means Cyberlands.io a business incorporated in the Republic of Estonia. Responsible Person
means Oleksandr Bodryk, a Member of the Management board.
1. Policy purposes
This Policy formalizes Cyberlands' commitment to ethical business practices in the areas of:
• Anti-Bribery and Corruption.
• Modern Slavery and Human Trafficking.
a. Open door - each and any of our employees or a vendor can submit observations, concerns or findings via [email protected]
b. Zero tolerance - we maintain zero tolerance for bribery, corruption, modern slavery, and human trafficking practices.
c. Full transparency - we outline business practices and processes of risk and provide examples in public to ensure each and any of our employees or a vendor can see unified and transparent guidance.
4. Oversight and Implementation
Company management board will count into its decisions ethical factors as an enabler to company growth and sustainable operations. The responsible person will perform annual audits to ensure company operations within principles mentioned above.
5. Areas of riskTendering and bidding exercises
All Cyberlands staff and associated persons involved with any Cyberlands-related tender exercises must take care to avoid conduct that could be perceived as offering or accepting a financial or another advantage to influence the outcome. Business development
Cyberlands does not allow the giving of (or the promise to give) gifts, hospitality or payment with the intention of influencing a decision to receive a business advantage or to provide a reward for a business advantage already given. Charitable and political donations
Cyberlands does not make any financial payments to any charitable organizations or political parties as of now. In the future Cyberlands may donate to well-known and reputable humanitarian organizations like Red Cross of Ukraine. Sponsorship
Cyberlands will not provide/request sponsorship except on basis of the approval of Management board. Corporate hospitality
Hospitality should not be given to, or received from, a third party.
6. Examples of anti-bribery and corruption misconduct:
¨ accepting/giving a cash payment to influence a decision
¨ accepting/offering gifts and hospitality which are excessive and outwith the norm of your business practice
¨ paying for, or receiving goods or services for personal gain to influence a decision, eg offering/accepting a holiday, use of holiday homes, private jets, flights etc
7. Legal definition on modern bribery and human trafficking
"Trafficking in persons shall mean the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control of another person, for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labour or services, slavery or practices similar to slavery, servitude or removal of organs."
8. Consequences for violators
Cyberlands has a zero-tolerance of acts of Slavery and human trafficking by any supplier or individual engaged by Cyberlands to carry out services, including accounting, marketing, and legal ones. Cyberlands will report all breaches of the act to the relevant authorities and will terminate all contracts with the supplier and individual with immediate effect. Cyberlands will blacklist the supplier and individual.