1. Purpose
This policy sets out Hybrid Core BV's commitment to preventing bribery and corruption in all its forms. It provides clear guidance on what constitutes bribery and corruption, the obligations of all individuals connected to the company, and how suspected incidents should be reported.
2. Scope
This policy applies to all employees, directors, contractors, agents, and third parties acting on behalf of Hybrid Core BV, in all countries and contexts in which the company operates. It applies to interactions with both private sector counterparts and public officials, including personnel from European Union institutions and member state government bodies.
3. Policy statement
Hybrid Core BV has a zero-tolerance approach to bribery and corruption. We will not offer, give, request, or accept any financial or other advantage intended to improperly influence a business decision or secure an unfair benefit. This position applies regardless of local practice, competitive pressure, or the perceived insignificance of the amount involved.
The company is committed to compliance with applicable anti-bribery and anti-corruption legislation, including the Belgian Criminal Code, the OECD Convention on Combating Bribery of Foreign Public Officials, and the anti-fraud provisions applicable under EU-funded programmes.
4. Principles
4.1 Prohibition on bribery
No employee or person acting on behalf of Hybrid Core BV may:
- Offer, promise, or give a bribe to any person or organisation, whether in the public or private sector
- Request, agree to receive, or accept a bribe
- Arrange or participate in a bribe through a third party
- Fail to prevent bribery where they had the means and authority to do so
4.2 Facilitation payments
Facilitation payments - unofficial payments made to public officials to secure or expedite routine actions - are prohibited regardless of local custom or legal status in the relevant jurisdiction.
4.3 Gifts and hospitality
Gifts and hospitality are acceptable only where they are modest, transparent, and consistent with normal business practice. They must not be offered or accepted in circumstances where they could reasonably be interpreted as an attempt to influence a decision. The following rules apply:
- All non-trivial gifts and hospitality received or offered must be recorded
- Cash gifts and gift vouchers must never be offered or accepted
- Gifts or hospitality offered to or by public officials require management approval in advance
- Any gift that creates a sense of obligation must be declined or returned
4.4 Political contributions
Hybrid Core BV does not make direct or indirect contributions to political parties, candidates, or campaigns. Employees must not use company resources for political purposes.
4.5 Charitable donations and sponsorships
Charitable donations and sponsorships may be made where they are legitimate, proportionate, and properly documented. They must never be used as a mechanism to disguise a bribe.
4.6 Due diligence on third parties
Appropriate due diligence must be conducted before engaging agents, intermediaries, or business partners in higher-risk contexts. Third parties involved in procurement, sales representation, or public sector engagement must confirm their acceptance of the company's anti-bribery standards.
5. Responsibilities
5.1 Management
The management team is responsible for setting the tone for ethical behaviour, ensuring adequate anti-corruption controls are in place, approving any borderline gifts or hospitality, and investigating any suspected incidents of bribery or corruption.
5.2 Employees
Every employee is responsible for understanding this policy, refusing any bribe or improper inducement they are offered, reporting any suspicion of bribery or corruption promptly, and cooperating fully with any investigation.
5.3 Finance function
The finance function is responsible for maintaining accurate books and records that reflect all transactions transparently and for ensuring that no payments are made to fictitious or undisclosed parties.
6. Reporting and compliance
Suspected bribery or corruption must be reported promptly to management or via the Whistleblowing Policy. Hybrid Core BV will investigate all credible reports and take appropriate action. Where required, incidents will be reported to the relevant regulatory or law enforcement authorities, including the European Anti-Fraud Office (OLAF) in the context of EU-funded projects.
Employees who breach this policy may face disciplinary action up to and including dismissal. Third parties who breach this policy may have their contracts terminated. Hybrid Core BV will not retaliate against anyone who reports a concern in good faith.
7. Monitoring and review
This policy is supported by appropriate internal controls, record-keeping requirements, and periodic risk assessments. Compliance will be reviewed through internal audits and management oversight. The policy will be updated as necessary to reflect changes in applicable law or business operations.
8. Communication and awareness
All employees will receive training on this policy as part of their induction and on a regular basis thereafter. The policy is published on the company's internal systems and made available to relevant third parties on request.
9. Review cycle
This policy is reviewed every two years by the Hybrid Core Management Team or sooner if required by legislative changes or material changes in business activities.
10. Version control
Version: 1.0
Owner: Hybrid Core Management Team
Approved by: Hybrid Core Management
Effective Date: 01.06.2026
Review Period: Every 2 Years