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Anti Bribery Policy

OVZA’s Anti-Bribery Policy enforces strict measures to ensure all business practices are ethical, transparent, and compliant with international laws. We maintain zero tolerance for bribery at every step.

1. Purpose

The purpose of this Anti-Bribery Policy is to ensure that OVZA conducts its business with integrity, transparency, and in compliance with all applicable anti-bribery laws and regulations. This policy establishes clear guidelines to prevent bribery and corruption in all business dealings. OVZA is committed to upholding the highest ethical standards and will not tolerate any form of bribery or corruption within its operations.

2. Scope

This policy applies to all employees, officers, directors, contractors, agents, and any third parties acting on behalf of OVZA. It extends to all locations and jurisdictions where OVZA operates, ensuring that the company’s commitment to ethical conduct is upheld universally.

3. Definition of Bribery

Bribery is defined as the offering, giving, receiving, or soliciting of any item of value as a means of influencing the actions of an individual or entity in a business or governmental decision. This includes, but is not limited to:

  • Cash payments
  • Gifts, hospitality, and entertainment
  • Favors, services, or benefits
  • Political or charitable donations made to influence a decision

Bribery is prohibited regardless of whether it occurs directly or indirectly through third parties.

4. Prohibited Conduct

All personnel of OVZA are strictly prohibited from engaging in any form of bribery. This includes:

  1. Offering, promising, or authorizing any bribe, kickback, or improper payment to any individual, organization, or government official
  2. Soliciting, accepting, or receiving any form of bribery or improper advantage
  3. Engaging in activities that facilitate or disguise corrupt payments, including facilitation payments unless legally mandated Any violation of this policy will result in disciplinary action, including termination of employment and potential legal consequences.

5. Gifts, Hospitality, and Entertainment

Gifts, hospitality, and entertainment may only be provided or received if they are:

  • Modest in value and reasonable in nature
  • Proportionate to the occasion and transparent in intent
  • Serving a legitimate business purpose

Any gifts, hospitality, or entertainment that exceed USD 1,000 cannot be accepted by OVZA employees without the unanimous approval of all members of the legal affairs team. Under no circumstances should gifts or hospitality be given with the intent of influencing business decisions or obtaining improper advantages.

6. Third-Party Engagement

OVZA shall conduct thorough due diligence before engaging third parties to ensure their adherence to anti-bribery standards. Third parties acting on behalf of OVZA must comply with the principles set forth in this policy. Any engagement with them shall be subject to:

  •  Contractual obligations containing anti-bribery clauses
  •  Periodic compliance reviews and audits
  •  Immediate termination of agreements if non-compliance is detected

7. Compliance and Reporting

All personnel are required to report any suspected or actual incidents of bribery or corruption immediately to the Compliance Officer or designated authority. Reports can be made anonymously, and OVZA guarantees that whistleblowers who report concerns in good faith shall be protected from retaliation. Violations of this policy will be subject to strict disciplinary action.

8. Training and Awareness

To ensure compliance, OVZA will provide anti-bribery training to all relevant personnel.
Employees must:

  • Complete periodic refresher training
  • Certify their adherence to this policy

Training sessions will be designed to foster a culture of ethical behavior and reinforce the importance of compliance.

9. Monitoring and Enforcement

OVZA shall:

  •  Conduct periodic reviews and updates of this policy
  • Implement internal audits and compliance checks regularly
  • Take corrective actions when necessary to address any weaknesses in anti-bribery controls

10. Policy Review

This policy shall be reviewed on an annual basis and updated as necessary to reflect changes in legal and business environments. OVZA remains committed to maintaining the highest standards of integrity and transparency in all aspects of its business operations