Anti-corruption Policy

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Anti-Corruption Policy

1. About This Policy

It is the Crocus Medical policy to conduct all of our work and to render all our services in an honest and ethical way.

We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships and in the promotion of Crocus Medical vision and goals.

Any Crocus Medical employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct.

Any non-employee who breaches this policy (or we have reasonable suspicion to believe this is the case) may have their contract terminated with immediate effect.

This policy forms the specially developed amendment to every Crocus Medical employee’s contract of employment.

2. Who Must Comply With This Policy?

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, any vendors and business partners.

3. Key Principles of the Policy

The Managing Director, members of the Management Board and top officials of Crocus Medical should form an ethical standard of non-acceptance of any forms of corruption at all levels, making their own behavior an example to others.

The Crocus Medical shall adopt the principle of non-acceptance of corruption in any form (the “zero tolerance” principle) in the course of its day-to-day activities and while implementing any projects or services, including in the course of interacting with the shareholders, investors, counterparties, representatives of governmental bodies and local authorities, political parties, its employees, members of their governance bodies, their employees, and other persons.

The Crocus Medical shall identify and, from time to time, update the corruption risk indicators typical of its operation and of the potentially vulnerable business processes.

The Crocus Medical shall develop and implement adequate procedures to prevent corruption that reasonably address the risks identified, and ensure compliance with these procedures.

The Crocus Medical shall take reasonable efforts to minimize the risk of business relations with counterparties that may be involved in corruption activities. For this purpose, the Corporation shall evaluate the counterparty’s tolerance to bribery, including checking if they have their own anti corruption policies and procedures, their willingness to comply with the requirements of this Policy and to include anti corruption clauses into contracts, and to mutually facilitate ethical business and prevention of corruption.

Crocus Medical shall place this policy on the corporate Internet site for public access, it shall openly declare its non-acceptance of corruption, welcome and encourage compliance with the principles and requirements of this Policy.

4. What is Bribery?

Bribery means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.

Bribery includes offering, promising, giving, accepting or seeking a bribe.
All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with the manager at

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; or
c. give or offer any payment (sometimes called a facilitation or/and administrative payment) to a government official in any country to facilitate or speed up a routine or necessary procedure;
d. 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. Gifts and Hospitality

This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining Crocus Medical image or reputation, or promoting its global goals.
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).

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 the name of Crocus Medical – not your own name.

Promotional gifts of low value may be given to our existing suppliers and business partners and we can accept equivalent gifts from them.

6. Record-Keeping

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 our expenses policy and record the reason for expenditure.
All accounts, invoices, and other records relating to dealings with third parties including suppliers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

7. How to Raise a Concern

If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify Crocus Medical management on as soon as possible.