HUEN ANTI-CORRUPTION POLICY

VERSION 1.0 · EFFECTIVE 1 MARCH 2023 REPORTING: INFO@PROFIXEPSZER.HU

We win work on price and capability

Construction carries a high corruption risk: many parties, large sums, pressing deadlines, and many decisions taken by one person on site. Declaring it prohibited is therefore not enough. This policy also states what counts as a borderline case, and what to do when one arises.

01 · Prohibited without exception

• Bribes and kickbacks in any form, including where the other party asks for them, and including where "everyone does it".
• Facilitation payments: small sums to speed up official or client processing. This is corruption too, even where the underlying matter is legitimate.
• Fictitious invoices and sham contracts: consultancy, agency or subcontractor fees for work that did not take place.
• Diversion of materials: taking materials or equipment intended for the works for private use, or handing them over as a "gift".
• We make no corporate donations to political parties, candidates or campaigns.

02 · Gifts and hospitality

Ordinary business courtesy is not prohibited, but it becomes so near a decision. All three of the following must hold:

1. it is of customary scale and consistent with local business practice;
2. it does not fall during a live enquiry, tender or completion certification;
3. it can be given or accepted openly, with your manager's knowledge, and is transparent in the accounts.

Practical test: if you would be uncomfortable telling your manager, the client or a journalist about it, it cannot be accepted. Cash and cash equivalents (vouchers, prepaid cards) are never given or accepted.

A gift that cannot be refused (a package handed over on site, for instance) must be reported to management, which decides whether to return or donate it.

03 · Conflicts of interest

The problem is not that a conflict exists, but that it goes unmentioned. Declare it to management in writing before a decision is made if:

• a close relative owns or manages a bidding subcontractor or supplier;
• you hold an interest in a business we contract with;
• you carry out work in your own name that falls within the company's field of activity;
• you would have to decide on the hiring, pay or appraisal of a close relative.

Once declared, the person concerned is excluded from that decision. Making the declaration never carries a disadvantage.

04 · Procurement and subcontractors

• For significant purchases we obtain several quotations and record the reasons for the decision.
• Wherever organisationally possible, the same single person does not both run the enquiry and close the decision.
• We work with intermediaries only under written contract, for a defined and genuine service at market rates. We pay no success fee for obtaining an official permit.
• By contracting, a subcontractor undertakes to comply with this policy and to extend it down its own chain.

05 · Records and fair competition

Every payment corresponds to a genuine economic event and an accurate accounting trail; there is no hidden invoice, "black box" or off-book fund. We do not align prices with competitors, share out markets or clients, or coordinate tender bids. We take no part in money laundering: unusual payment requests (third-country accounts, cash, refunds of overpayments) are investigated before we contract.

The Hungarian version of this policy governs; this English edition is provided for information.