Anti-Corruption Policy

BUSINESS SKILLS ANTI-CORRUPTION POLICY (SKILLS srl)

 

  1. OBJECTIVE

Since its establishment, SKILLS (hereinafter SKILLS) has been recognized for the quality of its products and its customer service, as well as for the way its commercial activities are conducted and how it interacts with its different interest groups (hereinafter “stakeholders” ). The purpose of this Policy (hereinafter, “the Policy”), is to document and disseminate to all SKILLS employees, their collaborators, directors, executives, representatives and their stakeholders in general, an absolutely clear and firm message of opposition corruption in all its forms, both in the public and private spheres, and SKILLS ‘desire to avoid this type of conduct in all its activities. This Policy constitutes a commitment to permanently prevent, monitor and punish acts and conducts that are fraudulent or that promote corruption in all its forms; maintenance of effective communication and awareness mechanisms for all recipients and the development of a business culture of ethics and honesty and a key element for the prevention of the commission of criminal acts and, therefore, its effective application should serve to prevent, detect and correct illegal actions that could expose both SKILLS and its shareholders to any type of criminal liability. All SKILLS employees, its collaborators, executives, directors and representatives, must be aware of this Policy, request clarifications and additional information when necessary, observing its terms and applying its content, as well as all applicable anti-corruption legislation.

  1. SCOPE

This Policy applies to all employees, collaborators, directors, executives and representatives, who, regardless of their country of origin or residence, are responsible for understanding and complying with it at all times. Likewise, they will have the obligation to report through the channels available for this purpose, in the shortest possible time, any breach of the Guidelines and procedures described in this document.

  1. GUIDELINES

3.1 Statement of the Policy. Employees, collaborators, directors, executives and representatives of SKILLS must never offer or grant, request or receive, directly or indirectly, any type of payment or consideration of any nature with the aim of: (a) influencing SKILLS decisions that affect the Company’s business activities; (b) obtain personal gain; or (c) obtain confidential information about business opportunities, tenders or activities of its competitors. SKILLS employees, collaborators, directors, executives and representatives must avoid any misconduct or conduct that may have an inappropriate appearance. SKILLS only makes decisions based on legitimate business factors, such as price, quality and service, among other reasonable elements. Gifts, entertainment, hospitality benefits, donations to political or charitable groups, favors and any other type of benefits, offered or received, should never be part of SKILLS decision-making processes.

3.2 Giving and receiving gifts and favors. In general, it is prohibited to offer, promise, give or receive gifts or favors, directly or indirectly, with the aim of influencing decisions that affect SKILLS business interests, or represent personal benefit. Money or equivalent securities may never be offered or received. If you have any questions about how to proceed, you should consult your line manager.

3.3. Presenting false, misleading or erroneous information in a conscious and intentional manner, may lead to disciplinary actions against the employees, collaborators and / or executives involved, even up to their dismissal. All hospitality benefits must meet the following conditions:

  • SKILLS employees, collaborators, executives, directors, representatives and agents should not select the specific person (s) who will receive these benefits. The organization or company in which they work must designate the people who will receive these benefits. Notwithstanding this, SKILLS employees, collaborators, executives, directors, representatives and agents may give suggestions in order to ensure the participation of those persons who are considered essential to achieve the legitimate purposes.
  • SKILLS will only pay for expenses necessary to achieve legitimate business purposes, in the most efficient manner possible. That does not include field trips, off-the-beaten-track trips, entertainment expenses, or “extra days.”
  • Necessary expenses for hospitality benefits should be for modest travel and / or accommodations.

3.4 Political Contributions and Sponsorships. Any donation or contribution to political parties is prohibited.

3.5 Social Responsibility and Social Contributions. SKILLS carries out social responsibility initiatives, such as supporting social projects with a focus on the integral development of children and young people through investment in programs in the areas of education, work, culture, sports and social justice. In the event that SKILLS employees, collaborators, executives, directors and representatives intend to implement such initiatives, they must coordinate the actions in conjunction with the specific area of ??the Company in charge of coordinating those activities. To ensure that these operations do not facilitate money laundering or any other type of illegal activity, SKILLS must carry out due investigation on the identity and reputation of the organization or beneficiary, the identity of the main participants, the class of the activities of the organization and its links with other entities. All records related to donations and social contributions must be complete and correct, with verification and verification that the donations and contributions were intended and used for the purposes for which they were originally intended. In particular, and without prejudice to the consequences that may arise from the non-application of this Policy, knowingly and intentionally presenting false, misleading or erroneous information, or neglecting the information in the same way, may involve disciplinary actions against employees, collaborators and / or executives involved, even until dismissal.

3.6 Other Types of Benefits. Providing favorable opportunities (for example, securing internships and jobs for a relative of the client or business partner; making a charitable or other contribution at the request of third parties; providing a product or service) should also be considered as acts potentially subject to anti-corruption laws. . According to these laws, “bribery” includes the delivery or promise of “anything of value”, such as the granting of favors, jobs, social donations or favorable opportunities provided directly or indirectly to business contacts and people who may impact SKILLS business activities. SKILLS employees, collaborators, executives, directors and representatives must acknowledge and approach these situations with great caution and communicate with their superior.

 

3.7 Other Prohibited Behaviors. Other strictly prohibited conduct are the following:

  • Any form of corruption, extortion or fraud
  • Offering or accepting tips, bribes or other illicit incentives; Falsification of documents, expense reports, financial records, brands or products
  • Misappropriation, smuggling, counterfeiting, corporate espionage, revealing of secrets or other unfair and anti-competitive practices

3.8 ACCOUNTING CONTROLS. Books and accounting records. SKILLS maintains an internal accounting control system that requires all employees to make and maintain accurate detailed records that accurately reflect the operations and disposition of the Company’s assets. False, misleading, or incomplete entries in such records or other documents are strictly prohibited. No funds or accounts may be established that are not disclosed or recorded, whatever the reason. The expenses incurred by employees, collaborators, executives, directors and representatives on behalf of SKILLS must be verified through the detailed description of activities and valid receipts or invoices that reflect the amounts spent. Both the presentation and the conscious acceptance of false records, receipts and / or invoices are strictly prohibited, and will be subject to sanctions, including dismissal and the initiation of a legal action against the person (s) involved (s).

3.9 THIRD PARTIES. SKILLS conducts its activities in accordance with the highest standards of ethics and integrity. SKILLS carries out the due analysis before contracting with third parties, and monitors their activities afterwards. The scope and depth of the analysis and monitoring should be commensurate with the risk of potential corrupt activities. Clauses must be included in all contracts signed with third parties to ensure compliance with this Policy, in order to prevent and mitigate the risks of committing acts of corruption.