Anti-corruption and business ethics policy #

Effective date: 2026-09-24 Last reviewed: 2026-09-24 Next review: 2027-09-24 Owner: Yaroslav Shmarov, operator Version: 1.0

1. Purpose #

This policy states the standards of business conduct that govern EthicsPortal, the specific practices they prohibit, and the arrangements that make a breach visible. It exists so that a customer, a partner, or a procurement reviewer performing third-party diligence can refer to a single named document rather than infer a position from silence.

EthicsPortal sells infrastructure for reporting wrongdoing. A vendor in that position is held to the standard it sells, and the sections below are written to be checked rather than admired.

2. Scope #

This policy applies to the operator, to anyone acting for or on behalf of EthicsPortal, and to every commercial relationship the business enters: customers, prospects, resellers and referral partners, sub-processors, suppliers, and public authorities.

It applies in every country where EthicsPortal does business. Where a national law sets a stricter standard than this policy, the stricter standard applies.

3. Prohibited conduct #

The following are prohibited without exception, and no commercial objective justifies any of them:

A breach does not require that the improper advantage was actually obtained. Offering and requesting are prohibited on the same terms as giving and accepting.

4. Laws that apply #

EthicsPortal is operated by a Polish sole proprietorship and sells across the European Union. The following apply directly or by extraterritorial reach:

• Polish Criminal Code, Articles 229 and 230a (bribery of and trading in influence with public officials) and Article 296a (bribery in commercial dealings).
• Polish Act of 14 June 2024 on the protection of whistleblowers, transposing EU Directive 2019/1937.
• UK Bribery Act 2010, Section 7, which reaches a non-UK organization carrying on part of its business in the United Kingdom, and which recognizes no facilitation-payment exemption.
• US Foreign Corrupt Practices Act, where any element of a transaction has a United States nexus.
• French Law 2016-1691 (Sapin II), which does not bind EthicsPortal directly but governs the third-party diligence obligations of French customers. Declarations made to those customers are made on that footing.
• OECD Anti-Bribery Convention and UNCAC, as the instruments the above implement.

EthicsPortal does not fall within the scope of Article 17 of Sapin II or of the Polish Act’s obligation to operate an internal reporting channel, neither of which reaches an organization of this size. The channel described in §10 is operated regardless.

5. Gifts and hospitality #

Gifts and hospitality are permitted only where they are modest, infrequent, transparent, proportionate to a normal business courtesy, and incapable of being read as an attempt to influence a decision.

Anything above the single-item threshold, and anything at all involving a public official, is recorded in a gifts and hospitality register maintained by the operator. The register is available to a customer or auditor on request during procurement review.

Where a gift cannot be declined without causing offence, it is accepted, recorded, and donated or otherwise disposed of so that the operator derives no personal benefit.

6. Conflicts of interest #

A conflict of interest is any circumstance in which a personal, financial, or professional interest could reasonably be seen to influence a decision taken for EthicsPortal. Perception is sufficient. An interest does not have to have caused a distorted decision to require disclosure.

The operator holds professional interests outside EthicsPortal. Where any such interest touches a customer, prospect, partner, or supplier of EthicsPortal, it is disclosed to that party in writing before the relationship is entered into, and the nature of the interest is disclosed on request during procurement diligence.

The following are disclosed without being asked:

• Any employment, directorship, shareholding, or advisory role held by the operator in an organization that is a customer, prospect, competitor, reseller, or supplier of EthicsPortal.
• Any personal or family relationship with a person who influences a purchasing decision affecting EthicsPortal.
• Any financial interest in an organization that would benefit from a recommendation EthicsPortal makes.

Because EthicsPortal has one decision-maker, a conflict cannot be managed by recusal. It is managed by disclosure and, where disclosure is not sufficient to protect the counterparty, by declining the engagement.

7. Referral fees, commissions, and partner arrangements #

This is the area where a business of this kind is most exposed, and it is stated in more detail for that reason.

EthicsPortal pays and receives referral fees and reseller commissions. Such an arrangement is legitimate when the buyer knows it exists and improper when they do not: an undisclosed payment to a person who influences a purchasing decision is commercial bribery, regardless of what it is called.

The following apply to every partner, reseller, affiliate, and referral arrangement:

• The commercial relationship and the existence of a fee are disclosed to the end customer before the customer commits.
• No fee, commission, or benefit is paid to an individual employee, officer, or adviser of a customer organization. Fees are paid to the partner organization, against an invoice, on written terms.
• No fee is contingent on a specific individual inside the customer recommending EthicsPortal.
• Consultants, advisers, and intermediaries paid by EthicsPortal are engaged on written terms that incorporate this policy, and are paid at a rate justifiable as the market value of the service actually performed.
• Where a prospective partner declines to allow disclosure of the arrangement to end customers, the arrangement is not entered into.

Free or discounted deployments offered for evaluation, pilot, or launch reasons are offered to the customer organization on published or written terms, never to an individual, and never as a personal benefit to the person who signs.

8. Political and charitable contributions #

EthicsPortal makes no political contributions of any kind: no donations to parties, candidates, campaigns, or political organizations, in cash or in kind, in any country.

Charitable contributions are permitted only where the recipient is a genuine charity, no decision-maker of a customer or prospect requested the contribution, and it could not reasonably be read as a benefit conferred to secure business.

9. Sanctions, export control, and financial records #

EthicsPortal does not deal with parties in, or controlled from, a jurisdiction subject to EU restrictive measures. Sub-processors are established in the European Union and are published on the subprocessors page. Customer payments are processed by Stripe, which applies its own sanctions and anti-money-laundering screening.

All transactions are recorded accurately in the accounting records required under Polish law. No undisclosed account, unrecorded transaction, false entry, or misdescribed expense is created or permitted. Invoices describe what was actually supplied.

10. Raising a concern #

Anyone — a customer, a partner, a supplier, or a member of the public — may report a suspected breach of this policy, in confidence or anonymously, through EthicsPortal’s own internal reporting channel, operated on EthicsPortal’s own product under Directive 2019/1937:

secure.ethicsportal.eu/p/R8HXGNHO

Reports may also be sent to legal@ethicsportal.eu , though that route is not anonymous.

A report is acknowledged within seven days and given feedback within three months, in line with the Directive’s own timescales. No person who reports in good faith suffers any detriment for having done so, and that protection holds even where the report turns out to be mistaken.

A reporter who does not wish to raise the matter with EthicsPortal may report externally to the competent national authority. For customers of EthicsPortal, the authorities for each Member State are listed under whistleblower laws by country .

11. Structural limitations #

This policy is operated by one person, and the ordinary controls against corruption assume more than one. That limitation is stated here rather than disguised by procedure:

What substitutes for these is external visibility rather than internal separation: published pricing, written terms for every partner arrangement, transactions recorded through Stripe and the statutory accounting records, disclosure obligations that run to the counterparty rather than to an internal committee, and a whistleblowing channel open to anyone outside the business.

This is a compensating position, not an equivalent one. A customer whose diligence standard requires segregation of duties at the supplier should record this as an open finding.

12. Enforcement and review #

A breach of this policy by the operator is a breach of the commitments made to customers under the Terms and may constitute a criminal offence under the laws in §4. Where a breach is suspected or reported, the operator records it, investigates it, remediates it, and discloses it to any affected counterparty.

Where EthicsPortal engages personnel, resellers, or intermediaries in future, this policy is a term of that engagement, and this document is updated to state the training and monitoring that apply to them.

13. Document control #

Signed: Yaroslav Shmarov, on behalf of EthicsPortal — 2026-09-24.

Last updated: September 30, 2026