Anti-corruption Policy

SEABERRY TECHNOLOGIES DOO BEOGRAD (hereinafter referred to as SEABERRY TECHNOLOGIES DOO) is committed to conducting its business transparently and in accordance with the highest ethical standards. This means that SEABERRY TECHNOLOGIES DOO business is always conducted in strict compliance with all applicable laws and regulations, including those related to security and anti-corruption, commercial bribery, money laundering and terrorist financing.
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SEABERRY TECHNOLOGIES DOO takes a zero-tolerance approach to all forms of bribery, corruption and fraud and makes every effort to address and prevent the causes and situations that may give rise to them.
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SEABERRY TECHNOLOGIES DOO expects all SEABERRY TECHNOLOGIES DOO employees and counterparties to adhere to and fully support the rules set out in this Policy and applicable regulations.

The requirements set out in this Policy apply to all SEABERRY TECHNOLOGIES DOO employees and counterparties.
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This Policy sets standards and describes the guidelines that SEABERRY TECHNOLOGIES DOO employees and contractors must follow when conducting business to counter corruption and commercial bribery.

Accounting records are accounts, books and journals, invoices, correspondence, papers and other documents that record and reflect the business, transactions and other activities of SEABERRY TECHNOLOGIES DOO in written or any other form (including electronic).
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Bribe - receipt by an official, a foreign official, or an official of a public international organization personally, or through an intermediary of money, securities, other property, or in the form of illegal provision of property services, granting other property rights (including when the bribe is transferred to another individual or legal entity on the instructions of the official) for the performance of actions (inaction) in favor of the bribe-giver or persons represented by him/her, if the said actions (inaction) are within the official duties of the bribe-giver or other persons represented by the bribe-giver.
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External Interest - additional income, third-party business or arrangements to provide services to external parties, in accordance with the Conflict of Interest Policy.
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Extortion - a demand to transfer another person's property or right to property or to perform other actions of a property nature under the threat of violence, destruction or damage to another person's property, as well as under the threat of dissemination of information dishonoring the citizen or his/her relatives, or other information that may cause substantial harm to the rights or legitimate interests of the citizen or his/her relatives.
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Business hospitality - various expenses associated with the reception and servicing of representatives of other organizations for the purpose of establishing and maintaining cooperation.
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Commercial bribery - illegal transfer of money, securities, other property to a person performing managerial functions in a commercial or other organization, as well as the illegal rendering of property services, granting of other property rights (including when property is transferred, property services are rendered, or property rights are granted to another individual or legal entity at the direction of such a person) for the performance of actions (inaction) in the interests of the giver or other persons, if the specified actionsCommercial Sponsorship - providing financial or in-kind support to an event, person or organization in exchange for the opportunity to promote that organization's brand and/or personnel or access to services, an event, or other marketing opportunities.
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The Ethics and Compliance Committee - a permanent collegial body and an integral part of SEABERRY TECHNOLOGIES DOO corporate culture that performs functions to ensure compliance with the rules of business conduct, ethics, compliance and anti-corruption standards.
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Counterparty - any person interacting with or acting for and/or on behalf of SEABERRY TECHNOLOGIES DOO, including customers, clients, contractors, suppliers, consultants, advisors, distributors, agents, commercials and other intermediaries.
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Conflict of Interest - any situation in which an employee or a close relative of an employee has an outside interest that could affect the objective performance of his or her job duties for SEABERRY TECHNOLOGIES DOO, regardless of whether the interest affected their performance.
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Corruption - abuse of official position, giving a bribe, receiving a bribe, abuse of authority, commercial bribery or other unlawful use by an individual of his or her official position contrary to the legitimate interests of society and the state in order to obtain a benefit in the form of money, valuables, other property or services of a property nature, other property rights for himself or herself or for third parties, or unlawful provision of such a benefit to the said person by other individuals, including the commission of such acts on behalf of or in the name of a third party.
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Lobbying - any individual or collective actions to influence decisions made by authorities, officials, legislators, or other authorized bodies.
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Fraud - theft of another's property, or acquisition of the right to another's property by deception or abuse of trust.
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Negative Acts - any willful act of misrepresentation to obtain an unfair or unlawful business or personal advantage, abuse of position or power, willful and wrongful waste or destruction of property or resources, any direct or indirect offer, promise, grant, request, consent to receive, acceptance or receipt of any payment, gift, or other valuable advantage, improper performance of one's duties.
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Political Contributions - any monetary or non-monetary contributions, such as resources and funds, to support political parties, candidates or campaigns.
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Provocation of bribe, commercial bribery, or bribery in the sphere of procurement of goods, works, services to ensure state or municipal needs - an attempt to transfer to an official, foreign official, official of a public international organization, a person performing managerial functions in commercial or other organizations, without his consent, money, securities, other property or rendering to him services of a proprietary nature, provision of other proprietary rights, in order to artificially create evidence of a committed crime.
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Manager - an employee employed by SEABERRY TECHNOLOGIES DOO on a permanent or temporary basis who is responsible for management and strategic decision-making in the division, service, department, or directorate he or she heads.
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Employee - any employee employed by SEABERRY TECHNOLOGIES DOO on a permanent or temporary basis.
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Facilitation payments - any payment to a public official made to expedite or secure the performance of a typical action of the authorities (e.g., processing a visa or issuing a customs invoice or permit) that is not expressly provided for by law.
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A public official is any Serbian or foreign person, appointed or elected, holding any position in a legislative, executive, administrative, law enforcement, judicial body or international organization; any person performing any public function for the state, including for a state body, institution or enterprise; leading political figures, officials of political parties, including candidates for political office, ambassadors, heads and employees of state bodies, institutions and enterprises:
- an employee or official of state and/or local authorities, including but not limited to educational, medical and military institutions, law enforcement and customs agencies, tax and migration services, organizations issuing state licenses, sanctions and permits;
- an employee or officer of a company, business, agency or legal entity that is wholly or partially owned or controlled by the government;
- other persons holding legislative, administrative, military or judicial office of any kind.
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Tangible or intangible assets applicable to this Policy are:
- money expressed in any form, including crypto-assets;
- gifts, discounts on goods not available to ordinary customers;
- entertainment or hospitality expenses, travel, lodging;
- job offers (including to relatives) and promises of future employment;
- personal favors;
- political contributions and charitable donations;
- commercial sponsorship and/or any other benefits or advantages (financial or not).

