Anti-Bribery Policy

Comprehensive policies and procedures to prevent, detect and address bribery and corrupt practices in all forms of business conduct.

PREVENTION SYSTEM

Detect • Prevent • Respond • Improve

Our Commitment

3DMoose is committed to conducting business with integrity and transparency. We strictly prohibit bribery in any form and have implemented robust systems to prevent, detect and respond to any instances of bribery or corruption.

This policy applies to all employees, directors, officers, agents, contractors, suppliers, joint venture partners and anyone acting on behalf of 3DMoose worldwide.

Types of Prohibited Bribery

Direct Bribery

Directly offering, giving, requesting or accepting anything of value to influence business decisions

Indirect Bribery

Using third parties, intermediaries or family members to provide or receive improper benefits

Commercial Bribery

Improper payments to private sector employees or agents to gain unfair business advantage

Facilitation Payments

Small payments to expedite routine services or actions that one is legally entitled to receive

Red Flags and Warning Signs

Be Alert to These Warning Signs:

Requests for cash payments or payments to bearer accounts
Unusual payment methods or routing through third countries
Reluctance to provide invoices or proper documentation
Excessive commission rates or consulting fees
Close relationships with government officials
Reputation for paying bribes or operating in high-risk countries
Requests for political or charitable donations as contract conditions
Unusual invoicing practices or billing for unspecified services

Report Immediately: If you encounter any of these red flags, immediately report them to the Compliance Officer and do not proceed with the transaction.

Due Diligence Requirements

Before engaging with any third parties, business partners, or intermediaries, we conduct comprehensive due diligence to assess bribery and corruption risks.

Financial Verification

Bank account verification and ownership confirmation
Financial statements and credit history review
Source of funds and wealth verification
Tax compliance and payment history

Legal & Regulatory

Company registration and licensing verification
Sanctions and watchlist screening
Litigation history and regulatory violations
Beneficial ownership and control structure

Reputation & Integrity

Media searches and adverse publicity review
Industry reputation and peer feedback
Ethics and compliance track record
Previous bribery or corruption allegations

Third Party Management

Contractual Requirements

  • Mandatory anti-bribery clauses in all contracts
  • Right to audit and inspect third party records
  • Termination rights for policy violations
  • Regular certification of compliance requirements

Ongoing Monitoring

  • Annual re-certification of anti-bribery compliance
  • Periodic risk assessments and due diligence updates
  • Transaction monitoring and expense reviews
  • Regular training and awareness programs

Training and Awareness Program

Comprehensive Training Framework

New Employee Training

Mandatory anti-bribery training within 30 days of employment

Annual Refresher

Updated training covering new risks and regulatory changes

Role-Specific Training

Enhanced training for high-risk positions and regions

Reporting and Investigation

Multiple Reporting Channels

We encourage the reporting of suspected bribery or corruption through various channels. All reports are investigated promptly and confidentially.

Compliance Email
compliance@3dmoose.com
Confidential Hotline
+372 609 4167

Anonymous Reports

Identity protection guaranteed

No Retaliation

Protection against reprisals

Prompt Investigation

Thorough and fair process

Last Updated: December 19, 2024

This anti-bribery policy has been approved by the 3DMoose Board of Directors and is binding for all employees and business partners.

3DMoose is a brand of ENSTITÜ OÜ (Registration: 14850305, VAT: EE102444771)

Questions or Concerns?

If you have questions about this anti-bribery policy or need clarification on specific situations, please contact our Compliance Officer at compliance@3dmoose.com.