Clearcode’s Compliance and Ethical Behavior Policy

Clearcode’s Anti-Bribery and Anti-Corruption Policy (hereinafter referred to as: Policy) puts in place the procedure and measures which are imposed by Clearcode at a group level, in order to prevent bribery, corruption and other improper activities of happening in the conduct of Clearcode’s business operations.

Clearcode endeavors to conduct its business ethically and in compliance with applicable laws, rules and regulations, and at the same time, to ensure that all personnel involved in its business operations, whether as employees or as third parties acting on behalf of Clearcode, to adhere their activities to all applicable laws, rules and regulations.

The content of this Policy is compiled and mainly based on the legislations of the companies, members of Clearcode, international rules and regulations related to bribery and corruption prohibition, and other laws that prohibit improper payments or other forms of inducement to obtain a business advantage.

For the purposes of this Policy, Clearcode shall mean and include all companies which are part, owned and directly or indirectly controlled by Aricoma Group.


Clearcode is committed to complying with all laws and regulations which govern our operations in every country in which we operate. This Policy explains our individual responsibility to comply with anti-bribery and anti-corruption laws around the world and to ensure that any third parties that we engage to act on our behalf, do the same.

The penalties for violating these laws can be severe, both for the Company and for the individuals involved, including significant corporate and individual fines, and imprisonment.

Clearcode has a zero-tolerance attitude towards bribery. Even the suggestion of corruption may damage the reputation of the Company and affect its ability to do business, as well as the reputation of its employees. The Company is therefore committed to doing business ethically, even if this means not gaining new business, not using the services of particular agents or business partners who support growth through activities that may be corrupted or incurring delays in carrying on our existing business.Our commitment is to act professionally, fairly and with integrity, to help create a high degree of trust and build solid and sustainable relationships.

Clearcode is required by each and every one of its personnel to act in an honest, open and ethical way. Clearcode chooses its partners within the same spirit in adhering to the anti-bribery principle and requirements. Corruption is contradictory to the objective of doing good business, our mission, vision or values as an organization. It damages the confidence Clearcode co-workers, suppliers, customers and other stakeholders have in the Clearcode and its brand. Furthermore, corruption undermines the rule of law, distorts markets, and denies the many people their rightful share of resources. By implementing this Policy, Clearcode sets out Clearcode responsibilities as well as responsibilities of those working for and with Clearcode, in observing and upholding our position on bribery and corruption, which would be an absolute refusal of bribery and corruption in any form.



Bribery” includes the act of offering, promising, giving, asking, agreeing, accepting or soliciting something of value for the purpose of influencing an action. Bribery is mainly focused on improper or illegal payments in exchange of any commercial, contractual, regulatory or personal advantage.

“Bribe” means a sum of money or other inducement offered or given to persuade someone to do something, usually dishonest.

“Corruption” refers to the abuse of entrusted power for private gain.

“Improper payments” include bribes, kickbacks, excessive gifts or entertainment higher than the ordinary or customary representation of a company, or any other payment made or offered to obtain an undue business advantage.
These payments should not be confused with reasonable and limited expenditures for gifts, business entertainment and other legitimate activities directly related to the conduct of Clearcode’s business.

“Kickback” refers to an illegal payment intended as compensation for favorable treatment or other improper services. The kickback may be money, a gift, credit, or anything of value. Paying or receiving kickbacks is a corrupt practice that interferes with an employee’s or a public official’s ability to make unbiased decisions.

“Facilitation payments” are a form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine governmental action, and not to obtain or retain business or any improper business advantage. Facilitation payments tend to be demanded by low level officials to obtain a level of service which one would normally be entitled to.

