Tradesilvania is strongly committed to being a responsible interest factor for the financial sector and is making every effort to conduct its business in an ethical and exemplary manner. Complying with the highest standards is at the heart of the Tradesilvania strategy, demonstrating its commitment to its ethical behavior and recognition of its role in protecting the financial system against financial crimes, including bribery and corruption.

The ultimate goal of these measures is to protect clients both individually and collectively from any effects of financial infractions, including bribery and corruption.

The company does not accept any form of corruption from private individuals or civil servants or public officials. The Company does not engage in or accept any activities that are not in accordance with this policy or applicable anti-bribery and anti-corruption laws.

The Company and the employees of the Company are prohibited from offering, promising, giving, requesting, receiving, approving, engaging in, or authorizing, directly or indirectly, the transfer of any valuable thing to influence the actions of another person (or to ensure inaction) and/or to obtain an undeserved commercial advantage.

Also, the Company and the employees of the Company are not allowed to offer consent to obtain or to obtain, request or receive, in any other respect, directly or through an intermediary, anything of value; and they are not allowed to act as intermediaries in giving public or private bribes, for example, they are not allowed to hand over bribes directly, at the instructions of the person who offers the bribe or the one who receives the bribe, or to help in any other way. when obtaining or reaching an agreement between them to receive or to give a bribe.

The company's internal policy is correlated with the entire framework of compliance with national and supranational legislation (financial accounting policies, policies to prevent and combat money laundering and terrorist financing, policies on the application of international sanctions).

In accordance with the Company's Anti-Bribery and Anti-Corruption Policy, it does not fund, sponsor, or participate in any charitable and/or sponsorship activities to receive any illegal privileges or business preferences.

Tradesilvania SRL will cooperate with the authorities that have responsibilities in preventing and combating fraud and corruption.

All financial operations of the company associated with a sponsoring activity or charitable activity are shown in detail and in confidence in the books; monitoring of procedures for charitable contributions allows a person to satisfy himself to the highest degree of certainty that such contributions do not constitute a disguised bribe.

Core principles

Zero tolerance for corruption: Committing or attempting to commit acts of corruption is forbidden regardless of the way they are carried out and whether they are committed directly or indirectly. Tradesilvania SRL does not tolerate its involvement in corruption acts, of its employees or of third parties with whom it is in any way involved.

Tone from the top: The company's management establishes a high standard of ethical behavior among its employees and clients and shows a non-compromising attitude toward any forms and manifestations of corruption, part of corporate culture, and daily business practices within the company.

Continuous monitoring of legislation and good practices in the field: The company strictly observes all changes made to the normative requirements of the applicable anticorruption laws and the practices through which they are implemented.

Political contributions: The company does not finance, support, or encourage in any way political parties or members, including candidates for political offices, their election campaigns or political events, or political organizations or movements. Political donations, in any tangible form or not, are completely banned.

Whistleblowing

To detect any possible acts of corruption, any conduct that might violate legal provisions, or any violation of the principles outlined by the anti-bribery and anti-corruption policy or other internal regulations, the Company relies on its own employees, clients, partners and other third parties with whom there is a business relationship and encourage them to report any suspicion or concern about corruption immediately. In this respect, the Company provides a secure channel for reporting unacceptable conduct – Whistlebllowing accessible on the company’s website for the communication of a written message through the electronic form.

The form is available on https://tradesilvania.com (here) and allows for the submission of nominal or anonymous complaints. In all cases, the incident must be described in detail so that it can be investigated.

The Company shall guarantee the full confidentiality of the identity of the reporting person, where permitted by applicable law, as well as absolute protection against discrimination or actions against the notifying person. The same level of attention is given to anonymous reports.

Persons using the privilege of anonymity should avoid making reports containing false and/or misleading information. The role of anonymous reports is to contribute to the identification of some people's inappropriate behavior and to the correction of the negative consequences that such behavior may have on Tradesilvania SRL.

Complaints/notifications regarding violations of laws on bribery (given or taken) and corruption sent through company communication channels are collected by a specialized team.

Third Parties

The company has no business relations and avoids relations with third parties known or suspected of giving and taking bribe and/or corruption. To this end, the Company shall apply due diligence procedures to certain third parties, including verification of their name and integrity. The company will not enter into business relations with new third parties unless they have been validated following due diligence or EDD where appropriate. ABC questionnaire - third parties is part of the due diligence process and is completed by the third party prior to the start of the (potential) business relationship with the Company and/or whenever necessary.

Once the Company has entered in a business relationship with a third party, it will continue to monitor the business relationship with that third party and will determine, where appropriate, whether to put in place risk mitigation controls, such as monitoring of expenditure activity (including carrying out an audit, if justified) and the requirement to refresh the due diligence process.

No person working for Tradesilvania SRL will accept that a third party (client, business partner, etc.) offer or receive bribes on his behalf.

Risk Assessment

Periodically, the Company implements measures to highlight and reduce corruption risks and also assesses the effectiveness of the current anti-corruption compliance system.

Continuous monitoring and reporting

Continuous monitoring is essential to ensure that ABC policy continues to function properly and effectively mitigates any evolving risks. For this purpose, the Company provides a clear responsibility for the continuous monitoring of various aspects of ABC policies.

Sanctions

Breaking the content of this document by Tradesilvania staff or business partners can trigger civil liability and the obligation to repair the resulted damage.

Audit and Control

Periodically, the Company undertakes internal and external audits of its financial and business activities and shall also conduct ongoing controls to ensure that all business operations are complete and clear in journals and records, as well as compliance with the requirements laid down in the applicable law and the company's internal normative documents, including the principles and requirements set out in the anti-bribery and anti-corruption policy.