Anti corruption directive

1 brief introduction

1.1 brief introduction

In almost all countries of the world, corruption and bribery are punishable by fines or imprisonment. Therefore, the fifth code of conduct of the Buch group (BucherGroup) prohibits all forms of corruption and bribery. The purpose of this anti corruption directive ("directive") is to give specific explanations to the fifth article and to enhance employees' awareness of the danger of corruption. Therefore, this directive has revised the code of conduct and strengthened the global compliance plan of the buck group by formulating specific rules of conduct.

Managers, employees and business partners of Buch group should not be involved in corrupt practices, no matter which country they are in.

1.2 scope and responsibility

This directive applies to all employees of Buch industries (BucherIndustries) and all its affiliated group companies (Buch group). All managers and employees of the Buch group must be honest, realistic and ethical in the process of dealing with individuals or individuals acting on behalf of a company or a private sector entity or by a company or a private sector entity, and should be familiar with their local laws in the country where they are located.

2 Definition

2.1 corruption

Corruption is a general term for all forms of bribery and corruption. Corruption refers to abuse of power or authority for personal interests. This kind of behavior is illegal. It is illegal to give bribes to anyone (whether this person is in the public or private sector) or to take bribes from anyone, whether directly or indirectly or accepting bribes. Even if a promise or benefit is not given to a business partner to act in a specific way, this anti-corruption provision still applies. Corruption does not require the success of bribery; giving bribes is enough to constitute a crime. Various forms of corruption are defined below.

2.2 bribe

Bribe can be "bribe" or "take bribe".

Bribery refers to the provision, commitment, granting, or presentation of anything valuable, whether economic or other, to improperly influence the other person in order to gain commercial or other benefits.

Asking for bribes is the opposite of bribes. It means solicitation or acceptance of any valuable thing as an inducement or reward for improper conduct related to the granting of business or certain other benefits.

Bribery can include money, gifts, hospitality, expenses, reciprocity, political or charitable donations, or any direct or indirect interest or consideration.

Bribery can be carried out directly or indirectly. Indirect bribery usually involves the use of intermediate ginseng and bribery in order to cover up or circumvent anti-corruption regulations. According to some state laws, the Buch group may have to be responsible for the bribe paid by the middleman on behalf of himself, even if the Buch group does not know that the bribe has occurred.

Examples of indirect Bribery:

The bribe in the name of "service charge", if the actual assessment is made, the amount of the service charge is disproportionate to the service provided.

Discounts or bonuses given for the purpose of corruption;

Issuing invoices for the amount of false payment ("overpriced" / "rebate");

2.3 managers

Managers include group management members, management and senior executives of group companies, and group compliance commissioners.

2.4 employees

Employees include all individuals who represent the group company to perform their duties.

2.5 middleman

The middleman works on behalf of the group in its own name or in the name of the group company, which can include consultants, agents, sub agents, brokers and consultants.

2.6 unsuitable benefits

Improper benefits are any interests that the person receiving a bribe has no right to obtain. The purpose is to improperly influence the behavior of the bribe or to establish a control relationship that makes the bribe in the status of benefiting the bribe.

2.7 public officials

A public official refers to any individual, a candidate, or a government owned or controlled company (such as a hospital controlled by a government) acting as a public, political, or military organization or organization (such as the government, government departments, government agencies, political parties and party leaders, the court). A doctor or an employee of a national or international organization such as the United Nations. If a public sector entity controls a private sector company (for example, by holding most rights), the individual working for the private sector company is regarded as a public official.

3 form of bribe

3.1 brief introduction

Buch Group recognizes that giving and receiving benefits, such as gifts, hospitality and hospitality, may be part of the process of establishing normal business relations. This approach may vary greatly between the different regions where the business of bu he Group operates. However, the grant and reception of certain gifts and hospitality, regardless of the local laws and customs, may imply that some improper influence has been confirmed (the imposition may be imposed on or imposed by the Buch group or by the Buch group), or some conflict of interest has come into being. In some cases, giving and / or receiving gifts or entertainment can be regarded as a bribe, which is illegal and will damage the reputation of Buch group. The following criteria can be used to confirm that certain interests are reasonable, appropriate and acceptable in specific circumstances, or are they criminal:

The value of interest,

Social acceptability,

Accept the position of the beneficial person in administrative rank or company / organization, or

The frequency of the occurrence and the purpose of giving that benefit.

With help to distinguish between unacceptable benefits and acceptable benefits, the most common types of undesirable benefits will be described below.

3.2 gifts

Gifts or gifts are transferred to another person without any return. If the value of the gift is high, it is not allowed to receive or accept such gifts when it is considered to be improperly affected by the recipient's behavior or to establish a relationship between the recipient and the beneficiary. Any cash or cash equivalents (such as travel coupons or personal checks) are not allowed in the form of gifts.

A permissible gift

Gifts must not be used as a means of influencing the recipient.

The value of the gift to be received or received must be appropriate and its amount shall not reach the level that affects the behavior of the recipient (such as a client).

Gifts can only be given or accepted in order to facilitate friendly relations, and gifts are not given for a specific reason or for many times. Giving gifts is a particularly sensitive issue in the public sector.

In the European Union, if the gift is worth more than 100 euros (or in the countries with weaker purchasing power, in the local market the amount of the local currency is equal to the economic value of the 100 euro), the gift shall not be given to individuals working in the public or private sectors.

If an employee receives a gift that is worth more than 100 euros (or in a country where the purchasing power is weaker, the local market is equal to the economic value of 100 euro) in the European Union, the employee shall return the gift. If this may cause an offense, the employee shall be obtained. Approval by the managing director.

The cost of any gift or other benefits must be recorded and stated in a timely manner.

If you are uncertain about giving or receiving gifts, you should consult a line manager, a managing director or a compliance Commissioner of a group company.

The permissible gifts include symbolic gifts and interests that conform to standard social customs. In this case, the value of the gift is not the first consideration, the value is not exceeded, and the gift is not given to obtain other benefits. Gifts must be delivered to the recipient's office address instead of his home address.