Prohibition of bribery

Clearcode prohibits bribery or other improper payments in any of its business operations. This prohibition applies to all business activities,anywhere in the world, whether they involve government officials or are entirely commercial. A bribe or other improper payment to secure a business advantage is never acceptable and can expose individuals and Clearcode to possible criminal prosecution, reputational harm or other serious consequences

It is not allowed to:

For the purposes of this policy, “third party”means any individual or organization contacted during the course of the work for/with Clearcode including actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

Policy Applicability

This Policy applies to everyone at Clearcode, including all officers, employees and agents or other intermediaries acting on Clearcode’s behalf. This policy also applies for partners, joint ventures and suppliers. The responsibility and obligation under this policy are personal, everyone who conducts Clearcode’s business activities must conduct it ethically and in compliance with the law. Failure to do so may result in disciplinary action, including dismissal, employment termination and compensation of damages. This Policy applies to all individuals working at all levels and grades, including managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, volunteers, interns, agents, or any other person associated with Clearcode, or any of our subsidiaries or their employees, wherever located (collectively referred to as workers in this policy).

This Policy applies in all material respects to business conducted with or through an agent, consultant, joint venture or other business partner. Employees who manage, supervise and/or oversee the activities of third parties working with Clearcode are responsible for ensuring that such persons or entities understand and fully comply with this Policy, through appropriate measures. The obligation for the personnel working with agents and other third parties includes paying particular attention to unusual or suspicious circumstances that may indicate possible legal or ethics concerns. Clearcode could be held responsible for the actions of a third party (e.g.employee, business associate, agent, contractor, supplier, consultant) acting on its behalf. As such, care must be taken to ensure that those third parties do not engage or attempt to engage in bribery while working or representing Aricoma Group.

All group companies shall:

Charitable contributions, political donations and facilitation payments

Political Donations mean donations of money, goods or services for the benefit of political parties, political campaigns, or individual politicians. It includes donations made directly or indirectly, and donations made spontaneously or upon request. Clearcode does not make political donations, whether in cash or kind, in support of any political parties or candidates.

Employees and officers of Clearcode are free to engage in political and trade union activity on their own behalf, but they must not purport to be doing so on behalf of Clearcode.
If anyone requests or suggests that Clearcode makes a political donation, you should immediately inform the Compliance Officer or the Legal Department of Clearcode.

Clearcode only makes charitable contributions and support, whether of in kind services, knowledge, time, or direct financial contributions that are legal and ethical under local and international laws and practices. However, our charitable activity is separated from our commercial activity, and we will never make charitable donations in order to achieve commercial objectives.

Charitable Donations means donations of money, goods or services for the benefit of charitable organizations for community groups. It includes donations made directly or indirectly, and donations made spontaneously or upon request of another person.

It is never permitted to make Charitable Donations in return for business or a business advantage. It is never permitted to make Charitable Donations in return for any other decision or in return for any favorable treatment.

If not already approved in the budget of the relevant Clearcode company, Charitable Donations in excess of EUR 200 must be approved by the CFO of Clearcode.

The Finance Department of Clearcode must create an accurate and timely record of any Charitable Donation. The record must, at a minimum, identify the sum/nature of the Charitable Donation, the recipient of the Charitable Donation, the purpose of the Charitable Donation, and the person who approved the Charitable Donation.

All donations must be:

Donations must not:

Facilitation payments, as small unofficial payments to public officials to ensure or speed up performance of routine or necessary action which is part of the public official’s usual responsibilities, are considered bribes, regardless of whether they may be a part of the “way of doing business” in a particular country. As a representative of the Company, you must not make any facilitation payments.

Gifts and hospitality

The act of exchanging business gifts and receiving corporate hospitality can play an appropriate role in building or maintaining business relationships. However, gifts and hospitality are problematic if they create actual or perceived conflicts of interest, or otherwise appear to influence a business decision

Accepting gifts, discounts, favors, or services from a current or potential customer, competitor, supplier, or service provider is prohibited if that benefit is a type or amount which has the potential to influence a person’s business decision.

Usually acceptable
Gifts and Hospitality are usually acceptable if they are
a) of nominal and modest value;
b) given and received transparently;
c) given and received without further obligation;
d) given and received infrequently and to a variety of recipients;
e) promotional (Clearcode’s pens, mugs, accessories etc.)
f) exchanged as part of genuine cultural traditions in the relevant market (Christmas, New Year, etc)
g) appropriate in a business context
h) legal in the relevant country;
i) given and received during an approved marketing or communications campaign

Danger –Proceed cautiously

You must receive advance written permission from your line manager or the Compliance Officer or the Legal Departmentof Clearcode before giving any Gifts or Hospitality of any value to any Public Officials.

