Gifts and Hospitality Policy

1.Scope

This policy applies to every person acting on behalf of Better Quality Assurance S.R.L. ("BetterQA," "the company"), in every country we operate in: employees, contractors, freelancers, directors, the Administrator (Tudor Brad), agents, and any partner who deals with clients, suppliers, or public officials in BetterQA's name. It governs gifts and hospitality given by BetterQA, and gifts and hospitality received by BetterQA staff.

2.Our Position

Reasonable, occasional, low-value business hospitality is a normal part of working with clients and partners. We do not want to ban it; we want to make sure it does not become a way for someone to buy or sell a business decision. The rules below exist so that hospitality is always something we'd be comfortable describing in writing to a regulator, a client procurement team, or an auditor.

3.Specific Obligations

Gifts and hospitality you can give or receive without pre-approval (still log if above EUR 100):

• Branded promotional items of nominal value (notebooks, pens, t-shirts)
• Reasonable working meals during a legitimate business meeting
• Conference attendance fees and refreshments provided to all attendees
• Modest seasonal gifts (a bottle of wine, a box of chocolates) outside any active negotiation

Gifts and hospitality requiring written Managing Director approval before being given or accepted:

• Anything with an estimated value above EUR 100 per person per occasion
• Any travel, accommodation, or event ticket offered by a counterparty
• Any gift or hospitality to or from a public official (this is normally prohibited - see Anti-Bribery and Corruption Policy)
• Any gift to a counterparty's family member or close personal associate
• Any gift or hospitality during an active sales pursuit, contract negotiation, audit, certification process, or tender evaluation. Even a working lunch needs approval in that period
• Any gift in cash or cash equivalent (gift cards, vouchers, cryptocurrency) - approval will almost always be refused

Hard prohibitions, no approval available:

• Cash or cash equivalents given or accepted in any amount
• Gifts or hospitality to public officials in violation of the Anti-Bribery and Corruption Policy
• Hospitality that is plainly disproportionate to the occasion (luxury travel, weekends away, expensive entertainment with no business content)
• Adult entertainment in any form
• Gifts or hospitality offered or accepted "on condition" - explicitly or implicitly - of a decision being made a particular way

The register. The Gifts and Hospitality Register is maintained by the Managing Director. Entries include: date, counterparty, individual recipient or giver, description, estimated value, business reason, and approval status. The register is reviewed at each annual policy review and is available to BetterQA's external auditors and to clients on request as part of compliance due diligence.

If you are unsure whether something falls inside or outside the rules, ask the Managing Director before accepting or giving it. The cost of declining is low. The cost of getting it wrong is not.

4.Reporting Channel

If you witness gifts or hospitality that look inappropriate, or if you receive an offer that feels coercive, report it.

• Email: [email protected] (anonymous reporting permitted)
• Acknowledgement within 7 days, outcome within 90 days, in line with EU Directive 2019/1937 and Romanian Law 361/2022
• See the separate Whistleblowing Policy for full procedure and protections

5.Consequences

Breach of this policy is treated as misconduct. Depending on the severity:

• Disciplinary action up to and including termination of employment or contract
• Personal criminal liability where the gift or hospitality constitutes a bribe under the UK Bribery Act 2010 or Romanian Law 78/2000
• The relevant gift, or its equivalent value, must be returned, donated, or surrendered to the company
• The matter is recorded in the register with a note explaining the breach and the corrective action

6.Review Cadence

This policy is reviewed at least annually by the Managing Director. The annual review includes a sample audit of register entries, an assessment of whether the EUR 100 receipt threshold remains appropriate, and a review of any borderline cases from the previous year.

7.Owner