Ethical Business Practices Policy

Introduction:

The purpose of GreenGuzo’s Ethical Business Practices Policy is to ensure the compliance of all employees, including contractors, with the company’s legal and regulatory obligations regarding bribery, corruption, and fraud prevention. This policy aims to promote ethical behavior, effective resource management, and strong internal controls to prevent and detect instances of bribery, corruption, and fraud. This policy applies to GreenGuzo AS, and all subsidiaries, and extends to hired contractors, consultants, temporary agency workers, and other third parties acting on behalf of GreenGuzo.

Purpose:

The purpose of this policy is to ensure the compliance of GreenGuzo and its employees, including contractors, with legal and regulatory obligations pertaining to bribery, corruption, and fraud prevention. Furthermore, it emphasizes the promotion of ethical behavior, efficient resource management, and robust internal controls to prevent and uncover instances of bribery, corruption, and fraud.

Anti-Bribery, Corruption, and Anti-Fraud Policy:

GreenGuzo is firmly committed to supporting the global fight against financial crimes such as bribery, corruption, and anti-competitive behavior. We unequivocally prohibit all employees and associated individuals from engaging in any form of bribery, corruption, fraud, or misconduct. This policy is rooted in the applicable laws and regulations concerning these topics in each country where GreenGuzo operates.

Policy Statement:

To achieve our Anti-Bribery, Corruption, and Anti-Fraud Policy goals, GreenGuzo commits to the following:

  1. Zero Tolerance: We distance ourselves from all forms of bribery, corruption, fraud, and misconduct.
  1. Prevention and Detection: We implement a robust, adequate, and risk-based anti-corruption program to prevent and detect instances of bribery, corruption, fraud, and misconduct.
  1. Leadership Role: GreenGuzo’s senior management acts as role models, promoting our values in their leadership and upholding ethical business practices.
  1. Compliance and Regulations: All employees are required to comply with GreenGuzo’s policies, code of conduct, and applicable regulations, including those related to anti-bribery, fraud, and competition law.
  1. Reporting Culture: We encourage an open culture where employees are empowered to report concerns and criticisms as part of our continuous improvement efforts.
  1. Stakeholder Engagement: We maintain an open, constructive, and proactive dialogue with stakeholders regarding our stance and work on anti-bribery, corruption, anti-fraud, and misconduct issues.
  2. Risk Assessment: We continuously identify, assess, reduce, and evaluate corruption and misconduct risks through comprehensive risk assessments.

Requirements:

GreenGuzo has established the following requirements to enforce our Anti-Bribery, Corruption, and Anti-Fraud Policy:

  1. Prohibition: We do not tolerate any form of bribery, corruption, or anti-competitive behavior by employees or associated individuals acting on behalf of GreenGuzo.
  1. Senior Management Responsibility: Senior management is responsible for ensuring compliance with GreenGuzo’s policies and procedures. They must allocate adequate resources to support the implementation of this policy.
  1. Employee Compliance: All GreenGuzo employees must comply with the relevant aspects of this policy and promptly report any suspected or confirmed instances of bribery, corruption, or fraud that they become aware of in their day-to-day work.
  1. Risk Minimization: We strive to minimize the risk of bribery or corruption occurring on behalf of GreenGuzo.
  1. Prohibition of Facilitation Payments: The use of facilitation payments, which are payments made to induce or expedite an action, is strictly prohibited.
  1. Accounting Integrity: Improper accounting practices or concealment of financial activity to disguise bribery or corruption-related activities is strictly prohibited.
  1. Contractual Clauses: Suitable contractual clauses are inserted to ensure that GreenGuzo’s relationships with stakeholders do not expose the company to unacceptable levels of bribery and corruption risk.
  1. Employment Practices: Transparent and documented processes are in place for employment and internships, ensuring they are not used to gain a business advantage or influence public officials in violation of anti-bribery or corruption laws.
  1. Periodic Inspections: Regular inspections are conducted to ensure compliance with this policy, and any allegations of bribery, corruption, or fraud are thoroughly investigated, with appropriate assistance provided to official authorities when necessary.

Responsibility:

The Board of Directors is responsible for maintaining GreenGuzo’s corporate governance framework, including policies related to anti-corruption and misconduct.

The Chief Executive Officer, as the risk owner, is responsible for annually assessing the risk of corruption and misconduct within their unit/process and ensuring leaders actively work to prevent corruption and misconduct.

The Compliance Officer is responsible for publicizing the corporate governance framework and associated documents, ensuring their publication on relevant forums, and conducting annual assessments of this policy and related risks.

Employees are responsible for complying with the policies, procedures, and standards outlined in this policy, acting in accordance with legal requirements and GreenGuzo’s principles of anti-corruption and misconduct. They must attend relevant training and report any suspected or confirmed instances of bribery, fraud, or corruption they become aware of in their daily work.

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