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Bizbrains Policy - Anti bribery


The purpose of this anti-bribery policy is to describe the requirements for our business practices and employee conduct.

The intention of this Anti-Bribery Policy

Bizbrains recognizes that corruption and other unethical behavior undermine the support and trust among our stakeholders (customers, contributors, suppliers, consultants and other business partners), which is critical to Bizbrains's business success.

Bizbrains has therefore drawn up this anti-bribery policy to counter corruption, bribery, and other unethical behavior. At Bizbrains, everyone is obliged to comply with applicable legislation and regulations as well as this anti-bribery policy as well as all relevant policies and guidelines in day-to-day work.

If applicable laws and regulations require higher standards than those set forth in this Anti-Bribery Policy, those standards must be followed.

Combating bribery and corruption

Bribery and corruption undermine legimite activities, distort competition, damage reputations, and expose both Bizbrains and individuals to risks.

Bizbrains has a clear zero-tolerance policy in relation to bribery and corruption. We strive to ensure that bribery does not occur in connection with business activities in which we are involved.

Bribery is a form of corruption that consists of the offer of improper advantages made with the aim of influencing a party. It can, e.g. be gifts, loans, fees, rewards, credits, discounts, travel, accommodation, or other benefits between anyone working for or on behalf of Bizbrains and any external person.

Kickback is a form of bribery between private entities, such as taking place with a view to winning a tender. In that situation, the person responsible for the tender or order does not necessarily award the task to the party with the best offer but instead to the party that pays the return commission. It is illegal to pay a return commission in this situation. Kickbacks are also illegal if the company paying kickbacks submits the best bid and would have won the tender in any case.

Bizbrains will not pay or promise to pay any kind of kickback in exchange for awarding tenders/orders to a particular supplier. In addition, Bizbrains will not promise, request, give or receive any kind of benefits that can be perceived as being connected to the awarding of a tender/order. This applies regardless of whether such an advantage is exchanged before, during, or after the award of the tender.

For the avoidance of doubt, any normal and transparent rebate structures are not considered Kickback.

"Paying under the table" is a form of bribery that takes place to expedite or facilitate a processing of routine activity and/or to expedite or secure the delivery of products or services to which Bizbrains has a legitim claim.

Bizbrains is against under-the-table payments and will actively fight such payments if/when we come across them. Corruption does not become more legal because it is common practice in a given country. Even in cases of minor illegal payments, references to local customs and trade patterns are not a defense that is acceptable to present before the courts of the country in question or Danish courts.

Political contributions are defined as financial and other forms of support given to political parties and political campaigns, while charitable contributions are defined as contributions made to charitable causes or organizations.

Bizbrains does not support individual political parties or individual politicians. However, Bizbrains's employees may exercise their private rights to participate in democratic political activities, provided that this is done without reference or connection to their relationship with Bizbrains.

Contributions to charity, e.g. knowledge, exchange of services or direct financial contributions, are acceptable, provided that such contributions are not made for the purpose of obtaining or retaining business relationships or any other form of improper advantage. By showing the necessary care and transparency, Bizbrains's employees must ensure that contributions to charitable purposes and financial support are not used as a substitute for and do not constitute bribery. As a result, charitable contributions must only be made to organizations, not to individuals.

Gifts and hospitality such as flowers, confectionery, wine, fountain pens, tickets to sporting and cultural events, meals, receptions, social events, entertainment, etc. must always comply with the laws of the country where they may be given or received. In this connection, Bizbrains's employees must be aware that stricter rules usually apply in the public sector than in the private sector.

Bizbrains's employees will therefore not offer or accept hospitality or gifts with a view to obtaining or maintaining business relationships or any other form of inappropriate advantage from clients in the public sector. Bizbrains's employees will also not offer or accept gifts or entertainment that is unreasonable, excessive or goes beyond normal market practice. Bizbrains's employees may not offer, request, give or receive gifts in the form of cash or gift cards of any kind. Gifts to or entertainment of parties involved in a tender or similar processes for awarding orders are also prohibited.

Complaints and reporting

If a person has moral concerns about any actions by Bizbrains or encounters direct violations of Bizbrains's anti-bribery policy, such cases must be reported immediately. You can, of your own choice, make a report either through the usual channels to the Bizbrains management who is responsible for the area where the problem arises (this assumes, however, that the manager responsible for the case is neither the person who makes the report nor is the subject of the report) , or to Bizbrains's compliance manager or CEO.

Employees who choose to make a report (whistleblowers) will not be exposed to reprisals.

The person who receives the report in question must properly investigate - and, to the extent relevant, ensure that the case is taken through the normal channels. Bizbrains's board has final authority and responsibility to deal with cases that cannot be resolved at a lower level.

Information about whistleblower(s) must be stored at all times in accordance with applicable laws and regulations on the protection of personal data, e.g. rules on the deletion of information that is no longer of interest to the company.


Bizbrains's employees will not be penalized or exposed to other negative consequences for refusing to pay a bribe, even if it may cause Bizbrains to lose business or be exposed to other negative consequences. Nor will Bizbrains's employees be punished for asking questions about or reporting unethical behavior or corruption.

Failure to comply with this anti-bribery policy may result in disciplinary action, including dismissal or expulsion, and may be reported to the appropriate authorities.

Compliance and Monitoring

This policy has been adopted by Bizbrains's board of directors. Bizbrains's management will periodically review and update this policy and ensure that it is complied with by all senior staff, employees and business partners who act on our behalf.

It is the responsibility of Bizbrains's management to pass on this policy and ensure that all employees and external parties who represent Bizbrains understand and comply with the objectives and procedures in relation to this policy.

Communication and education

All partners and all relevant employees will receive appropriate training regarding compliance with anti-corruption laws and regulations as well as general practices relevant to Bizbrains's business area.

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