Nodefusion maintains a zero-tolerance approach to bribery, corruption, fraud, and any form of unethical conduct. This Policy states the principles that support that commitment, in line with our ISO 37001:2016 Anti-Bribery Management System. Top management is committed to implementing and continually improving this Policy and has approved the resources necessary for its effective operation.

This Policy applies to Nodefusion and all its employees, officers, and members of the Management Board and Executives, and extends to contractors, consultants, agents, distributors, and other third parties acting on Nodefusion’s behalf (“associated persons”).

Nodefusion is committed to the following principles:

• We do not offer, promise, give, request, or accept bribes or kickbacks, in any form, to or from any person, including public officials.
• We do not make facilitation payments, in any jurisdiction, regardless of local custom.
• We only give or receive gifts, hospitality, and entertainment that are reasonable, proportionate, and transparent, and never intended to improperly influence a decision, as set out in our Gifts and Hospitality Procedure.
• We apply risk-based due diligence to associated persons before they act on our behalf, as set out in our Third-Party Due Diligence Procedure.
• We maintain accurate books and records reflecting all payments and transactions; no undisclosed or off-the-books accounts are permitted.
• We assess and manage our exposure to bribery risk on an ongoing basis.
• We encourage the reporting, in good faith, of suspected bribery or corruption, through the channels set out in our Whistleblowing Procedure, and protect reporters from retaliation.
• We provide anti-bribery training appropriate to role and risk exposure.

Management Board approves this Policy, demonstrates visible commitment, and ensures adequate resources for its implementation, promotes awareness of this Policy and acts as a first point of contact for questions.

All employees and business partners are responsible for understanding and complying with this Policy.

Violations of this Policy may result in disciplinary action, up to and including termination of employment or of a business relationship, applied in accordance with Nodefusion’s disciplinary and HR procedures.

This Policy is reviewed at least annually, or sooner following significant organizational, legal, or regulatory change, and is approved by the Management Board.