The following thresholds apply in relation to Gifts and Hospitality that you may give or receive to and from individuals who are not Public Officials

If you want to give Gifts or Hospitality to someone, you should research the gifts and hospitality rules of that person’s organization or employer. This will avoid the embarrassment of offering something that the person cannot accept and must refuse.

Always Prohibited:

Gifts and Hospitality are prohibited if they are any of the following:


As a company, we are committed to observing the laws and regulations that govern our operations in every country where we do business. This Policy explains our individual responsibility in complying with anti-bribery or anti-corruption laws around the world and ensuring that any third parties that we engage to act on our behalf, do the same. The management of Clearcode is committed to complying with all laws. Any employee who violates the rules in this Policy or who permits anyone to violate those rules shall be deemed making a severe breach of employment responsibilities and may be subject to appropriate disciplinary action, up to and including dismissal and employment termination, and may be subject to personal civil or criminal sanction.

All officers, employees and agents are responsible for understanding and complying with this Policy, as it relates to their job positions.

This Policy provides the following obligations:

Clearcode managers have a particular responsibility to ensure that subordinates, including agents, receive proper training, and to monitor for compliance with the Policy.

Reporting (possible violations)

Employees and officers who think that bribery and/or corruption is occurring in relation to Clearcode’s business must immediately inform their Line Manager, the Compliance Officer or the Legal Department at Clearcode or send an email describing the concern to

No one is immune to sanction, if corrupted!

Employees who violate this Policy will be subject to disciplinary action, up to and including dismissal and compensation of damages caused by this kind of action to Clearcode.

Violations can also result in prosecution by law enforcement authorities and serious criminal and civil penalties. Clearcode reserves the right to terminate all contractual relationships with other workers, agents, consultants, suppliers, joint venture or other business partners in case it has reasonable belief that some of them has committed or has been involved in bribery, corruption or other prohibited activities and use any available legal instruments to protect its rights further.

Prevention and training

Anti-bribery and anti-corruption training, as part of the Compliance training, forms part of the induction training process, mandatory for all new employees. All existing employees will receive regular, relevant training on how to implement and adhere to this Policy. Also, separate training sessions may be ad hoc organized to targeted teams, if needed for a certain project and/or customer.

Clearcode’s zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.

Management at all levels have primary and day-to-day responsibility for implementing this policy, and for monitoring its use and effectiveness.

Clearcode keeps financial records and has appropriate internal controls in place which evidence the business reason for making payments to third parties. Everyone must keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review. All accounts, invoices, memorandum and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments. It is important that every employee reports to his/her supervisor or the next level of supervision,as soon as possible,if he/she is offered a bribe by a third party, is asked to make one, suspect that this may happen in the future, or believe that he/she is a victim of another form of unlawful activity.

Monitoring and review of the policy

Clearcode will monitor the effectiveness and review the implementation of this Policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. All employees are responsible for the successful implementation of this Policy and should ensure they use it to disclose any suspected danger or wrong doing.

Modifications of the policy (general provisions)

Any modification on this Policy can be made only by Clearcode. Every update of the Policy will be written and published as a new version in an accessible location or relayed in proper manner.


For any question and/or additional information, contac Clearcode at

If you are uncertain about how to behave in a specific situation, or if you think we are not living up to our Clearcode values, you should share your concerns promptly. You can speak to your Manager, the Compliance Officer (Jakub Zębik) or address your concern to the Finance/Legal Department at Clearcode or you can send an email to .

By reading this Policy, you acknowledge that you have read, understand and you comply with the content of it. The prevention, detection and reporting of bribery, corruption and/or other forms of activities forbidden hereunder, are the responsibility of all those working with and for Clearcode.

Latest update: June, 2022

Clearcode anti-bribery and anti-corruption policy
Clearcode Services S.A.
Version: No.3