The purpose of this Policy is to prevent any action that may entail risks of involvement of SEABERRY TECHNOLOGIES DOO employees and counterparties, through relationships with SEABERRY TECHNOLOGIES DOO and/or SEABERRY TECHNOLOGIES DOO employees, in illegal activities related to corruption and commercial bribery.

The objectives to achieve the purpose of this Policy are:
- developing a uniform understanding among SEABERRY TECHNOLOGIES DOO employees of the rejection of corruption in any form or manifestation;
- minimizing the risk of involvement of SEABERRY TECHNOLOGIES DOO employees and contractors in corrupt activities;
- monitoring the effectiveness of the measures taken in this Policy;
- establishing the obligation of SEABERRY TECHNOLOGIES DOO employees to follow the requirements of this Policy;
- ensuring liability for corruption offenses in all cases expressly provided for by regulatory legal acts.

The Policy is developed in accordance with the legislation "On Combating Corruption" 35/2019-6, 88/2019-3, 11/2021-3, 94/2021-3, 14/2022-47, the Criminal Code of Serbia, as well as the International Standard ISO 37001 "Anti-corruption Management Systems - Requirements and Guidelines for Application".
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Compliance with the principles, rules and requirements of the Anti-corruption Policy is an element of SEABERRY TECHNOLOGIES DOO corporate culture.

SEABERRY TECHNOLOGIES DOO anti-corruption framework is based on the following key principles:
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Principle of compliance with legislation. Compliance of implemented anti-corruption measures with the Constitution of Serbia, international treaties concluded by Serbia, legislation of Serbia and the European Union, and other legal acts applicable to the organization.
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The principle of personal example. The key role of SEABERRY TECHNOLOGIES DOO managers of all levels to build a culture of intolerance to corruption and commercial bribery.
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Principle of engagement. At SEABERRY TECHNOLOGIES DOO, employees are regularly informed about the provisions of anti-corruption legislation.
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Principle of proportionality. SEABERRY TECHNOLOGIES DOO has developed and implements a set of measures to reduce the likelihood of employees and counterparties becoming involved in corrupt activities.
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Efficiency principle. SEABERRY TECHNOLOGIES DOO uses anti-corruption measures that are low-cost, easy to implement, and have a meaningful impact.
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The principle of inevitability. Inevitability of punishment for SEABERRY TECHNOLOGIES DOO employees, regardless of their position, length of service and other conditions, in case they commit corruption offenses in connection with the performance of their employment duties.
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Principle of control and monitoring. SEABERRY TECHNOLOGIES DOO monitors corruption and commercial bribery prevention measures, controls compliance with them, and, if necessary, revises and improves them.

