Anti-Bribery and Corruption 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. That includes:

• All employees, regardless of seniority, location, or contract type
• All contractors, consultants, freelancers, and seconded personnel
• Directors and the Administrator (Tudor Brad)
• Agents, intermediaries, sales representatives, and channel partners acting in BetterQA's name
• Suppliers and sub-contractors whose conduct is attributable to BetterQA under the contracts they sign with us

The policy follows the UK Bribery Act 2010 and Romanian Law 78/2000 on preventing, detecting and sanctioning acts of corruption, including provisions on public officials, private commercial bribery, and trading in influence (trafic de influență). Where local law in another country we operate in is stricter, that stricter standard applies.

2.Our Position

BetterQA does not pay bribes, does not accept bribes, and does not tolerate corruption in any form. This applies whether the counterparty is a public official, a client procurement contact, a supplier, a competitor, a recruitment candidate, or anyone else. Our long-term position in the QA services market depends on us being chosen on merit, not on what we paid to be chosen.

3.Specific Obligations

You must:

• Refuse, and report, any offer of a bribe, kickback, or facilitation payment, regardless of the amount or local custom
• Decline to give or receive any gift, hospitality, or benefit that could reasonably be seen as influencing a business decision (see the separate Gifts and Hospitality Policy for thresholds)
• Apply zero tolerance to public officials: no cash, no cash equivalents, no entertainment, no gifts of any monetary value to government employees, regulators, customs officers, tax inspectors, judges, NATO procurement staff, EU-funded programme staff, or anyone holding a public function. Working lunches at a reasonable cost during legitimate meetings are permitted; nothing else
• Refuse facilitation payments (small payments to speed up routine government action). These are illegal under the UK Bribery Act and Romanian Law 78/2000. If you are pressured to pay one, withdraw from the situation and report it
• Never use a third party (agent, distributor, introducer, lobbyist) to do something you would not be allowed to do directly. The company is liable for the conduct of anyone acting on its behalf
• Conduct proportionate due diligence before engaging any commercial agent, introducer, or high-risk supplier (see the Supplier and Third-Party Management Policy)
• Keep accurate books and records. No off-book accounts. No false invoices. No vague descriptions that hide the real purpose of a payment
• Get written approval from the Managing Director before making any political contribution, charitable donation requested by a client or public-sector counterparty, or sponsorship arrangement above EUR 500

You must not:

• Offer, give, request, or accept anything of value as an inducement for improper performance of a duty
• Promise a job, internship, or paid engagement to a relative or associate of a client or public official as a way to win or retain business
• Use personal funds, personal credit cards, or expense reclassification to disguise a payment that would not be allowed if made openly
• Discuss with a third party any pricing, candidate placement, or evaluation in exchange for a personal benefit

4.Reporting Channel

If you suspect a bribe has been offered, paid, requested, or hinted at, report it through the BetterQA whistleblowing channel:

• Email: [email protected]
• You may report anonymously. If you do, include enough detail for us to investigate
• Reports are received by the Managing Director and the legal counsel; both are bound by confidentiality
• We acknowledge every report within 7 days and provide an outcome within 90 days, in line with EU Directive 2019/1937 and Romanian Law 361/2022
• See the separate Whistleblowing Policy for full procedure, protections, and escalation routes (including direct reporting to ONPCSB and DNA where appropriate)

Retaliation against anyone who reports a suspected bribe in good faith is itself a disciplinary offence and a breach of this policy.

5.Consequences

Breach of this policy is treated as gross misconduct. Depending on the severity it may lead to:

• Disciplinary action up to and including termination of employment or contract
• Personal criminal liability under the UK Bribery Act 2010 (up to 10 years' imprisonment for individuals) and Romanian Law 78/2000
• Corporate liability for BetterQA, including unlimited fines under section 7 of the UK Bribery Act
• Recovery of any benefit obtained through the breach
• Reporting of the matter to the Romanian National Anticorruption Directorate (DNA), the UK Serious Fraud Office, or other competent authority where law requires

The company will not indemnify any individual against the personal consequences of a bribery offence.

6.Review Cadence

This policy is reviewed at least annually by the Managing Director, or sooner if there is a material change in law, in the company's operations, in the territories we work in, or following any incident. The review covers the risk register, the gifts and hospitality register, and the outcomes of any reports received through the whistleblowing channel.

7.Owner