Anti-bribery and corruption policy statement for CRMT

CRMT is committed to applying the highest standards of ethical conduct and integrity in its business activities in the EU and other countries. Every employee and individual acting on CRMT's behalf is responsible for maintaining our reputation and for conducting company business honestly and professionally.

We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate.

The purpose of this policy statement is to:

set out our responsibilities, and of those working or providing services for us, (which for the purpose of the Zakon o integriteti in preprečevanju korupcije (ZintPK) includes service providers of the CRMT), in observing and upholding our position on bribery and corruption;

provide information and guidance as to how we expect those working for us to conduct themselves and how to recognise and deal with bribery and corruption issues; and

how to raise concerns with us including any breaches of this policy statement

CRMT’s Management is committed to implementing and enforcing effective systems throughout CRMT.

What is bribery?

A bribe, broadly, is an inducement or reward offered, requested, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. This can be in the context of giving or receiving. An offence is committed when the bribe is coupled with an intention of inducing, a reward for or in anticipation for a person to improperly perform their function or if the request, agreement to accept or acceptance of the bribe itself constitutes or is believed to constitute the improper performance of an activity. In addition, offering a bribe to a foreign public official to induce that public official to obtain or retain business or an advantage in the conduct of business (and that is not permitted by local laws), will also be an offence.

Responsibilities

The prevention, detection and reporting of bribery and other forms of corruption is the responsibility of all those working for us, or supplying services to us, or under our control. All CRMT raise any concerns with us as set out in section 8.1.

Gifts and Hospitality


CRMT permits normal and appropriate corporate entertainment, gifts, hospitality and promotional expenditure (given and received) to or from third parties that is undertaken:
for the purpose of establishing and maintaining good business relationships
to improve the image and reputation of CRMT
to present CRMT's goods/services effectively

Provided that it is:
in good faith
not offered, promised or accepted to secure an advantage for the its employees or associated persons or to influence the impartiality of the recipient
The giving of gifts by CRMT employees with an approximate value of EUR50 or higher (or the local equivalent outside the EU) is prohibited unless they have been given prior approval by Management. With regard to our employees receiving gifts, unless approval has been provided by the Management, gifts that exceed a EUR50 threshold must be declined and will be recorded. Gifts in the form of cash must never be accepted by our employees or service providers and therefore must not be offered and any offers of cash must be immediately reported to the Management. The giving or receiving of promotional material is not considered a gift.
The giving and receiving of corporate entertainment and hospitality for our employees should not exceed an approximate value of EUR50 per head (or the local equivalent outside the EU) without prior approval by a CRMT Management where possible and reasonable to do so in the circumstances.
The test to be applied is whether in all the circumstances, the gift, entertainment or hospitality is reasonable and justifiable. We expect the intention behind the gift to always be considered.

What is not acceptable?


There are many scenarios where there will be a breach of the ZintPK, however below are some non exhaustive scenarios as to we think is not acceptable for employees or service providers of CRMT to do, namely:

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

give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure;

give, offer or promise to a foreign public official to induce that public official to obtain or retain business or an advantage in the conduct of business (and that is not permitted by local laws), request, agrees to receive or accept payment from a third party knowing or suspecting it is offered with the expectation that it will obtain a business advantage for them;

request, agrees to receive or accept payment from a third party knowing or suspecting it is offered with the expectation that it will obtain a business advantage for them;e) accept a gift or hospitality from a third party knowing or suspecting that it is offered or provided with an expectation that a business advantage will be provided by CRMT in

accept a gift or hospitality from a third party knowing or suspecting that it is offered or provided with an expectation that a business advantage will be provided by CRMT in return ;

threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; and

engage in any activity that might lead to a breach of this policy

Facilitation payments and kickbacks

We and our service providers should not make, and should not accept, facilitation payments or "kickbacks" of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. They are not commonly paid in the EU. Kickbacks are typically payments made in return for a business favour or advantage. We expect all employees and service providers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

If you are asked to make a payment on behalf of the CRMT, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment.

Any transactions in contracts and documentation must be recorded so that there is never any attempt to hide the way a contract will work.

Record Keeping

We and our service providers are expected to keep financial records and have appropriate internal controls in place which will evidence the business reason for giving and/or receiving payments from/to third parties.

Raising Concerns

If you believe this policy has been breached, or suspect it may have been breached, in any way please contact CRMT on management@crmt.com.

GDPR - Data Privacy

Personal Data Protection

At CRMT d.o.o. we assume the responsibility of handling personal data, therefore all databases of personal data are processed, maintained, stored and controlled in accordance with the Personal Data Protection Act (ZVOP-1, Official Gazette of the Republic of Slovenia, No. 94/2007). The subject, be it a company or an individual, whose personal data is processed, is guaranteed the following rights:

Right to request access to personal data from CRMT d.o.o. as a data controller, listed hereunder:

  1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
  • the purposes of the processing;
  • the categories of the personal data concerned, recipients or categories of recipients to whom personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of automated decision-making, including profiling
  1. Reasons for the processing and management of personal data, as well as significance and envisaged consequences.
  2. The controller shall provide a (free of charge) copy of the personal data undergoing processing in a format. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
  3. Right to rectification of inaccurate personal data concerning him or her.
  4. Right to restriction of processing where one of the following applies:
  • the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
  • the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
  • the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
  1. Right to erasure (‘right to be forgotten’) provided that conditions from Art. 17 of the General Data Protection Regulation are fulfilled and in particular where the data subject withdraws consent on which the processing is based.
  2. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.

 

  1. The data subject shall have the right to object, where personal data are processed for direct marketing purposes, including profiling.
  2. The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
  3. Every data subject shall have the right to lodge a complaint with the Information Commissioner if the data subject considers that the processing of personal data relating to him or her infringes the General Data Protection Regulation.

CONTACT US

CRMT d.o.o.

Ukmarjeva ulica 2, 1000 Ljubljana

T: +386 05 99 437 00

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