Eigen upholds integrity and transparency as core principles in all business operations. To reinforce these values, the company implements a comprehensive Anti-Bribery and Anti-Corruption Policy.

 

Corruption is defined as the misuse of entrusted authority for personal gain. Bribery refers to offering or receiving any gift, loan, reward, or advantage as an incentive to act dishonestly, illegally, or in breach of trust in the course of business activities.

 

Purpose

 

This policy outlines Eigen’s principles and practices in combating bribery and corruption. It also provides clear operational guidance for all employees.

 

Commitments

 

Eigen enforces a zero-tolerance approach to bribery and corruption. This policy applies to all commercial transactions and business activities conducted by the company, its subsidiaries, and its partners in every jurisdiction in which Eigen operates.

 

The policy is implemented under a dedicated Anti-Corruption Program, which is continuously reviewed and updated to reflect changes in legislation, reputational expectations, and operational dynamics.

 

Eigen commits to full compliance with this program and maintains a consistent pursuit of ethical business conduct. The management assumes responsibility for the implementation, oversight, and clarification of this policy and its principles.

 

Scope and Definitions

 

Political and Charitable Contributions

 

Eigen refrains from engaging in any political contributions, whether financial or in-kind, to political parties or campaigns. Employees may participate in political and democratic processes solely in their personal capacity.

 

The company allows charitable donations and community support in the form of financial contributions, services, or information exchange, provided such actions are transparent and not used to disguise bribery. Managers and employees ensure due diligence is exercised at all times.

 

Facilitation Payments

 

Facilitation payments—typically made to expedite routine governmental actions—are recognized as a form of bribery. Although often requested by lower-level public officials, such payments are prohibited under many legal frameworks. Eigen strictly prohibits facilitation payments and actively works to prevent them in all jurisdictions.

 

Gifts and Hospitality

 

Gifts may include items such as flowers, chocolates, or beverages, while hospitality includes meals, receptions, and event invitations offered within a business context.

 

Eigen permits the giving and receiving of gifts and hospitality only when they are modest, proportionate, and lawful. Under no circumstances may such offerings be excessive or influence business decisions. In the case of public officials, all actions must comply with local laws and regulations.

 

Protection Payments

 

In certain regions, extortion in the form of protection payments may occur. Eigen does not tolerate or pay protection money. If any such incident arises, it must be reported immediately to management, which may, when necessary, suspend business activities to ensure safety.

 

Implementation

 

Roles and Responsibilities

 

All employees are expected to comply with this policy and take an active role in preventing bribery and corruption. Managers are responsible for communicating the policy and ensuring that all internal and external stakeholders under their supervision understand and adhere to its provisions.

 

Section 3 of this policy sets out minimum requirements related to political contributions, charitable donations, facilitation payments, gifts, and hospitality. These requirements do not override national legislation, and legal compliance remains mandatory at all times.

 

When confronted with a request for a facilitation payment or an inappropriate gift or hospitality, the individual must:

• Clearly reject the offer,

• Inform their manager before proceeding, where feasible,

• Keep any unavoidable payments to an absolute minimum,

• Record all details accurately and promptly.

 

Business Relationships

 

Subsidiaries and Business Partners

 

Prior to entering into any commercial engagement, Eigen conducts due diligence to ensure that subsidiaries and business partners are fully aligned with the Anti-Bribery and Anti-Corruption Program.

 

Distributors and Agents

 

Payments to distributors and agents must reflect fair compensation for legitimate services. Contracts are established with clear terms and include binding commitments to comply with this policy. Eigen reserves the right to terminate agreements in the event of non-compliance.

 

Contractors and Suppliers

 

Eigen manages all procurement activities with fairness and transparency. Due diligence is performed when evaluating major suppliers and contractors. All third-party partners are informed of this policy, and any breach may result in contract termination. The company avoids working with entities known to have engaged in corrupt practices.

 

Awareness and Training

 

Eigen ensures that all employees are aware of and understand this policy. Mandatory training is provided during onboarding and updated annually for key personnel, covering relevant laws, ethical expectations, and business conduct standards.

 

Sanctions

 

Employees are not penalized for refusing to participate in corrupt practices, even if such refusal leads to lost business opportunities. Violations of this policy result in disciplinary measures, up to and including termination of employment.