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Anti- Bribery & corruption Policy

Policy statement

Útgerðarfélag Reykjavíkur hf. (“ÚR”) is committed to conduct its business in an ethical and honest manner. ÚR is committed to act professionally, fairly and with integrity in all business dealings and relationship, wherever we operate. ÚR has zero tolerance for bribery, facility payments and other corrupt activities.

This policy sets out the responsibilities of Útgerðarfélag Reykjavíkur hf., its employees, contractors and others associated with the company in regards to observe and uphold the companies commitment of business integrity and zero tolerance position on bribery and corruption.

Compliance with laws, rules and regulations

ÚR´s commitment to integrity, ethics and anti-corruption begins with complying with laws, rules and regulation where the company operates.

ÚR´s employees, contractors and others associated with the company must have a general understanding of applicable laws, rules and regulations that apply with their specific role within the organization.

In the event that there is doubt that a contemplated action is permitted by law, rules or regulations, the company will seek an advise from it´s legal council before such an action is taken.

ÚR´s employees, contractors and others associated with the company are obligated to prevent violations of laws, rules and regulations and to inform senior management if they see possible violations.

Bribes

Bribery refers to the act of offering, giving, promising, asking ,agreeing, receiving, accepting or soliciting something of value or of an advantage to induce or influence an act or decision.

A bribe refers to any inducement, reward, or item of value offered to another individual in order to gain, commercial, contractual, regulatory or personal advantage.

Bribery is illegal. ÚR´s employees, contractors and others associated with the company are obligated not to engage in any form of bribery, weather it is directly or through a third party.

Facility payments

ÚR does not accept and will not make any form of facilitation payments of any nature. The company recognizes that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action.

Gifts and hospitality

ÚR accepts normal and appropriate gestures of hospitality and goodwill weather given to or received from third parties, as long as the giving or receiving gifts meets the following requirements:

– It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or business advantage or as an explicit or implicit exchange of favors or benefits.

– It is not made with the suggestion that the return favor is expected.

– It is in compliance with local law.

– It is given in the name of the company, not an individual.

– It is of an appropriate type and value and given at an appropriate time or occasion.

– It is given/received openly, not secretly.

– It is not offered to or accepted from a government official, politician or a political party without the prior approval of the company´s CEO.

– It is not offered to or accepted from a government official, politician or a political party without the prior approval of the company´s CEO.

Responsibilities and disciplinary actions

ÚR´s employees, contractors and others associated with the company have a responsibility to report on any activities that could imply a breach of this policy. Reports on activities or concerns over possible breaches shall be addressed to the company´s CEO or a member of the board of directors.

ÚR´s employees that are found to have breached this policy will face disciplinary actions and could face termination of employment for gross misconduct.  Violation of this policy may also constitute a criminal offence. If it appears that an employee, contractor or other associated with the company have committed a criminal offence, ÚR will refer the matter to the police or other appropriate regulatory authorities.

Approved by ÚR´s board of directors 29.3.2022