Introduction and purpose

The purpose of this anti-bribery and corruption policy (“Policy”) is to ensure compliance by BHM group a.s. and its affiliates (“BHM group”) with all applicable anti-corruption laws. BHM group has zero tolerance for bribery and corruption in all forms and is committed to conducting business ethically and with integrity.

Definitions used in this policy

Bribe means promising, offering, giving, authorizing, or rewarding money, gifts, gift cards, hospitality, expenses, reciprocal favors, political or charitable contributions, any financial or other advantage, or anything else of value to gain undue business or  another advantage, which is considered dishonest, unethical, or illegal.

The promising, offering, giving, authorizing, or acceptance of bribes in any form, either directly or indirectly, is prohibited.

Corruption means the misuse of power or position for private or other personal gain.
Corruption undermines public trust, poses a significant threat to both economic and social progress, and undermines ethical business practices.

Corruption can take many forms, such as giving or taking bribes, conflicts of interest, or favoritism, all of which are strictly forbidden.

Facilitation payments are payments of small monetary value provided (in cash or in kind) to government officials, political party members, or other official parties with the expectation of facilitating or expediting routine government services, such as permit applications, the issuance of licenses, or other official documents.

Kickbacks are payments (cash or in kind) in return for facilitating or providing favorable treatment in commercial transactions.

Scope of this policy

BHM group and all its directors, employees, and third parties acting on behalf of BHM group are responsible for complying with this Policy and anti-corruption and anti-bribery laws.

BHM group expects that its business partners are committed to anti-corruption and anti-bribery compliance and maintain the highest level of anti-corruption and bribery practices.
This Policy applies equally to the private as well as the public sector.

Gifts, hospitality, and entertainment

Non-Government Officials

Gifts, hospitality, or entertainment must not be offered or received in a way that may improperly influence or be perceived to improperly influence business decisions or business relationships.

However, it is recognized that corporate hospitality, such as meals, entertainment, and appropriate business gifts, may be permissible when offered in the normal course of business practices, remain infrequent, modest, and of small value, and do not violate this Policy.

The acceptance or provision of cash or cash equivalents, including gift cards, is strictly forbidden, irrespective of their value.

Government Officials

There is a heightened risk that the provision or acceptance of gifts, hospitality, and entertainment in relation to a government official could be interpreted as bribery, improper influence, or conflict of interest. Therefore, all interactions with government officials must be carried out in a manner that complies with all relevant laws, rules, and regulations.

Gifts, hospitality, or entertainment offered to government officials, irrespective of their value, must not be provided or received with the intention of influencing or gaining improper advantages in business transactions. For the sake of clarity, the offering or acceptance of cash or cash equivalents, such as gift cards or other forms of monetary benefits to or from government officials, is strictly prohibited.

All gifts, hospitality, and entertainment offered to government officials must be carefully considered, reasonable, and of low value, transparent, properly recorded, and documented, and in line with this Policy and all relevant laws, rules, and regulations.

Political contributions and charitable donations

BHM group does not make donations or contributions to any political party, political party member, representatives, or candidates.

Charitable donations are always gratuitous and provided without expecting anything in return, and completely independent of any business relationships.

The utilization of donations, sponsorships, or similar with the intention of circumventing anti-corruption and anti-bribery provisions set out in this Policy is strictly forbidden.

Kickbacks and facilitation payments

The offering, authorization, and acceptance of kickbacks directly or indirectly to and from business partners in any transaction between BHM group and any of its business partners is strictly prohibited.

Facilitation payments in all forms are strictly prohibited.

Third parties

BHM group will pay particular attention to anti-corruption compliance when using third parties in business transactions.

All payments to third parties, including commissions, compensation, and reimbursements, must be customary and reasonable in relation to the services provided and accurately documented in BHM group’s accounts. These payments must not be made in cash.

BHM group will check third parties properly and carefully and take all precautions to prevent corruption.

All agreements with third parties must be made in written form and recorded together with the results of possible due diligence findings of such third parties.

Reporting and consequences of violations

As BHM group has zero tolerance policy towards corruption or bribery of any kind and wishes to uphold ethical business practices, it encourages its employees to disclose their concerns as to potential violations of this Policy.

BHM group investigates all reported cases of bribery and corruption and will make an investigation plan for each case. All information received related to the investigation will be treated with confidence. Any individual who, in good faith, reports potential violations, provides information or assists in inquiries or investigations of potential violations with respect to this Policy will be protected against any form of retaliation.

Non-compliance with this Policy may lead to disciplinary actions. A breach of this Policy by BHM group’s business partner will result in the termination of such business relationship unless the non-compliance is corrected immediately. Depending on the severity of the violation, a breach of this Policy by BHM group’s directors or employees may lead to reprimand, warning, or termination of employment.

Conflict of interest

BHM group endeavors to avoid all types of conflicts of interest between work and personal interests.