Code of Conduct & Anti-Bribery
Last updated:
SmartOne maintains a zero-tolerance approach to bribery and corruption.
1. Our commitment
We prohibit bribery, kickbacks, and improper advantages in all jurisdictions where we operate. This aligns with the UK Bribery Act 2010 and the U.S. Foreign Corrupt Practices Act where applicable.
2. Scope
Applies to employees, officers, contractors, agents, and business partners acting on our behalf.
3. Gifts and hospitality
Modest gifts and business hospitality are permitted only if transparent, infrequent, and below an internal threshold (example: €50 equivalent) — REPLACE-GUIDE: confirm policy limit.
4. Political contributions
Prohibited unless explicitly authorised by the Board and lawful in the relevant jurisdiction.
5. Facilitation payments
Prohibited.
6. Agents and intermediaries
Due diligence and contractual anti-corruption clauses are required before engagement.
7. Reporting
Report concerns confidentially: ethics@smartoneworld.com — REPLACE-GUIDE: T-04. No retaliation against good-faith reporters.
8. Approval
Example approval: Pavel Voloshin, Chief Executive Officer — June 2026. REPLACE-GUIDE: L-04 Board sign-off.