Employees
SEABERRY TECHNOLOGIES DOO employees need to be honest, ethical and responsible, and expect the same from others.
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As part of job responsibilities, notify counterparties of the requirements of this Policy, the Conflict of Interest Policy and the Counterparty Due Diligence Policy.
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If there are any questions, concerns or when learning of any known or suspected violations of this Policy, inform SEABERRY TECHNOLOGIES DOO management in accordance with the Violation Reporting Policy.
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Managers
Managers need to ensure that employees and counterparties follow the requirements and instructions set out in this Policy and ensure that employees are trained in the requirements of this Policy.
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Security and Compliance
The Head of Security and Compliance is responsible for implementing the requirements of this Policy.
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This Policy and other documents designed to implement it shall be reviewed and updated annually.
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Anti-corruption and commercial bribery training and education for all employees shall be organized upon hiring and at least once a year.
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The CEO of SEABERRY TECHNOLOGIES DOO shall be promptly informed of any actual or suspected violations of this Policy or any laws or regulations related to anti-corruption and commercial bribery.
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The Head of Security and Compliance shall advise employees and counterparties on compliance with this Policy and related regulations.

Prohibition of bribery
Corruption and commercial bribery can take many forms: they can be obvious, such as a monetary bribe, or more covert, such as job offers, commission payments, excessive gifts or hospitality. To ensure compliance with legal requirements and this Policy, the following rules and guidelines have been developed and must be observed by all employees and counterparties.
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As part of anti-corruption activities, employees and counterparties are prohibited from:
- make, support, offer or authorize, promise, request, agree to receive, approve and/or obtain any payment, financial or non-financial benefit (directly or indirectly);
- directly or indirectly (including through intermediaries) promise, pay, gift, transfer, offer, or provide tangible or intangible assets in any form to public officials for reasons not expressly authorized by law;
- to transfer directly or indirectly, including through third parties, any tangible or intangible values to children, spouses, other close relatives of a public official or related persons, or any other person to whom the public official has entrusted such transfer for purposes not expressly provided for by law;
- to make incentive payments or disbursements of any kind, unless such payment is required to avoid risk to life or personal injury.
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Certain administrative or expedited review fees are permissible and will not be considered incentive payments, provided they are authorized or specifically required under applicable law. However, payments that are made in accordance with common practice or cultural traditions in conflict with established law are unacceptable.
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The above prohibitions apply regardless of whether SEABERRY TECHNOLOGIES DOO funds are used to offer or receive a bribe, and regardless of whether they are promised, given or offered, directly or indirectly, through third parties.
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SEABERRY TECHNOLOGIES DOO employees and contractors must always exercise caution when dealing with public officials.
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In all cases where the transfer of tangible or intangible assets or the making of a payment to government officials is contemplated, even if expressly provided for by law, prior written authorization must be obtained from the Head of Security and Compliance and all information regarding such actions must be properly retained.
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Upon receiving a request or demand for a bribe, an SEABERRY TECHNOLOGIES DOO employee or counterparty must:
- refuse to pay or provide a bribe and explain that under no circumstances does SEABERRY TECHNOLOGIES DOO make such payments or provide improper advantages because they are contrary to the provisions of applicable law;
- make it clear that such refusal is final;
- not use non-verbal means of communication, including gestures and postures, or give any hints implying mutual understanding regarding actions that are not in compliance with this Policy;
- alert the immediate supervisor and the Head of Security and Compliance (the counterparty should alert the contact person at SEABERRY TECHNOLOGIES DOO, who will be required to inform the Head of Security and Compliance).
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Counterparties or persons representing SEABERRY TECHNOLOGIES DOO must be notified that they are not authorized to make payments or provide any other benefits on behalf of SEABERRY TECHNOLOGIES DOO.Counterparties or persons representing SEABERRY TECHNOLOGIES DOO's interests should be aware that the relationship with them will be terminated if such payment is made by them.
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Unacceptability of fraud
Fraud can take many forms: for example, falsifying invoices and other financial documents, financial statements or accounting records, as well as information on inventories, resources, expenses, making false statements and committing fraudulent transactions.
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As part of anti-fraud efforts, employees and counterparties should:
- not participate in any fraudulent activity (directly or indirectly) or otherwise contribute to any fraud;
- safeguard the property of SEABERRY TECHNOLOGIES DOO and use it with good faith and care;
- know and comply with work-related procedures that are designed to reduce the risk of fraud occurring.Expenses, gifts and donations
