Policy statement.
HEXATECH SH.P.K. prohibits bribery and corruption in all forms. No HEXATECH person — employee, officer, director, agent, consultant, or third party acting on behalf of HEXATECH — may offer, give, request, accept, or authorise any improper advantage, in any jurisdiction, in connection with HEXATECH business.
No commercial opportunity, however significant, justifies a breach of this policy. HEXATECH declines business that cannot be won lawfully.
Alignment with international standards.
The policy is aligned with:
- ISO 37001 — Anti-bribery management systems
- UN Convention against Corruption (UNCAC)
- OECD Anti-Bribery Convention
- UK Bribery Act 2010 — applicable where HEXATECH or its counterparties have UK nexus
- US Foreign Corrupt Practices Act (FCPA) — applicable where US nexus exists
- Kosovo Law No. 06/L-011 on Prevention of Conflict of Interest and the Criminal Code of Kosovo
Specific prohibitions.
- No facilitation payments of any kind.
- No improper gifts, hospitality, or entertainment to public officials. Ordinary hospitality is permitted within documented limits.
- No political contributions in the name of, or funded by, HEXATECH.
- No charitable contributions made with the purpose or effect of securing improper advantage.
- No use of intermediaries to circumvent the above prohibitions.
Controls.
- Counterparty due diligence on agents, consultants, joint-venture partners, and distributors.
- Written anti-bribery clauses in all commercial agreements with third parties.
- Periodic anti-bribery training for all personnel, with enhanced training for commercial and business-development roles.
- Approval workflow for hospitality, gifts, and donations above defined thresholds.
- Independent whistleblowing channel (see Whistleblowing).
- Annual risk assessment by the Compliance Officer, reported to the Compliance Committee.
Breach and enforcement.
Breaches of this policy are grounds for disciplinary action up to and including dismissal, termination of third-party agreements, and referral to law-enforcement authorities. Retaliation against a person reporting a suspected breach in good faith is itself a breach of this policy.