Anti-Bribery Policy
Last updated: October 2023
Last updated: October 2023
Perpetio OÜ (hereinafter "the Company", "we" or "our") is committed to responsible corporate behaviour and compliance with all laws, regulations and other requirements that govern our business. Our unwavering commitment is to foster a strong anti-corruption culture and to ensure strict compliance with local anti-bribery and anti-corruption laws and regulations. We are committed to prohibiting any form of giving, offering, seeking or receiving bribes, corrupt payments, inducements or similar conduct by ourselves or anyone acting on our behalf. Our senior management will consistently implement effective measures to prevent, control and eliminate bribery. It is important to note that this Anti-Bribery Policy (hereinafter - "the Policy") is not considered to be part of the employment contract, and we reserve the right to amend or cancel it at any time.
Bribery is described as the act of giving or promising to give a financial or other benefit to another party with the intention of persuading them to perform improperly or as a reward for improper behaviour. Bribery is also considered to be when a party requests or agrees to receive a financial or other benefit from another party with the intent to induce improper behaviour or to engage in improper behaviour in expectation of the benefit. In the context of bribery of a foreign official, this involves the offer or pledge of a financial or other benefit to influence a foreign official to secure business or gain an advantage in business transactions, where such influence is not required or permitted by law. Our Company has a categorically negative attitude to any of the above actions and will report them to the relevant government agency if they are detected.
The team and/or their related parties are prohibited from offering, promising, giving, requesting or receiving any bribe in the form of: cash, gift, as an incentive or additional remuneration, or otherwise inducing any action in favor of any person, regardless of geography and regardless of whom. We reserve the right to test our team and/or customers and/or vendors for bribery to ensure that they are improperly fulfilling the obligations of this Policy (if these parties take advantage of the offer, we will immediately terminate our cooperation with them).
Under applicable laws and international guidelines, a party found guilty of bribery may face fines and/or imprisonment. Based on this, we will apply the following sanctions internally for violations of the basic terms of this Policy: disciplinary action, which may include dismissal; notification of the relevant government agency and transfer of the offending party's data to such agencies. For us, any breach of this Policy by any team member could result in: us possibly being deemed to have violated the law; fines being imposed on us by a governmental authority; and us losing our reputation in the global marketplace (that is categorically negative for us).
This Policy applies to all team members, contractors, subcontractors, consultants, business partners and any other parties (including individuals, partnerships and corporate organizations) associated with us or any of its subsidiaries. Therefore, the parties are prohibited from: (1) provide or promise any financial or other benefit to another party (or use a third party to do the same) on behalf of the Company if such benefit is intended to induce the other party to perform a function improperly, to reward the other party for doing the same, or if acceptance of such benefit would itself be considered improper conduct (2) demand or agree to receive any financial or other benefit from the other party if such benefit is intended to induce improper performance of a certain function, where acceptance of such benefit would itself be considered improper behavior, or where the recipient intends to act improperly in anticipation of such benefit. In addition, parties must: (1) be aware of and remain alert to all bribery risks at all times; (2) exercise due diligence at all times when dealing with third parties on behalf of the Company; and (3) report any bribery-related concerns to the Company's CEO or, in the case of non-employees, their usual contact at the Company.
The Company pays special attention to team members and related persons who maintain all records relating to any contracts or business activities, including financial accounts and all payment transactions with customers, suppliers and partners, as such team members and related persons must conduct due diligence before entering into any contractual arrangements or relationship with a potential service provider, agent, consultant, or customer representative. In addition, we keep records of all financial transactions of our company and make sure that each transaction is properly recorded.
A facilitation payment is defined as a small payment given to an official to secure or expedite the performance of a normal or necessary function, and is a bribe. Gifts and hospitality may, if excessive, constitute a bribe and/or a conflict of interest. Charitable donations are allowed only to registered (non-profit) charitable organizations, i.e. no charitable donations may be made to any organization that is not a registered charitable organization (under no circumstances may charitable donations be made in cash). The Company does not make political donations and is not affiliated with any political party, independent candidate or any other organization whose activities are primarily political (the team and other related parties are free to make personal donations, provided that such payments are not made on behalf of the Company and are not made to obtain any form of advantage in any business transaction). Any of the above should be reported to the Company's CEO as soon as possible.
In any transactions, agreements with officials and other business matters involving third parties, we should carefully consider the following issues: (1) territorial risks, in particular the prevalence of bribery and corruption in a particular country; (2) cross-border payment risks; (3) requests for cash, intermediary payments or other unusual payment methods; (4) activities requiring the Company and/or any related party to obtain permits or other forms of official authorization; (5) import or export transactions.
