BIOPROB LTD · UIC 208386774
Anti-Bribery Policy
Version 1.0 · Published 31 October 2026 · Policy owner: Management
1. Purpose and scope
BIOPROB LTD has zero tolerance for bribery and corruption. This policy applies to directors, employees and anyone acting for or on behalf of BIOPROB, including agents, brokers, consultants and other intermediaries. It covers public and private sector dealings in every market in which we operate.
2. Prohibited conduct
No person may offer, promise, give, request or accept money or any other benefit to improperly influence a decision, reward improper conduct or obtain an unfair business advantage. This includes kickbacks, concealed commissions and benefits provided through relatives or third parties. No commercial target justifies a breach.
3. Gifts, hospitality and conflicts of interest
Gifts and hospitality must be lawful, modest, infrequent, transparent and connected to a legitimate business purpose. They must never influence, or appear intended to influence, a pending decision. Cash and cash equivalents are prohibited. Obtain written management approval before offering or accepting gifts or hospitality and record the recipient, purpose and value. Disclose personal or financial interests that could affect impartial decisions.
4. Public officials and facilitation payments
Unofficial payments to secure or speed up routine actions, including customs clearance, inspections, permits and port formalities, are prohibited. Legitimate published fees may be paid only through authorised channels against supporting documents. If an immediate threat to personal safety arises, prioritise safety and report the incident and any payment as soon as safe; record it accurately.
5. Business partners and payments
Before engaging intermediaries, assess their identity, ownership, reputation, public-official connections and the commercial reason for their services, in proportion to the risk. Use written agreements with clear services and fees, require compliance with this policy and verify that services were delivered. Payments must be approved, commercially reasonable and made to the contracted party. Unusual cash requests, unrelated accounts, excessive commissions or opaque ownership must be escalated before proceeding.
6. Donations, sponsorship and records
Company funds must not be used for political contributions. Charitable donations and sponsorship require prior written management approval, recipient checks and a legitimate documented purpose; they must never disguise a bribe. Maintain complete and accurate contracts, invoices, approvals and accounting records. False descriptions, off-book funds and concealed payments are prohibited.
7. Reporting concerns and protection
Report suspected bribery, requests for improper payments or concerns about this policy promptly to management or at ops@bioprob.com, using the subject “Confidential — Anti-Bribery”. This is the company’s existing business mailbox, not a separate anonymous reporting service. Information will be restricted as far as practicable to those who need it for review and action, subject to legal obligations. BIOPROB prohibits retaliation against anyone raising a concern honestly or refusing a bribe, even if business is lost. Nothing in this policy prevents reporting to a competent authority.
8. Responsibility, review and consequences
Management is responsible for implementing this policy, communicating requirements, providing risk-appropriate guidance and reviewing it at least annually and after significant incidents or changes. Concerns must be assessed promptly and impartially, with an independent reviewer where a conflict exists. Breaches may lead to disciplinary action, termination of business relationships and referral to competent authorities, as appropriate and subject to applicable law. BIOPROB requires compliance with applicable Bulgarian anti-bribery law and other laws that apply to the relevant transaction.