1. Purpose & Scope

This Policy establishes clear rules to prevent corruption and ensure strict compliance with global anti-bribery regulations. This includes European Union anti-corruption directives, national EU member state laws, the U.S. Foreign Corrupt Practices Act (FCPA), and all local anti-bribery laws in any country where the Company conducts business.

• Applicability: This policy applies to all EU and US-based employees, international technical consultants, sub-contractors, and third-party vendors acting anywhere on behalf of the Company.
• Scope: It covers all commercial business interactions, software licensing, procurement processes, IT service bidding, and public-sector tenders globally.
• Leadership Commitment: Stelios Lazakis, Director, holds ultimate oversight of this policy.

2. Industry Standard Rules Matrix

The following guidelines detail what is strictly prohibited versus what is permissible under monitored conditions:

3. Detailed Procedures for IT Consulting

Gifts, Hospitality, and Entertainment (GHE) Protocol

• Monetary Threshold: No gift, meal, or hospitality value may exceed €100 per person (or local currency equivalent) without written management approval.
• Global Official Pre-Approval: Any entertainment, gift, or meal involving an EU Public Official, a US Government Official, or any government or state-owned enterprise representative from any country requires written validation from Stelios Lazakis, Director, prior to the event.
• GHE Registry: Technical consultants and sales teams must log all given or received business courtesies exceeding €50 in the internal Gift Register within five business days.

Public Procurement, Software Commissions, and Partners

• Tender Integrity: Employees must never attempt to obtain confidential pricing, competitor data, or insider information regarding any public sector IT procurement tenders globally.
• Mandatory Partner Due Diligence: The Company must perform comprehensive background checks before onboarding international sub-contractors, freelance developers, or software reseller agents to ensure they have no history of bribery.
• Transparent Commission Structures: All finder's fees, software referral commissions, or partner payouts must be formally contracted. Payments must be executed via bank transfer directly to the contracted entity's verified bank account.

Political Contributions and Charitable Donations

• Political Contributions: The Company maintains a position of absolute political neutrality. Direct or indirect contributions, financial support, or use of company resources (such as free IT consulting services or software licenses) to support political parties, committees, or individual candidates—whether in the EU, the US, or any other nation—are strictly prohibited.
• Charitable Donations: Any corporate charitable giving, sponsorship, or community investment must be made in good faith without expecting any business advantage in return.
• Donation Guardrails: Charitable contributions may never be used as a roundabout way to bribe a public official or client procurement manager. All corporate donations must be fully transparent, verified as legitimate non-profit entities, and require prior written authorization from Stelios Lazakis, Director.

Financial Books and Records Accuracy

• Complete Transparency: All project expenses, travel claims, software license receipts, corporate donations, and subcontractor payments must be recorded accurately with proper supporting documentation to ensure compliance with FCPA record-keeping provisions.
• No Slush Funds: Creating hidden, unrecorded, or off-book accounts for any purpose is a severe violation of this policy.

4. Reporting Mechanisms & Protection

• Duty to Report: Employees who witness or suspect a violation of this policy must report it immediately to their supervisor or directly to Stelios Lazakis, Director.
• Whistleblower Safeguards: In accordance with the EU Whistleblower Protection Directive and relevant global frameworks, the Company guarantees full anonymity and protection against retaliation, demotion, or discrimination for reporting potential misconduct in good faith.
• Consequences: Violations of this policy will lead to strict disciplinary actions, up to and including immediate termination, alongside potential civil or criminal prosecution by EU, US, or international authorities.