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We conduct our business in an ethical and lawful manner and act with integrity and in compliance with all applicable laws. We do not participate in or knowingly benefit from, any kind of corruption, extortion or bribery.

The purpose of this description is to give Comtec Carl Backs employees a practical introduction to Comtec Carl Backs's policy on anti-corruption. The policy also covers the rules for the conditions, under which Comtec Carl Backs offers gifts and entertainment, as well as when a Comtec Carl Backs employee may receive gifts and entertainment from customers and suppliers.

The policy aims to ensure a basic understanding of how the policy affects Comtec Carl backs's business activities, so that we continue to live up to our intention to conduct business in a fair, honest and transparent way.

Corruption, bribery and greasing may pose risks in connection with our activities and could have serious legal consequences for the company and the individuals involved. This could also cause damage to Comtec Carl Backs's reputation and the values we stand for.

We will not accept any form of corruption, bribery and greasing and has in that regard introduced a zero-tolerance policy.

This means, that Comtec Carl Backs is ready in bypassing contracts if a condition is made that bribes are granted in order to obtain these.

The management of Comtec Carl Backs considers this a serious violation of the individual’s liability, if he or she contributes to corruption, bribery or greasing, which can lead to employment law implications and legal action.

A risk analysis will be performed annually to ensure, that we continuously live up to our anti-corruption policy.


Comtec Carl Backs has a zero-tolerance policy, when it comes to corruption, bribery or greasing. We have the policy to comply with the Danish Criminal Code and the UK Bribery Act in Europe. In addition, we comply with anti-bribery laws in the countries we operate in. The following applies:

  • Individuals who work in or for Comtec Carl Backs must never offer, give, request or receive any illegal or improper donations or other payments or benefits to achieve commercial advantage or private benefits for yourself or others
  • No individual will be demoted or punished in other ways for refusing to give or receive bribes and greasing, even if it may result in loss of business opportunity for the company
  • No individual will be demoted or punished in other ways for having expressed suspicion or provides notification of corruption, bribery or greasing
  • Comtec Carl Backs accepts no retaliation against persons who express suspicion or gives notification of corruption, bribery or greasing. This may have employment law consequences for the provider of the retaliation.

The Board of Directors has unanimously approved these principles.


This policy applies to all individuals working in Comtec Carl Backs, anywhere in the world. Subjects include all employees, officers or other representatives of the company, regardless of type of employment.

Comtec Carl Backs requires, that partners/third parties who perform services for or on behalf of the company adhere to Comtec Carl Backs's anti-corruption policy and applicable laws.

The same applies, when trading with or on behalf of Comtec Carl Backs.

Upon agreement with partner/third parties it is the manager of that area, whom is responsible for securing evidence that partner/third parties have agreed to abide by this policy. The written agreement with partner/third party contains the right to termination, if they act contrary to this policy.



Corruption is defined as "the abuse of entrusted power for private gain"1. This definition includes both economic and non-economic benefits.
Corruption can be expressed in many ways and it is not always easy to discover or identify, when it occurs in daily activities.
If you are in doubt, you should always consider the following:

  • Transparency: Do I mind, if others find out what I've decided?
  • Impact: Does my decision have an inappropriate influence on a process or a person?
  • Justice: Would a reasonable person consider my decision to be fair?

If you are unsure, and if this policy does not answer your questions, you should always ask/seek advice before taking any action. You can always ask your questions to the Group CEO or your HR department.


Bribery is defined as "a payment that aims to get someone to do something that is dishonest, illegal or in breach of his duties with the purpose of obtaining an undue advantage “2.
There are many forms of corruption, such as:

  • Cash- or cash assimilated vouchers.
  • Travel and entertainment activities.
  • Gifts, that have a significant value.
  • Payments disguised as consulting fees, commissions, sponsorships or contributions to charities or political parties, if the real purpose is to influence a decision in an improper way.
    It is illegal to bribe someone in this way, even if it is done through a third party (eg consultant, agent or intermediary). It is also illegal to protrude against such bribery.


Greasing, also known as facilitation payment is a variety of bribery, typically with a smaller amount, which aims "to secure or expedite an action to which the payer is legally or otherwise (legally) entitled to”3.
You must be aware, that greasing may be customary in a particular country. If you are likely to suffer harm if no payment is made, do the following:

  • Refuse the payment and if unavoidable, keep the payment to an absolute minimum amount of cash.
  • Compile a detailed record of the transaction.
  • Immediately inform the manager/company's highest body. The record shall be available for Comtec Carl Backs finance department and accountant.

