Anti-Bribery & Corruption Policy

It is part of Pochmak policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate, and implementing and enforcing effective systems to counter bribery. Pochmak expects the same approach from all those with whom we do business.

What is bribery?

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

Bribery includes:


This policy applies to all Pochmak’s employees and associated people acting on behalf of Pochmak, and extends to our business dealings in all jurisdictions within which we operate.


Pochmak does not engage in bribery or corruption. It is contrary to our policy for any employee or third party acting on behalf of Pochmak to request, offer, solicit, make or receive any payments or inducements which are illegal, unethical or represent a breach of trust. Pochmak respects all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate, particularly laws that are directly relevant to specific or local business practices. Pochmak will not do business with any person or company which we know (or have reasonable grounds for suspecting) engages in bribery or corruption.


Each Pochmak employee receives training in respect of this policy and it is the responsibility of each Pochmak employee to ensure compliance with the terms of this policy. If any employee believes that the terms of this policy are not being correctly adhered to then they should seek to raise their concerns with their line manager as soon as possible.


Compliance with this policy will be subject to regular review and audit, to ensure it remains suitable, effective and proportionate having regard to Pochmak’s operations and the jurisdictions within which we operate. Any concerns raised by any person relating to any alleged non-compliance with the terms of this policy will be immediately investigated and, if appropriate, action will be taken. Failure to observe the terms of this policy may constitute a disciplinary offence and may expose individuals to civil or criminal proceedings.