In all its activities, Unifarm is committed to the basic principles of good corporate conduct and integrity. The establishment and implementation of the Anti-Corruption Programme (hereinafter referred to as the Programme) is an important part of this commitment.
HONESTY, TRUST, RESPECT.
Our programme is based on the laws of Bosnia and Herzegovina, anti-corruption conventions whose signatory Bosnia and Herzegovina is, the best world anti-corruption practices, and specific anti-corruption requirements of our partners.
The purpose of our Programme is to foster the culture of respecting, preventing or detecting violations of laws or the Company’s internal acts. Unifarm expects the conduct and actions of our employees, contractors, agents, representatives and all other persons acting for and on behalf of the Company to be in full compliance with the laws, our codes, policies, procedures, guidelines, working instructions. If the Company becomes aware of violations of the law or our internal acts, we will immediately initiate an investigation process, take appropriate disciplinary action, and apply corrective actions to prevent future violations.
Unifarm recognizes that our Programme must constantly evolve in order to respond effectively to changing circumstances in the Company and the environment. In this regard, we are committed to continuous improvement of the quality of the Programme its development, based on regular review and assessment of the changing regulatory and business environment.
Responsibility and monitoring
Unifarm has determined that responsibility for developing, implementing and monitoring the Programme, as well as proposing improvements for a more effective Programme, is assigned to the Business Ethics and Compliance Management Representative. The Business Ethics and Compliance Management Representative reports to the Director of the Company on his/her work and on the essential issues related to the programme. The Director of the Company is responsible for supervision of the Business Ethics and Compliance Management Representative. In addition to being responsible for meeting the set goals, the Director of the Company evaluates the effectiveness of the Programme once a year.
Internal Anti-Corruption Legislation
Unifarm’s Anti-Corruption Policy, Code of Conduct, procedures, guidelines, work instructions and other instructions are binding on all our employees, contractors, agents, representatives and all other persons acting for and on behalf of the Company (hereinafter referred to as the Personnel). To emphasize the importance of compliant conduct, we require each of our employees to confirm that they are familiar with and agree with all of Unifarm’s policies and procedures.
Unifarm conducts all its activities and business in an honest and lawful manner. We have zero tolerance for corrupt conduct, which includes bribery, fraud, distortion of competition, coercion and interference. The anti-corruption policy strictly prohibits such conduct and clearly indicates that Unifarm has no tolerance for conduct that does not comply with the Policy. Our Code of Conduct provides guidance on how to do business in a fair, ethical and lawful way. All Unifarm personnel must be familiar with, understand and follow the Code of conduct that includes anti-corruption expectations for all personnel. Our Programme includes a number of controls of reporting, monitoring and certification, as well as the component of mandatory training which we elaborated in the Code of Conduct for our employees as well as in the Procedure for education, training and development of the employees, in the Procedure for providing resources, scheduling employees, and the conclusion and termination of the employment contracts, where we have defined in detail the process of admission, monitoring, promotion and conclusion of relations with our Personnel. An important part of this Procedure is the anti-corruption elements in terms of defining relations with public officials, conflicts of interest, compliance with laws and internal regulations. Unifarm expects our suppliers, business partners and others who do business with us or on our behalf to operate in accordance with all applicable laws and regulations and in accordance with the highest anti-corruption standards. In order to avoid unlawful third party conducts, Unifarm has developed a Third Party Code of Conduct, where the third party due diligence process prior to their engagement is prescribed in detail. It is also defined how third parties are monitored and the possibility of third party monitoring, because we are aware of the legal and business risks associated with the selection of suppliers and business partners. The procedures for marketing activities, in addition to the process of awarding sponsorship being recognized as a risk point, prescribe in detail the process of advertising in compliance with the specific requirements of the regulator. Unifarm aims that all Personnel clearly distinguish the conduct considered normal and acceptable in relation to what is considered unethical, punishable, or contrary to good corporate governance and best business practice. Therefore, we have prescribed in detail the conduct and procedures associated with high-risk processes such as donations, gifts, entertainment, hospitality and travel in the Rulebook of cost management integrity. Detection of any violation of laws and/or internal acts and/or the occurrence of non-compliant conduct with it has the highest priority for the successful functioning of our Programme. The Procedure for management of non-compliance and deviations, and the Procedure for corrective actions prescribe the process of discovery, investigation and remediation of non-compliance.