All expenses (including hospitality and entertainment), gifts and donations must meet the following criteria:
- are for legitimate business purposes directly related to SEABERRY TECHNOLOGIES DOO's business;
- conform to industry norms in nature and value, at the point of giving or receiving them, and are reasonable and appropriate;
- are unacceptable if they could be construed as a bribe or commercial bribery;
- must not put an SEABERRY TECHNOLOGIES DOO employee or counterparty in an uncertain or difficult position;
- must not be used to improperly influence, or attempt to influence, with the intent to improperly obtain or retain any advantage;
- must not give rise to any form of conflict of interest;
- must not be offered to and accepted from a person or organization with a reputation for dishonest, unethical or illegal behavior;
- must not be offered and accepted by any party with whom SEABERRY TECHNOLOGIES DOO is engaged in public bidding or tender procedures;
- shall not be continuous or recurring;
- must not violate applicable local laws, policies, rules or regulations;
- must be agreed in advance in writing by the line manager before being implemented and must not exceed the value authorized by local law or an equivalent amount in another currency;
- must be supported by receipts, checks and timely and fully recorded in the appropriate SEABERRY TECHNOLOGIES DOO accounting records in accordance with applicable legal and accounting requirements.
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Gifts should never be made in cash or its equivalent (gift cards, certificates, electronic funds, etc.).
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All expenditures related to state employees must be approved regardless of cost.
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Any gifts or hospitality offered to public officials (if permitted by applicable law) must, regardless of their value, be subject to prior written approval by the Head of Security and Compliance.
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Items of small value intended for promotional purposes (where the SEABERRY TECHNOLOGIES DOO logo is present) are not considered gifts and may be given to government officials or contractors without prior approval, provided they are for legitimate business purposes and are properly recorded in SEABERRY TECHNOLOGIES DOO's accounting records.
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Political contributions, lobbying, commercial sponsorship and commission payments
Any political activity conducted for personal purposes and in a personal capacity must be conducted separately from SEABERRY TECHNOLOGIES DOO. Such activities must not create a conflict of interest. Making political contributions or engaging in lobbying for personal purposes on behalf of SEABERRY TECHNOLOGIES DOO is prohibited.
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Any commercial sponsorship, political contributions or commission payments on behalf of SEABERRY TECHNOLOGIES DOO must be formalized in an enforceable agreement and reflected in the appropriate accounting records.
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Charitable donations may only be made to registered charities and must be appropriately recorded in SEABERRY TECHNOLOGIES DOO's accounting records.
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Commercial sponsorships, political contributions, commission payments or charitable donations on behalf of SEABERRY TECHNOLOGIES DOO must have the prior written approval of the Head of Security and Compliance, regardless of their size.
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Conflict of Interest
In order to ensure maximum integrity in the conduct of SEABERRY TECHNOLOGIES DOO's business and in view of the expansion of SEABERRY TECHNOLOGIES DOO's business (including the acquisition of new entities), each employee and counterparty must promptly and fully declare the existence of a potential conflict of interest when it arises, or when they become aware of its actual or possible existence.
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If there is a conflict of interest, the necessary measures are taken to manage or eliminate it. All conflicts of interest are dealt with on an individual basis.
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Books and records
SEABERRY TECHNOLOGIES DOO employees and counterparties are required to follow established accounting and reporting procedures to accurately reflect each transaction and maintain a system of internal accounting controls and to keep records in the books and records.
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All transactions and payments (including gifts) must be properly, faithfully and accurately recorded in the accounting records and in all source documents, including invoices, receipts and expense documents.
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Reporting Violations
Any employee who knows or suspects a violation of this Policy, or an event or circumstance that suggests that another employee or counterparty has violated the laws on corruption and commercial bribery, is required to communicate that information in accordance with the Violation Reporting Policy.
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Critical to SEABERRY TECHNOLOGIES DOO's ability to prevent anti-corruption and anti-fraud violations depends on how employees uphold ethical principles and business reputation and respond to violations.
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SEABERRY TECHNOLOGIES DOO management will fully support any employees or counterparties who conduct their business in accordance with this Policy.

All employees and contractors of SEABERRY TECHNOLOGIES DOO are responsible for compliance with this Policy and other documents designed to implement it. Failure to comply with this Policy will be grounds for disciplinary action, up to and including dismissal or termination of the business relationship.
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In case of receiving information about any violations of this Policy, as well as an event or circumstance indicating a violation of anti-corruption, commercial bribery or fraud laws, SEABERRY TECHNOLOGIES DOO will initiate a compliance audit, involving, if necessary, law enforcement agencies and other competent persons.