Code of Conduct & Anti-Bribery (ABAC) Policy
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This page summarises our ABAC policy; it is not the full internal policy.
1. Our commitment
Smart One Holding Limited (Malta, C 112842) and its group companies ("SmartOne", "we") maintain a zero-tolerance approach to bribery and corruption. We prohibit bribery, kickbacks, facilitation payments, and any improper advantage, whether offered, given, solicited or accepted. We comply with the anti-corruption provisions of the Criminal Code of Malta (Chapter 9) and, where applicable to our activities, with the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act, and we support the principles of the OECD Anti-Bribery Convention.
2. Scope
This policy applies to all directors, officers, employees, contractors, agents, consultants and business partners acting for or on behalf of SmartOne, in all countries in which we do business.
3. Gifts and hospitality
Modest gifts and business hospitality are permitted only where lawful, transparent, infrequent, proportionate, and given without intention to influence a business decision. As a general guide, any single gift should not exceed €50 (or local equivalent). No gift, hospitality or thing of value of any amount may be offered to a public official, government employee or political figure where prohibited by applicable law; in such cases a zero-value threshold applies. Anything above the guideline requires prior approval and must be recorded.
4. Political contributions and facilitation payments
Corporate political contributions are prohibited unless expressly authorised in writing by the Board and lawful in the relevant jurisdiction. Facilitation payments – small unofficial payments to secure or expedite a routine governmental action – are prohibited without exception, even where customary locally.
5. Agents, intermediaries and third parties
We engage agents, distributors, resellers and intermediaries only after risk-based due diligence, including screening for politically exposed persons (PEPs) and against applicable sanctions and export-control lists. All such engagements must be governed by a written contract containing anti-corruption representations, audit rights and termination rights, and are subject to ongoing monitoring and periodic re-screening.
6. High-risk sectors and counterparties
Because we provide technology to government programmes and to customers in regulated and higher-risk sectors, we apply enhanced due diligence to such counterparties, transactions and jurisdictions, and we decline business that cannot be conducted lawfully and transparently.
7. Books, records and controls
All transactions must be accurately recorded. We maintain internal financial controls designed to prevent and detect bribery, corruption and the misrecording of payments.
8. Reporting and whistleblower protection
Concerns about actual or suspected bribery or corruption should be reported to our Compliance Officer (designated person) at info@smartoneworld.com. Reports may be made confidentially. We do not tolerate retaliation against any person who reports a concern in good faith. Reporters are protected in accordance with the Protection of the Whistleblower Act (Chapter 527 of the Laws of Malta) and EU Directive 2019/1937, where applicable.
9. Governance and review
This policy is owned by management, adopted by the Board of Smart One Holding Limited, and reviewed at least annually. Approved by Pavel Voloshin, Chief Executive Officer, on behalf of the Board. Date of adoption: June 2026.