Technovate N.V. is committed to conducting business with integrity, transparency, and in compliance with all applicable anti-corruption laws. This Anti-Corruption Policy outlines our zero- tolerance stance on bribery and corruption and provides guidance to our employees, contractors, partners, and clients on what is expected. We adhere to Surinamese anti-corruption laws (including the Anti-Corruption Act of 2017 which establishes anti-bribery rules and a Commission[44]) and, given our international dealings, we also respect the principles of laws like the US Foreign Corrupt Practices Act (FCPA) and UK Bribery Act in spirit and practice.

1. Scope and Applicability

This policy applies to all Technovate-employees, officers, directors, contractors, consultants, and any other parties acting on our behalf (collectively referred to as “personnel” for this policy). We also expect our suppliers, vendors, and business partners to uphold similar anti-corruption standards – adherence to this policy (or your own equivalent) is a condition of doing business with Technovate.

2. Definitions

• Bribery: Offering, promising, giving, accepting, or soliciting of any goods of monetary value (money, gifts, favors, services or anything else of value) as an inducement or reward for doing something illegal, unethical, or a breach of trust, to gain any business or personal advantage. Bribes can be direct or indirect (through third parties).
• Corruption: Abuse of entrusted power for private gain. This includes not just bribery but other unethical practices like nepotism, embezzlement, conflict of interest, etc., in a business or government context.
• Public Official: Any officer or employee of a government or any department, agency, or instrumentality of a government (including state-owned enterprises), or a public international organization, or any person acting in an official capacity for or on behalf of such entities. Note: Many anti-bribery laws have strict rules about interacting with public officials.
• Facilitation Payment: A small payment (often unofficial) made to a low-level public official to expedite routine, nondiscretionary governmental action (e.g., processing permits, providing services like mail delivery). Even if common in some places, these are often considered bribes under many laws and under this policy are treated as bribes.

3. Policy Statement

Technovate strictly prohibits all forms of bribery and corruption, whether dealing with public officials or private sector individuals or entities. Specifically:

• No Bribes: You must not offer, give, or authorize any bribe, kickback, illicit payment or other thing of value to any person or entity with the intent to obtain or retain business, or to secure an improper advantage. This includes “grease” or facilitation payments. If you are confronted with a request or demand for improper payment, you must decline and report the incident to Technovate management or the compliance contact (see Reporting section below). We would rather lose business than gain it through bribery.
• No Acceptance of Bribes: Likewise, you must not solicit or accept any bribe or improper payment or advantage. You should not misuse your position at Technovate for personal gain. If a supplier or partner offers you something valuable to influence a decision, you must decline and report it.
• Gifts and Hospitality: Technovate recognizes that modest gifts and hospitality can be a legitimate part of business relationships. However, they can also be misused for improper influence. Therefore, offering or accepting gifts, meals, or entertainment is only permissible if it is reasonable, proportional, and for a genuine purpose (e.g., a modest promotional item, or a working lunch). Extravagant or frequent gifts/hospitality are prohibited. Cash or cash-equivalents (like gift cards) should never be given nor will be accepted as a business gift. If you are unsure whether a proposed gift or event is appropriate, seek guidance from management. Any gift or hospitality that could be perceived as a bribe is not allowed.
• Donations and Sponsorships: Charitable donations or sponsorships by Technovate must not be a subterfuge for bribery. We do donate to community causes, but never as an exchange for business favors. Any requests for donations by clients or officials must be treated cautiously. Political donations on behalf of Technovate are generally not allowed unless approved by the board; personal political donations must not be claimed to be from Technovate.
• Business Partners and Third Parties: We expect agents, consultants, resellers, or any third party representing Technovate to comply with this policy. You must not use a third party to do something that we ourselves cannot do (no “shadow bribery”). Due diligence should be conducted on key third parties, especially those interacting with government on our behalf, to ensure they have a reputation for integrity. Compensation to third parties must be for legitimate services and at appropriate market rates. Unusual payment methods (cash, offshore accounts not related to transaction, payments to different name) are red flags.
• Conflicts of Interest: All personnel should avoid situations where personal interests conflict (or appear to conflict) with Technovate’s interests. This can relate to anti-corruption as well – e.g., awarding a contract to a company owned by a relative without disclosure. Such conflicts must be disclosed and managed. Hiring decisions and contract awards should be based on merit, not personal benefit.

4. Books and Records

We must maintain accurate books, records, and accounts that correctly reflect all company transactions. This is not only good practice but also a requirement under laws like the FCPA (for companies subject to it). False or misleading entries that conceal the true nature of a transaction (for example, recording a bribe as a “consulting fee” or “marketing expense”) are strictly prohibited. All expenses, receipts, invoices, and financial dealings must be documented with honesty and detail. Periodic audits may be conducted to ensure compliance.

5. Training and Awareness

Technovate will provide anti-corruption training to employees and key partners as appropriate, especially those in roles with high corruption risk (sales, procurement, management, etc.). All relevant personnel are expected to participate in such training and understand this policy. New employees will receive a briefing on anti-corruption expectations as part of onboarding. This policy will be available on our intranet/website, and by signing employment or contractor agreements, individuals agree to comply with it.

6. Reporting and Seeking Guidance

Everyone at Technovate has a responsibility to help prevent bribery. If you suspect or become aware of any violation of this policy (or any corrupt behavior in our business dealings), you must report it. We encourage a speak-up culture and will not tolerate retaliation against anyone who reports concerns in good faith.

• How to Report: You can report concerns to your manager or directly to our designated compliance officer (if one is appointed). You may also report via email to [email protected] or [email protected] (reports will be directed to the appropriate internal authority). If you feel uncomfortable using internal channels, you may use an anonymous method if available (like a suggestion box or third-party hotline if we have one).
• Confidentiality: Reports will be treated confidentially to the extent possible. We may need to share information with those investigating or with law enforcement but will do so carefully.
• No Retaliation: Technovate prohibits retaliation against anyone for making a good-faith report or for cooperating in an investigation of a report. Any act of retaliation should be reported and will be treated as a serious violation of this policy.
• Guidance: If you are faced with a situation and are unsure whether it’s permissible under this policy (e.g., a client in another country asks you to add a small “tip” for expediting paperwork), you should pause and seek guidance. Contact management or the compliance contact for advice before acting.

7. Enforcement and Discipline

Technovate will investigate all reported or suspected violations of this policy. All employees and partners are required to cooperate fully and honestly in such investigations.

• Consequences: Anyone found to have violated this Anti-Corruption Policy will face disciplinary action, up to and including termination of employment or contract. In the case of third-party partners, a violation could lead to termination of the business relationship.
• Legal Consequences: Bribery and corruption are crimes. Violations can result in heavy fines and even imprisonment for individuals, and fines and reputational damage for the company. We will not protect individuals who engage in illegal acts; to the contrary, we will report criminal conduct to the authorities when appropriate.
• Corrective Actions: Beyond discipline, if a violation occurs, we will review what went wrong and strengthen our controls or training to prevent future incidents. The company’s leadership will also monitor compliance and report on anti-corruption measures internally (and externally to stakeholders if required).

8. Summary

In summary, Technovate N.V. takes a zero-tolerance approach to bribery and corruption. Integrity is one of our core values and cannot be compromised. We compete and do business based on the quality of our services, not on unethical practices. By adhering to this policy, you are protecting yourself, your colleagues, and the company from legal and reputational harm, and contributing to a fair business environment.

If you have any questions about this Anti-Corruption Policy or need further clarification on acceptable conduct, please contact [email protected] or reach out to your manager. Thank you for upholding our standards and commitment to ethical business.