COMPUTER C-DATA LTD. – ANTI-CORRUPTION AND BRIBERY POLICY
1. GENERAL PROVISIONS
1.1 Purpose and objectives of this Computer C-Data Ltd. Anti-Corruption and Bribery Policy
(the“Policy”) is establishing the key principles, requirements and procedures adopted by Computer C-Data
Ltd. and its affiliates (collectively, "C-DATA") to prevent corruption, mitigate the risks of bribery and
corruption and ensure compliance with all applicable anti-corruption laws and regulations, including
but not limited to the U.S. Foreign Corrupt Practices Act and the UK Bribery Act of 2010, to the extent
1.2 C-DATA is committed to applying the highest standards of ethical conduct and integrity in its
business activities. Every employee and individual acting on C-DATA’s behalf is responsible for
maintaining C-DATA’s reputation and conducting C-DATA business honestly and professionally. The
implementation of the Policy ensures the legitimacy, transparency and openness of C-DATA activities
to all its stakeholders.
1.3 This Policy applies to all individuals working at all levels and grades, including directors, senior
managers, officers, employees (whether permanent, fixed-term or temporary), consultants,
contractors, agents, trainees, interns, seconded staff, agency staff, and subsidiaries acting for, or on
behalf of C-DATA and any of our subsidiaries or their employees, wherever located (collectively, for
the purpose of this Policy, "Employees"). This Policy applies to all dealings and transactions of C-D
ATA. C-DATA Employees are required to read, understand, and adhere to this Policy. In addition,
CDATA managers are required to enforce the policy and ensure that Employees, individuals, and
entities, are aware of, and understand the requirements of this Policy.
1.4 Fundamental principles and requirements of the Policy equally apply to contractors of C-DATA,
including suppliers, agents, intermediaries, consultants, representatives and other individuals and
legal entities, to the extent such responsibilities are implied by agreements with them, stated in their
internal documents, or expressly derived from the applicable laws (including anti-corruption laws).
2. PROHIBITION OF CORRUPT PRACTICES
C-DATA applies a “zero tolerance” attitude to any form of corrupt practices within its business
activities as well as to violations of this Policy. All Employees have an obligation to uphold the ethical
standards of the Policy, and must take responsible steps to prevent any Policy violations. An Employee
will be reprimanded and/or terminated (or other disciplinary actions will be applied to such Employee)
for any intentional violation of this Policy or for failing to report violations of the Policy which are
known to the Employee. If required by applicable laws, breaches of the Policy may be reported to law
enforcement agencies and may result in criminal proceedings being issued against C-DATA’s Employee
and/or other parties involved. At the same time, C-DATA undertakes that no prohibition will be
imposed (including dismissal, demotion, deprivation of bonuses, etc.) on the Employees who refuse
to participate in corrupt activities even if such refusal results in C-DATA’s failure to gain commercial
and/or competitive advantages and/or losses that cannot be avoided without breach of this Policy.
3. REGULATION FOR THE MOST RISKY AREAS
3.1 Bribery It is prohibited for C-DATA Employees and any party which renders services on behalf or
for the benefit of C-DATA, including agents, representatives, consultants and other intermediaries,
• to promise, offer and/or give bribes, including bribes to governmental officials;
• to request, agree to receive and/or accept bribes;
• to make facilitation payments in favor of governmental officials and other persons.
A “bribe” or “bribery” is giving or offering money, securities, property, rendering of services or any
advantage, whether directly or indirectly, to any person (including public officials),
with the intentionof influencing their actions or decisions, to reward them for improper performance, in order to gain
any improper advantage, or for any other improper purpose. Bribery is also requesting or receiving
items similar to those indicated above whether directly or indirectly, from any person (including public officials),
intending that, as a consequence, a relevant function or activity should be performed
improperly, whether by an Employee of C-DATA or another person. Facilitation payments is to provide
funds, property, property rights and interest, services, and other financial or other advantages in order
to ensure execution or to facilitate standard statutory procedures or actions, provided that such
payments are not stipulated by the laws and other regulations of a particular country, but are
commonly used as a part of its local business practices. If an Employee of C-DATA is offered, or
requested to give, a bribe or make a facilitation payment, the Employee must refuse any such offer or
request (even if an Employee is forced to make such activity by different means). The Employee shall
inform C-DATA about any such case.
3.2 Gifts, Hospitality and Business Entertainment Expenses Gifts, including services, special
acknowledgments and entertainment, shall not put the recipient in a situation where an C-DATA
Employee’s ethics might be called into question or into the situation of the conflict of interest. Gifts,
souvenirs and promotional items may not be accepted. It is prohibited to give gifts, pay for goods,
works or services, or provide any other tangible or intangible benefits for the benefit of government
officials (or persons as directed by them, including family members and other relatives) intended to
influence actions or omissions of state employees regardless of whether such actions were made
directly or through agents or third parties.
C-DATA and its Employees must not make, directly or indirectly, a payment or gift of, or an offer,
promise, or authorization to give money or anything of value to: (a) a government official, or
(b) any other person or entity while knowing or having reason to believe that some portion or all of
the payment or thing of value will be offered, given, or promised, directly or indirectly, to a
government official for the purpose of influencing any act or decision of a government official,
including a decision to do or omit to do any act in violation of its lawful duties or to obtain or retain
business for, direct business to, or secure an improper advantage for C-DATA or any of C-DATA's
customers and partners. The term “government official” includes: (i) any official or employee of any
government agency or government owned or controlled enterprise; (ii) any candidate for political
office; (iii) any political party or member thereof; (iv) any official of a public international organization;
and (v) anyone acting in an official capacity on behalf of a government agency or government owned
or controlled enterprise.
Each Employee shall immediately disclose to C-DATA at firstname.lastname@example.org when either: (a) an Employee,
agent, or representative of C-DATA is a government official with the ability to direct, influence, or
control the sales or procurement of the business or C-DATA or any of C-DATA's customers and
partners, or (b) a spouse, sibling, parent, or child of an Employee, agent, or representative of C-DATA
is a government official with the ability to direct, influence, or control the sales or procurement of the
business or C-DATA or any of C-DATA's customers and partners.
3.3 Interaction with Suppliers and Contractors For the purposes of this Policy, suppliers and
contractors mean legal entities, individuals or individual entrepreneurs who:
• render services to C-DATA (and its subsidiaries) or operate on behalf or for the benefit of C-DATA;
• are not part of C-DATA.
C-DATA seeks to do business with reputable suppliers and contractors that are not involved in any
corruption or bribery proceedings. C-DATA informed suppliers and contractors regarding anticorruption policies
applied by C-DATA. Also C-DATA expects its counterparties to prevent cases of
corruption on their part, as well as on the part of Employees of C-DATA.
4. IMPLEMENATION COMPLIANCE WITH THE POLICY
4.1 Policy Requirements All Employees are responsible for the success of this Policy and should ensure
that they use it to disclose any suspected danger or wrongdoing. Employees are invited to comment
on this Policy and suggest ways in which it might be improved. Comments, suggestions and queries
should be addressed directly at email@example.com. All Employees should know the Policy, its
requirements and the ways of communication. All new Employees of C-DATA shall become
familiarized with the requirements of this Policy.
4.4 Review and Monitoring C-DATA will regularly review this policy, assessing the efficiency of both
its terms and implementation. Any improvements identified as being necessary will be made as soon
as possible in order to ensure that the policy is in compliance with applicable anti-corruption
legislation, suitable, adequate, and up to date and effective at all times.