We depend on our team and those associated with them to ensure that the highest standards of ethical behavior are maintained in all of its business dealings, so we ask them to assist us and remain vigilant in preventing, detecting and reporting bribery. Our team and those associated with them are encouraged to report any concerns they may have to the Company's CEO as soon as possible. Report any: suspected or actual bribery attempts; concerns that other team members or associates may be bribed; or concerns that other team members or associates may be bribing third parties. Any reports of bribery or suspected bribery will be investigated thoroughly and promptly by us, with the involvement of our team with knowledge of the matter. Our team or those associated with them who report bribery in good faith will receive our support as a result of their report. Any mistreatment by a colleague because a team member has made a report will be treated as disciplinary action. An instruction with the intent to conceal wrongdoing is itself a disciplinary offense. Even if a person in a position of authority, such as a supervisor, tells you not to raise or report any concerns, the team member and those associated with them should not agree to remain silent. They should report it to the Company's CEO.
In the event that a team member or a person associated with a team member reports suspected bribery, we will treat any personal data collected in accordance with our Privacy Policy. The data collected from the moment a team member or a related person submits a report will be kept in a secure state and accessed and disclosed only for the purpose of processing the bribery report.
We will fully investigate any incidents of alleged or suspected bribery that come to our attention or are reported. Team members who are suspected of bribery may be suspended from their duties while the investigation is conducted, subject to disciplinary procedures, and proven allegations may result in a finding of gross misconduct and immediate dismissal. We may at any time terminate the cooperation agreement with anyone who breaches the terms of this Policy, notifying the relevant governmental authority of the breach and providing them with all the details.
This Policy has been approved by the CEO of Perpetio OÜ, if you would like to receive further information regarding this Policy, please contact the CEO of Perpetio OÜ.
Perpetio OÜ (hereinafter "the Company", "we" or "our") is committed to ethical corporate behaviour and to comply with all applicable laws, regulations and other provisions governing our business. Our unwavering commitment is to foster a strong anti-corruption culture and to ensure strict compliance with local anti-bribery and anti-corruption laws and regulations. We are committed to prohibiting any form of giving, offering, seeking or receiving bribes, corrupt payments, inducements or similar conduct by ourselves or anyone acting on our behalf. Our senior management will consistently implement effective measures to prevent, control and eliminate bribery. It is important to note that this Corporate Social Responsibility Policy (hereinafter - "the Policy") is not considered to be part of the employment contract, and we reserve the right to amend or cancel it at any time.
We are a one-stop partner for full-cycle mobile application development. We are always ready for the next challenge: iOS Development Services, Android App Development Services, Flutter App Development Services, React Native Development, Web Development, UI/UX Design and other customised service packages (collectively, the "Services"). Our purpose is to improve performance by delivering unrivalled value, insight, and success to our customers.
We are committed to ensuring the well-being and sustainable development of our team, where each member clearly understands their role and contribution to the business. We ensure that each member of the team has the opportunity to develop according to their interests and talents through a clearly defined personal growth plan that includes appropriate training and systematic assessment points where tangible progress goals are met. We expect our team to treat each other fairly and to meet the highest standards of business ethics and excellence. We support diversity, equity, and equal opportunities for everyone, supporting them in their new learning endeavours.
We intend to develop long-lasting and meaningful relationships with our customers and stakeholders, ensuring that we fully understand their objectives, meet all requirements and exceed their expectations for our Services. Our goal is always to provide fair value, consistent quality and reliability. We are fully committed to the highest professional and ethical standards, and are committed to being honest, open, and transparent in all our interactions with customers.
We strive to create and maintain strong relationships with key suppliers and contractors who share our ethics in terms of employment, quality and environmental controls. We have rigorous vetting processes in place to ensure that we work with companies and/or individuals who are committed to maintaining best practice and the performance of our Services.
We recognise our environmental impact as an integrated, progressive business and continue to take appropriate measures to mitigate this impact, both by us and by our teams and customers, such as an environmental policy, which is reviewed annually and updated as necessary, and through which we set environmental goals and targets, use procedures and provide training to ensure that our teams and contractors understand their environmental responsibilities and can strive to improve our environmental performance, and ensure that we are committed to the environment. In addition, we are committed to providing a safe and healthy working environment for all our activities and to promoting a health and safety culture that focuses on maintaining the highest standards while complying with health and safety requirements. We make sure our team is happy and healthy at work, so they can enjoy time with their loved ones. This commitment extends to our relationships with customers and vendors.
We recognise and understand the importance of the local communities in which we operate, which is why we strive to increase our contribution to society by being aware of the needs of local people and groups. We are committed to the following actions: making monetary and time donations to local volunteer charities, and supporting the surrounding community by employing local people and providing opportunities for young people from our local communities through training and work experience.
This Policy has been approved by the CEO of Perpetio OÜ, if you would like to receive further information regarding this Policy, please contact the CEO of Perpetio OÜ.