Anti-Corruption and Bribery Policy v. 1.0

Arnarlax value:

We Care!


Implementation:
Through awareness, dialogues and follow-ups


Anti -Corrupti on and Bribery Policy

Arnarlax opposes corruption in all forms, including corruption of Public-Officials as well as any representative of any entity, company, organization and any other legal person, regardless of whether an intent to influence is present. Arnarlax has zero tolerance for corrupt practices from any employee, manager, member of the Board of Directors or any third party engaged in any of the company's projects in connection with any of company's activities. No company employee shall directly or indirectly offer, promise, give or receive a bribe, unlawful or inappropriate gift or other unreasonable benefit or consideration inorder to obtain an improper advantage for themselves or for the company.


Arnarlax employees are not permitted to give or accept personal benefits or gifts that constitute an improper advantage in connection with the conduct of a position, an office or performance of an assignment. This prohibition also applies to invitations, travel or participation at events staged by suppliers or business associates without the prior approval of the employee’s line manager. Employees have a duty to inform the company of all benefits they receive from business partners or other third parties in connection with their employment. The employee must, no later than the last day of the month, submit such information to the company. If the company does not receive such information from the employee by the specified deadline, the company is both entitled and obliged to estimate the value of such benefits on the basis of available information. Corruption and bribery risk assessments should be carried out at regular intervals, and personnel training is done in due course.


Arnarlax has zero tolerance for any form of money laundering. Any actions that involve assistance in safeguarding the proceeds of a criminal act for another person by for example collection, storing, concealing, transporting, sending, transferring, converting, disposing of, pawning or investing them is considered as money laundering.


Money laundering also includes converting or transferring assets or by other means conceals or obscures where the proceeds of a criminal act the person or entity itself has personally committed are located or originate from, who controls them, their movements or rights associated with them.


Arnarlax shall only trade with suppliers and others who conduct legal business and whose funds come from legal sources. The company will take all necessary precautions to prevent its transactions being used by others for the purpose of money laundering. This includes measures to encourage and support the compliance of relevant regulations, ethics and compliance policies and risk-based screening procedures against money laundering and terror financing by personnel.


All transactions with related parties must be based on the “arm’s length” principle. This means that price and conditions of the transaction shall consist of fair market terms and terms similar to what two independent parties with an equal bargaining power would have chosen.


To the extent that agents or local representatives are used in countries outside Arnarlax main operating areas, particular prudence must be exercised, and necessary background checks (due diligence) must be performed when relevant. The Group’s Compliance Officer must be involved in this process.


Conflicts of interest should be avoided, and Arnarlax employees are always committed to minimizing these. A conflict of interest may be an actual or perceived interest a person has in the subject matter – economically or otherwise – directly through personal interests or someone they are closely related to. A conflict of interest may involve customers, suppliers, contractors, existing or future employees, competitors or other associates. Should a conflict of interest arise, the employee has a duty to assess the situation and inform their line manager and the Compliance Officer of the situation.


Any identified breaches relating to the above-mentioned should always be reported through Arnarlax's whistleblowing channel. This channel is handled by an independent third-party and is available to anyone, both internally and externally. Failure to report identified breaches will be considered a breach of Arnarlax's Ethical Guidelines, which may result in formal warnings or dismissal.