, and only if such support is not provided to obtain any sort of benefit or advantage for the company employing them.
  • GRIFS AG employees are not allowed to carry out any campaigning or promotion for political organisations, parties or politically engaged persons at the cost of the company, and to receive any material and non-material assets for performing such activities.

Charity and sponsorships

These are items of material value or funding that are contractually provided by the company to a public welfare organisation to achieve the goals specified in its charter, without financial gain.

  • GRIFS AG prohibits any charity and sponsorships that take place to cover up (or replace) bribes.
  • Any charity or sponsorships conducted by GRIFS AG must not create any obligations for the recipient of the corresponding donation, e.g. forcing the recipient to acquire products or services provided by the company.
  • GRIFS AG publishes information about all of its charity and sponsorship activities on its website.

Investments in the public

  • GRIFS AG makes sure that investments in the public are not made to cover up bribes.
  • Such investments should not impose any obligations to use the products and services of GRIFS AG on the public.

Gifts, hospitality, allowances

  • GRIFS AG prohibits offering or receiving any gifts, hospitality or allowances that could affect the results of business transactions.
  • In any cases, the receipts for such expenses (if any) must be lodged in the accounting documents, in accordance with the law.

Facilitation payments

Facilitation payments are a form of bribery, whereby amounts of money are paid to ensure faster completion of a recurrent or necessary procedure. Facilitation payments are a form of bribery, which is why GRIFS AG neither makes such payments, nor permits accepting them.

The support of the anti-corruption programme and the understanding of the necessity for it is achieved among company employees through lectures about anti-corruption measures during company-internal training. The anticorruption principles are also communicated to company employees through the binding internal documents.

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