This example could be paying an official to get goods quickly through customs.
Greasing should not be confused with blackmail, which typically may involve substantially larger amounts.

GIFTS & representation

A gift is characterized by the fact, that one does not expect anything in return. Entertainment or gratuities consists of events and services, that a company offers to existing or potential customers and partners in order to establish or strengthen its business relationships. Entertainment may consist of dinners, invitations to social events, free transportation or the like.

Depending on the business relationship, gifts and entertainment may be widespread.

Comtec Carl Backs accepts the giving and receiving of gifts in a modest extent, which means, that the recipient is not required to return the favor. The same applies to offering and receiving business or social events.

Be aware, that the tolerance threshold for gifts and entertainment is very low in the public sector.

What you may and may not do:

  • Never receive and never give donations (cash or liquid assets)
  • Only gifts, that have a modest value and are customary in that country or region, and which serve a business purpose, can be given or received
  • Occasional gifts of modest amounts may be given and received, for instance for christmas, birthday, anniversary or retirement
  • Gifts should under no circumstances be given or received in exchange for a promise of action or as part of the tender procedure or contract. This applies regardless of whether the recipient is not directly involved in the decision and whether it is given to one of the employee's related family members.
  • Personal discounts cannot be accepted, if such discounts are not given to all employees. The agreement must be approved by the Comtec Carl Backs CEO.
  • All gifts and business courtesies must be recorded and reported to the CFO and be available for the company's audit.


Political Contributions:

Contributing to one or more politicians, an election campaign or political party can be seen as attempts to achieve business benefits and can not be accepted in Comtec Carl Backs.

Charitable Contributions & Sponsorships:

Donations to charity, which is beneficial to help those in need are acceptable, if they reflect Comtec Carl Backs's values, and there is an economic basis.
The amount is determined in relation to its purpose and it must never serve as an incentive to do business.
Sponsorships, with the support aims to serve a business purpose are accepted.
Donations and sponsorships must be approved by the Comtec Carl Backs CEO.
Donations and sponsorships must be recorded and reported to the CFO and be available for the company's audit.


Comtec Carl Backs assumes a risk by purchasing goods from countries worldwide. We must therefore ensure, that we only work with suppliers, whose ethical standards are consistent with Comtec Carl Backs's standards. This policy also applies to our suppliers.
Therefore money or anything else of value must not be received by a possible supplier, if the conditions indicate, that this wholly or partially will be used directly or indirectly to influence a decision or secure an improper advantage.
A thorough assessment of suppliers must be conducted, before this is approved. When entering into an agreement with the supplier, is the team leader for procurement, whom is responsible for securing evidence, that the supplier has agreed to abide by this policy.
All communication with the supplier must be documented.
The written agreement with the supplier has the right to termination, if the supplier acts in violation of this policy.
The supplier may not delegate or subcontract tasks to a third party, not approved by Comtec Carl Backs.


Comtec Carl Backs commits to to ensure, that employees can report any suspicion in full confidentiality. All reviews are taken seriously and are investigated.

If you are offered or requested to engage in corruption, bribery or greasing, or if you suspect that there has been corruption, bribery or greasing or other breach of this policy, you must immediately notify Comtec Carl Backs's CEO or HR department. Both are obligated to inform the board about incoming reports.
Each report is treated separately for analysis and corrective actions.


The Board of Directors is responsible for approving Comtec Carl Backs's anti-corruption policy.

The operational responsibility and supervision are delegated to Comtec Carl Backs's CEO.

The HR department carries out regular internal audits.

HR is, together with the Director, responsible for ensuring, that this policy is sufficiently effective, and that the necessary improvements will be made.

Incidents and reports of breach of the policy, will be reported on the board meetings.


The Anti-corruption policy is after the board's approval presented to all employees, who signed the addendum to their contract in which they agree to abide by the guidelines listed in the policy.

All new employees will in conjunction with the signing of their contracts also sign a declaration to abide by the listed guidelines in the policy. To ensure, that the anti-corruption policy is understood, it is discussed along with the new staff induction program.