1.1. SCOPE AND PURPOSE

Compliance with all the applicable laws and regulations, inclusively the legal provisions regarding combating corruption, as well as observing the highest professional, moral and ethical standards are a key value for Rozoti Prodcom SRL.

Rozoti Prodcom SRL undertakes to comply with the law and the highest ethical standards and not to tolerate corruption in any form. We expect Rozoti Prodcom SRL employees to act at all times according to law and to the generally accepted ethical and moral standards.

1.2. AREA OF APPLICABILITY

The anticorruption policy applies to all the Rozoti Prodcom SRL employees, as well as to third parties that represent or act in the name of the company, irrespective of their quality: subcontractors, agents, as well as business partners.

Any corruption, bribery, deed

– blackmail and embezzlement is prohibited.

In fact, any person working in the name or for Rozoti Prodcom SRL shall not give or accept bribes, shall not engage in activities liable to act as incentives for business partners or public authorities.

1.3. UNDERSTANDING THE POLICY

In the meaning of this policy, the notion of “corruption” refers to the deeds described in Title V – “Corruption and job-related crimes” in the Penal Code, the ones described in the Law no. 78/2000 on preventing, discovering and sanctioning corruption deeds, as well as any other corruptions deeds, described as such in special penal laws or in penal laws that contain penal dispositions. The provisions of the Law no. 78/2000 are applicable to persons that fulfill, permanently or temporarily, a function or an assignment, to the extent they take part in decision making or may influence decisions, within public services, state companies, trading companies, national companies, national firms or other economic operators.

Without being a comprehensive listing, according to the Penal Code, the main deeds and practices considered to be corruption deeds are:

Giving and taking bribes – promising, offering or giving, as well as asking or receiving money or other undue benefits, directly or indirectly, for oneself or for another, in relation to performing, failing to perform, expediting or delaying the performance of an act that is within the job-related duties or in relation to performing an act contravening to such duties

Influence peddling and influence buying – asking, receiving or accepting the promise, as well as promising, offering or giving money or other undue benefits, directly or indirectly, for oneself or for another, to a person that has influence, or makes believe they have influence over a civil servant or a person in the private sector, in order to determine the latter to fulfill, to fail to fulfill, to expedite or delay fulfillment of an act that is within their job-related duties, or to fulfill an act contravening to such duties

Advantages may be financial or non-financial in character and may include:

• Money;
• Loans (in advantageous or preferential conditions);
• Donations (inclusively charitable donations);
• Employment contracts;
• Consultancy contracts;
• Preferential treatment;
• Confidential information;
• Gifts and hospitality;
• Holidays;
• Any other advantage or benefit with a property value, or which is perceived as valuable to the recipient or another person (for ex., a relative or a friend of the recipient).

There is no difference between bribery and facilitating an activity, which is also prohibited. Facilitating an activity consists of a small sum offered to a low rank civil servant, in order to facilitate or expedite an activity, which is a job-related obligation for the latter. The attempt to bribery may be performed both in the private sector and in the public sector. Rozoti Prodcom SRL forbids taking/giving bribes and facilitating an activity.

Rozoti Prodcom SRL forbids its employees and collaborators to offer, promise, authorize or accept and request, directly or indirectly, any payment, gift or any valuable, for the purpose of obtaining undue benefits normally.

2.1. BASIC RULES AND PRINCIPLES

Employees/collaborators are forbidden to bribe or use agents (agents, consultants, distributors) for the purpose of obtaining undue benefits by means of bribery.

Rozoti Prodcom SRL makes no difference between public representatives and persons from the private sector as regards offering/receiving bribes; bribery, as defined in this policy, is not accepted in any of its forms, to any person, notwithstanding their status. It is always required to review the act of offering or promising any valuables, to any person, if such action could be considered unlawful. If the answer to such review is YES, no such action should be performed.

If you have any doubts regarding this topic, you can obtain information from the Legal Department of Rozoti Prodcom SRL, always before the occurrence of the event. Bribery may take various forms, from cash to valuable products/ services, etc.

2.2. FACILITATION PAYMENTS

Rozoti Prodcom SRL forbids any facilitation payments, these being considered another form of bribery. Such payments are informal, improper – not necessarily of large amounts – and facilitate obtaining results using a short cut instead of the legitimate way. Such facilitation payments have as their main purpose to reduce the response and action time on part of the governmental bodies or private sector bodies.

2.3. PROSPECTING NEW BUSINESSES

Before initiating new business opportunities, a review of the business partner/partners is to be made based on the integrity and requirements regarding this policy.

3.1. OBLIGATIONS AND SANCTIONS

Employees should get familiar with the concepts and rules described in this procedure, which is to be the object of a separate discussion topic, in the annual training courses regarding compliance matters.

The failure to comply with this policy shall not be tolerated and may lead to disciplinary investigation up to termination of the employment contract or of the collaboration contract.

3.2. RESPONSIBILITIES AND IMPLEMENTATION

Each Director or team leader within Rozoti Prodcom SRL is responsible with the distribution of this policy and guiding their team for the purpose of understanding the matters described and the entire managerial team to lead by example, in all the situations, and requests all its employees and collaborators to comply with the anti-bribery and anticorruption principles and rules.

This procedure is applicable to all the Rozoti Prodcom SRL employees, being implemented, monitored and enforced continuously.

3.3. REPORTING THE VIOLATIONS OF THIS POLICY

The Rozoti Prodcom SRL employees, as well as its business associates, who know, or are certain that violations of this policy took place, should report them by following the channels below:

• The electronic address of the company: office@rozoti.ro
• Website: https://rozoti-spedition.ro/
• Office: Oradea 410603, str. Petre P. Carp nr. 7 , judetul Bihor

Any report shall be treated with maximum confidentiality and there will be no actions against the complainant, as a consequence of reporting, the complainant being protected.

Further, any reporting should be performed in good faith, concerning real deeds and actions, based on the objective judgment of the reporting person.

Revised on 2021.04.07