Corruption risk assessment
The assessment of the risk of corruption occurrence is the basis for our Programme and the accompanying anti-corruption policy, procedure and instructions. It is an ongoing process that provides the company with systematic insight into the risk points of corruption occurrence. The results of the risk assessment are used to design controls and activities that address the identified risks in terms of reducing/eliminating them. This process is of priority importance as the information provided by the risk assessment serves to shape our Programme and associated procedures. Additionally, the continuity of our Programme ensures the validation of this process and ensures its continuous improvement. The corruption risk assessment is done once a year and includes the assessment of business processes and job positions, the assessment of the adequacy of internal policies and procedures, the analysis of historical data and the assessment of employees’ awareness of internal policies and procedures.
Training and communication
Education and training are essential for effective communication of our Programme and the requirements related to our Personnel. All the Personnel receive training on the Programme, the Code of Conduct as well as on the rules, procedures, guidelines and working instructions related to anti-corruption that apply to their work functions. We maintain and monitor the training records to ensure that all the Personnel have received the necessary training. We believe that the training and informing the Personnel on their legal and ethical obligations is a prerequisite for coordinated and correct action in the conduct of business activities.
Unifarm provides the training on the Programme as a part of the introductory process for all new Personnel. We provide, on an annual basis, the adequate anti-corruption training for all the Personnel, and where we deem it necessary, the Personnel receive additional extended training, especially where there is a potential risk of bribery or corruption during work activities. The Personnel are required to confirm annually that they have complied with the provisions of the law and internal acts of the company.
Counselling and detection of irregularities
Unifarm is committed to fostering an active and healthy dialogue between the management and the Personnel on ethical and regulations compliance issues. The Unifarm Personnel are encouraged to seek answers to questions regarding the Programmes. In its policies and procedures, the Company has prescribed an obligation for all the Personnel to report any type of irregularity and to encourage their Personnel to report any potential doubts regarding compliance to the rules. Unifarm has also established a channel for counselling about potential doubts related to our Programme and reporting of potential irregularities. Unifarm cultivates the “Open door policy” and encourages the Personnel to discuss all dilemmas or doubts with their superiors and/or the Director of the Company. Unifarm warrants that any Personnel who in good faith indicate a suspected malpractice will not be exposed to any kind of retaliation or prejudice. Unifarm strictly forbids any kind of retaliation or discrimination on any grounds and considers such conduct unacceptable.
Corrective action procedures
Our Programme increases the likelihood to prevent or identify any unlawful and unethical conduct. However, we recognise that even an effective Programme will not prevent all misconduct, and therefore our Programme requires the Company to respond promptly to potential violations of laws or Unifarm policies and procedures, to take appropriate disciplinary measures, to assess whether the breach has been due to deficiencies in our policies, practices or internal controls, and to take appropriate corrective action to prevent or limit any future violations.
Implementation and discipline
All our activities related to the implementation of the Programme are set out in the annual Anti-Corruption Plan, which is based on the corruption risk assessment.
Everyone bears personal responsibility for not complying with and abiding by the laws, policies and procedures and any violation will be considered as a disciplinary matter. All violations identified will result in disciplinary procedure and a prescribed sanction will impose proportionate to the misdemeanour committed, and it may also result in the termination of the contract and/or lawsuit. These procedures are intended to address inappropriate conducts and to deter future violations of the laws, policies, and procedures.
Relations with Third Parties
Unifarm is committed to performing all our activities in accordance with applicable laws and ethical standards. We are a fair and honest business partner and therefore we require our third parties to respect the standard of zero tolerance for corruption. We firmly believe that relationships built on these principles, values of trust and mutual respect are sustainable and beneficial to everyone. Our Programme and the zero tolerance attitude are clearly communicated to our suppliers, business partners and all third parties at the beginning of the business relationship and, where appropriate, thereafter.
We believe that we have developed and implemented an effective Anti-Corruption Programme and will continue to work on the improvement of our Programme and all of our anti-corruption activities.