Anti-Bribery Policy

P.D.01 – Edition 1 – 02/04/2024

SPINE ACTION applies a “zero tolerance” policy towards incidents of bribery. All employees are required to adhere to the ethical standards outlined in this Policy and the company’s Code of Conduct, and must take responsible measures to prevent any violations.

The company’s governing body is the Managing Director and Legal Representative, who demonstrates leadership and commitment to the anti-bribery management system as follows:

  1. Approves this organization’s anti-bribery policy.
  2. At predetermined intervals (through reviews), receives and reviews information regarding the content and operation of the company’s anti-bribery management system.
  3. Ensures the allocation and availability of sufficient and appropriate resources required for the effective operation of the anti-bribery management system.
  4. Exercises reasonable oversight regarding the implementation of the organization’s anti-bribery management system and its effectiveness.

Definition of Bribery

Bribery is defined as the provision or offer of any item of value or any advantage, directly or indirectly, to any person, with the intention of influencing that person or any other person to perform a function or activity in an improper manner. Additionally, bribery is also defined as the solicitation or receipt of any item of value or any advantage, directly or indirectly, by any person, with the purpose or effect of performing the relevant function or activity improperly.

Instances of Bribery

Based on its activities, the company may be involved in instances of bribery as follows:

  • Bribery in the Public and Private sectors.
  • Bribery by the company to third parties.
  • Bribery by staff acting on behalf of the company.
  • Bribery by partners acting on behalf of the company.
  • Bribery of the organization by a third party.
  • Bribery of the company’s business partners in relation to the company’s activities.
  • Direct and indirect bribery without the payment of money.

Details on how to manage and address the above are presented in the company’s Code of Conduct, which has been approved by the Management.

Anti-Bribery Management System

The company has established, documented, implemented, maintained, and continuously reviewed and, where necessary, improved its anti-bribery management system, including the required processes and their interactions, in accordance with the requirements of ISO 37001.

The anti-bribery management system includes measures aimed at identifying and assessing risk, and preventing, detecting, and addressing bribery.

Anti-Bribery and Corruption Compliance Officer

The company has appointed an anti-bribery and corruption compliance officer, who acts as an expert for the implementation and management of the company’s anti-bribery and corruption program and related compliance procedures.

Implementation

Company employees are required to strictly adhere to this Policy, the Code of Conduct, and the Procedures of the Anti-Bribery Management System.

No employee will ever be penalized, through performance evaluations, compensation, or any other method, for:

  • Refusing to offer a bribe,
  • Reporting suspected bribery, even if the report proves to be incorrect.

Similarly, professional performance will not be negatively evaluated due to delays or financial losses resulting from refusing to bribe.

Reporting Suspected Violations

If you are uncertain about how to respond to a situation or whether certain behavior may be improper or contrary to this Policy and/or the company’s Code of Conduct, you should always seek guidance from Senior Management and the Anti-Bribery and Corruption Compliance Officer before taking any action.

If you observe behavior that raises concerns or may constitute a violation of this Code of Conduct, immediately report the matter to Senior Management and the Anti-Bribery and Corruption Compliance Officer.

For SPINE ACTION

THE MANAGEMENT