Anti-Corruption and Conflict of Interest Policy
Purpose
This policy aims to establish clear guidelines to prevent corruption and manage conflicts ofinterest within VENBEST LLC. It promotes a culture of integrrity, tansparency, and accountability, ensuring compliance with applicable laws and ethical standards.
Scope
This policy applies to all employees, directors, officerrs, contactors, suppliers, and any other individuals or entities acting on behalf of VENBEST LLC.
Definition of Corruption
Corruption includes any act of offering, giving, receiving, or soliciting anything of value to improperly influence the actions of another party. This includes bribery, kickbacks, facilitation payments, and any other form of improper benefit or advantage.
Prevention Measures
- VENBEST LLC maintains a zero-tolerance approach to all forms of corruption.
- Employees and associated persons must not engage in any corrupt practices, directly or indirectly.
- Regular risk assessments are conducted to identify and mitigate potential corruption risks.
- Robust internal controls and approval processes are implemented to prevent corrupt activities.
- Mandatory training on anti-corruption laws and company policies is provided to all employees and relevant third parties
- Confidential reporting channels are established to enable reporting of suspected corruption without fear of retaliation.
Employee Responsibilities and Accountability
- All employees must comply fully with this policy and applicable anti-corruption laws.
- Employees are required to avoid situations where personal interests conflict, or appear to conflict, with the interests of VENBEST LLC.
- Any suspected corruption or conflict of interest must be reported promptly through the designated reporting channels.
- Violations of this policy may result in disciplinary action, including termination and legal prosecution.
Conflict of Interest: Disclosure and Resolution Procedures
- Employees must disclose any actual, potential, or perceived conflicts of interest as soon as they arise.
- Disclosures should be made in writing to the Compliance Officer or designated authority.
- The company will review disclosures impartially and determine appropriate actions to manage or resolve conflicts, which may include recusal from decision-making, reassignment, or other measures.
- Failure to disclose conflicts of interest may lead to disciplinary measures.
Monitoring and Enforcement
- VENBEST LLC will regularly monitor compliance with this policy through audits and reviews.
- The Compliance Officer is responsible for overseeing implementation, investigating reports, and ensuring corrective actions are taken.
- All employees will receive periodic refresher training to reinforce understanding and compliance.
Reporting Mechanisms
- VENBEST LLC provides confidential and anonymous channels for reporting concerns related to corruption or conflicts of interest.
- Reports can be submitted via email, hotline, or designated online forms.
- The company prohibits retaliation against anyone who reports concerns in good faith.
Review and Updates
This policy will be reviewed annually oras needed to reflect changes in laws, regulations, or company practices.
Date of Implementation: May 13, 2025
Vadym Olianishyn
General Director
VENBEST LLC
