Anti-corruption policy

The purpose of this policy is to set standards of conduct and minimise the risk of bribery. HASPO and its employees are committed to practising responsible conduct and direction in accordance with the law, regulations and other requirements. We are fully committed to a strong anti-corruption culture and policy that complies with all anti-corruption laws of the Slovak Republic and the laws of other countries, and to ensuring that no bribes or corrupt payments, inducements and the like are made, offered, sought or obtained by anyone who works for us or on our behalf.

The Slovak Criminal Code No. 300/2005 Coll. distinguishes the following forms of corruption:

1. Accepting a bribe (Section 328) If a person, directly or through an intermediary, for themselves or for another person, accepts, solicits or is promised a bribe in order to act or refrain from acting in breach of the duties arising from their employment, profession, position or function, they shall be punished by imprisonment of two to five years.

2. Bribery (Section 332) If a person, directly or through an intermediary, promises, offers or gives a bribe to another so that they act or refrain from acting in breach of the duties arising from their employment, profession, position or function, or for this reason, directly or through an intermediary, promises, offers or gives a bribe to another person, they shall be punished by imprisonment of up to three years.

3. Indirect corruption (Section 336) consists in accepting a bribe by a person who is to use their influence on another so that the latter grants the bribing person certain advantages consisting in a breach of their duties arising from their employment, profession, function or position, or in bribing such a person who exerts influence on another.

HOSPITALITY, CHARITY AND GIFTS

Gifts and hospitality are a legitimate part of corporate culture and should be given in accordance with this policy. If gifts are disproportionate, they may be considered a bribe or a conflict of interest. A review should always be carried out when receiving or giving any form of gifts and hospitality on behalf of HASPO. All charitable donations are recorded in writing.

POLITICAL INDEPENDENCE

HASPO does not provide any contributions to political parties or politically oriented associations.

RESPONSIBILITY AND SCOPE

This anti-corruption policy applies to all employees, independent representatives, contractual partners, consultants, business partners and all other parties that cooperate with our company. It is the responsibility of all the parties mentioned above to ensure the prevention and detection of bribery, and all reports submitted must comply with this policy.

HASPO

Košice, 4 July 2011