Anti-Corruption Guidelines for Smets Technology and Its Sales Representatives

1. Purpose The Anti-Corruption Guidelines aim to prevent, detect, and address corruption and bribery in all forms. These guidelines are designed to ensure compliance with anti-corruption laws and uphold Smets Technology’s commitment to ethical business practices.

2. Scope These guidelines apply to all employees, sales representatives, contractors, and third-party agents acting on behalf of Smets Technology.

3. Prohibited Practices

     • Bribery: Offering, giving, soliciting, or accepting any form of bribe, kickback, or undue advantage is strictly prohibited.

     • Facilitation Payments: Small payments made to expedite routine actions are not allowed.

     • Improper Gifts and Entertainment: Providing or accepting gifts, meals, or entertainment to influence decisions is forbidden.

     • Third-Party Misconduct: Using third parties to engage in corrupt practices is prohibited.

4. Guidelines for Sales Representatives

     • Transparency: Conduct all transactions with clear documentation and full transparency.

     • Due Diligence:: Assess the integrity of clients, vendors, and partners before engaging in business relationships.

     • Compliance with Laws: Adhere to all local and international anti-corruption laws, including Smets Technology’s Code of Conduct.

     • Fair Competition: Avoid anti-competitive practices such as collusion or bid-rigging.

5. Gifts and Hospitality Policy

     • Permissible Gifts: Modest and customary gifts that comply with local laws and company policies are allowed.

     • Approval Requirements: Gifts exceeding a specific value must be pre-approved by management.

     • Record Keeping: Maintain detailed records of all gifts and hospitality provided or received.

6. Reporting and Whistleblowing

     • Reporting Mechanism: Report any suspected corruption or unethical behavior promptly through designated channels.

     • Protection Against Retaliation: Employees and representatives are protected against retaliation for reporting concerns in good faith.

     • Investigation and Follow-Up: All reports will be investigated thoroughly and fairly.

7. Training and Awareness

     • Regular Training: Participate in mandatory anti-corruption training sessions.

     • Policy Updates: Stay informed about updates to anti-corruption laws and company policies.

     • Resources: Access anti-corruption resources provided by the company for guidance.

8. Consequences of Non-Compliance Failure to comply with these guidelines may result in disciplinary action, including termination of employment or contracts, and potential legal consequences.

9. Commitment Statement Smets Technology is dedicated to maintaining the highest standards of integrity and ethics. By adhering to these Anti-Corruption Guidelines, we protect our reputation, ensure compliance with the law, and foster a culture of transparency and trust.

Acknowledgment All employees and representatives are required to acknowledge and adhere to these guidelines. By doing so, you contribute to Smets Technology’s commitment to ethical excellence.