KAPP: ANTI-BRIBERY AND CORRUPTION POLICY
1. About this policy
1.1. This policy relates to KAPP hf. as well as all its subsidiaries and affiliate companies (collectively “KAPP” or the “company”).
1.2. It is KAPP’s policy to conduct all of the company’s business in an honest and ethical manner and in accordance with applicable laws, regulations and rules concerning anti-bribery and anti-corruption. KAPP takes a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all of the company’s business dealings and relationships.
1.3. KAPP is committed to: (a) not offering bribes or condoning the offering of bribes on KAPPi’s behalf; (b) not accepting bribes, or agreeing to them being accepted on KAPP’s behalf; (c) comply with anti-money laundering laws; (d) maintaining accurate books and records; (e) avoiding doing business with or affiliating KAPP with others who do not accept KAPP’s values and policies and who may harm KAPP’s reputation; and (f) ongoing monitoring of and auditing compliance with these principles.
1.4. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated with immediate effect. Any breach of this policy could also result in criminal liability in accordance with Iceland’s General Penal Code or other laws, whether in Iceland or abroad.
1.5. This policy may be amended at any time. It will be reviewed at least every two years, or more frequently if circumstances require.
2. Who must comply with this policy?
2.1. This policy applies to all persons working for KAPP or on KAPP’s behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
3. Who is responsible for the policy?
3.1. The board of directors shall appoint a Compliance Officer who is primarily responsible for implementing this policy. The current Compliance Officer is Robert Gislason, CFO.
3.2. The Compliance Officer has responsibility for monitoring the use and effectiveness of this policy and dealing with any queries on its interpretation.
4. What is bribery and corruption?
4.1. Bribe means a financial or other inducement or reward for, or with the intention of inducing, action which is illegal, unethical, a breach of trust or improper in any way, wherever in the world it occurs. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit. Bribes can include payments or inducements not only to the person taking such improper action, but also to any person who claims to be able to have an influence on the person taking such action.
4.2. Bribery includes offering, promising, giving, accepting or seeking a bribe.
4.3. Corruption is the abuse of entrusted power or position for private gain.
4.4. All forms of bribery and corruption are strictly prohibited. If you are unsure about whether a particular act constitutes bribery or corruption, raise it with your manager or the Compliance Officer.
4.5. Specifically, you must not: (a) give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received; (b) accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else; (c) give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure.
4.6. You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.
5. Anti-money laundering
5.1. Money laundering is the process by which criminals attempt to conceal the true origin and ownership of the proceeds of their criminal activity and reintroduce the proceeds into the economy for legitimate purposes. KAPP must not enable any organisation or individual to use KAPP to launder money and must ensure that KAPP does not accept the proceeds of a crime from any organization or individual.
5.2 Specifically, you may not: (a) accept, make use of or acquire, or conceal, convert or transfer criminal property or its proceeds; (b) become involved in an arrangement facilitating any of the above; or (c) possess or in any way deal with funds related to terrorist activities or funds likely to be used for terrorist activities.
6. Gifts and hospitality
6.1. This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining KAPPi’s image or reputation, or marketing KAPPi’s products and services.
6.2. A gift or hospitality will not be appropriate if it is unduly lavish or extravagant or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).
6.3. Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers) or be given in secret. Gifts must be given in KAPP’s name, not your name.
6.4. Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.
6.5. This policy does not prohibit the giving or receiving of reasonable samples by KAPP for the purposes of introducing or marketing products to potential customers or business partners.
7.1. You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with KAPP’s expenses policy and record the reason for expenditure.
7.2. All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept "off-book" to facilitate or conceal improper payments.
8. How to raise a concern
8.1. Any person that is offered a bribe, or is asked to make one, or if any person suspects that any bribery, corruption or other breach of this policy has occurred or may occur, must notify their manager or the Compliance Officer as soon as possible. This policy has been prepared in Icelandic and English, both of which are equally valid. This policy was adopted by KAPP on 6th. Februar 2023, becoming effective immediately