To ensure that business is conducted ethically within the Martin & Servera Group, and that the giving and receiving of bribes does not occur. The policy covers and applies to all managers and employees within the Martin & Servera Group in their interactions with customers, suppliers, and other business partners. This also includes consultants and temporary staff.
Introduction
A key part of our operations is building and maintaining relationships with customers, suppliers, and other business partners. A mistake could lead to inappropriate and, in the worst case, illegal actions. The penalties for violating anti-bribery legislation vary depending on the nature of the offence. Sanctions typically involve fines, but serious offences can result in imprisonment for up to six years. It is usual for both the employee and the company to be convicted. In the event of a breach of this policy or related documents, employees may face dismissal.
The Martin & Servera Group is committed to conducting business fairly, and it must be clear to all employees what is expected. It is of the utmost importance that we handle this correctly in our relationships with our customers, suppliers, and business partners.
Martin & Servera complies with Swedish legislation as outlined in the Code to prevent corruption in business.
Risk analysis
The risk of corruption is highest in our relationships with customers, suppliers, and business partners. Martin & Servera has identified the following functions within the Group as the most vulnerable: sales, purchasing, logistics, marketing, and IT.
Companies' responsibility to prevent corruption
To ensure compliance with the policy, companies within the Group must:
- Identify risk roles within their respective company.
- Ensure that persons in risk roles are informed of and kept continuously up-to-date concerning the policy, procedures and guidelines and the content of such. Training must be conducted and confirmed.
- Ensure that all managers and employees have information on and access to the Group's whistleblowing service.
Definition of risk role
Any person who, in their role, is responsible for and authorised to either purchase or sell goods and/or services is considered to hold a so-called risk role. Because of their role, this person risks ending up in situations where they have the opportunity to either give or receive bribes and/or other undue advantages. It is always the role that determines whether a person is considered to be in a risk role and not their character. Persons who hold risk roles are required to complete the 'Anti-Corruption' training and confirm that they have read and understood the content of the Martin & Servera Group's anti-corruption policy. Training is repeated and confirmed.
The following categories of persons are defined as risk roles within the Martin & Servera Group:
- Persons who enter into agreements with customers, suppliers, and business partners.
- Persons who do not sign contracts but who have the opportunity, in their role, to treat customers, suppliers, and business partners in an advantageous manner. For example, through support on a tender, sponsorship, purchase/sale of goods/services, etc.
- Managers whose direct reports hold the roles indicated above
- All roles within Company and Group Management
