Introduction
Bribery and corruption are criminal offences under applicable Cyprus law. P1 (“P1”, “we”, “us”) is committed to preventing bribery and corruption in all forms.
We take a risk-based and proportionate approach that reflects the nature and scale of our business. This policy sets out how P1 identifies, manages, and mitigates bribery and corruption risks.
At a high level, we will:
ensure senior management leads our anti-bribery stance
identify, assess, and monitor bribery risks on an ongoing basis
consider bribery risks in all business relationships
conduct ongoing monitoring of compliance
communicate our anti-bribery expectations clearly
provide training to staff and associated persons
supply relevant management information to leadership
2. What is a Bribe?
A bribe occurs when a person associated with P1 offers, gives, requests, or receives something of value with the intention of obtaining or retaining business or a business advantage.
“Associated persons” include:
employees
contractors
suppliers
agents
partners
any person performing services for or on behalf of P1
Bribery is assessed based on whether a reasonable person would view the conduct as improper.
2.1 Facilitation Payments
P1 prohibits facilitation payments of any kind. The only exception is where there is an immediate and unavoidable risk to life, liberty, or safety.
2.2 Corruption
Corruption includes dishonest or fraudulent conduct by those in power, typically involving bribery. P1 remains alert to the risk of being used to facilitate corruption, including by politically exposed persons (PEPs).
3. Penalties for Bribery and Corruption
Bribery and corruption offences may result in:
criminal prosecution
fines
imprisonment
termination of employment or contracts
All employees and associated persons must comply with this policy.
4. Who Must Comply?
This policy applies to:
all employees
senior management
contractors and temporary staff
agents and associated persons
Breaches will be dealt with seriously and may result in disciplinary action.
5. Senior Management Commitment
P1’s Board is responsible for our anti-bribery stance. Day-to-day responsibility is delegated to the designated Risk Officer, who oversees:
staff training
vetting of new and existing staff
monitoring of anti-bribery controls
gifts and hospitality registers
due diligence on third parties
reporting to senior management
6. Policy Statements
P1 is committed to preventing bribery. We will:
ensure all staff understand their responsibilities
remain aware of bribery risks
provide regular training
assess bribery risks periodically
maintain high standards of conduct
avoid engaging with third parties linked to bribery
conduct proportionate due diligence
communicate our anti-bribery stance clearly
monitor compliance on an ongoing basis
7. Risk Assessment
P1 uses a dynamic, risk-based approach to identify and assess bribery risks. We consider both internal and external factors, including:
jurisdictions where we operate
nature of business relationships
staff training and controls
gifts and hospitality practices
financial controls
transparency and governance
8. Due Diligence
P1 conducts due diligence on all associated persons.
8.1 External Associated Persons
For suppliers, contractors, and partners, we may conduct:
background checks
media checks
review of their anti-bribery policies
contractual clauses allowing termination for bribery
9. Communication and Training
P1 regularly communicates its anti-bribery expectations internally and externally. All staff receive annual anti-bribery training.
10. Monitoring and Review
We conduct ongoing monitoring, including:
annual compliance reviews
review of gifts and hospitality
review of due diligence on third parties
periodic reassessment of risks
Findings are reported to the Board.
11. Responding to Bribery Events
11.1 Internal Events
If bribery is identified internally, P1 will investigate and take appropriate action, including disciplinary measures or termination.
11.2 External Events
P1 monitors industry best practices, regulatory guidance, and international anti-corruption standards to ensure our policy remains appropriate.
12. Gifts and Hospitality
Staff may not offer, give, solicit, or accept any gift or benefit that:
could be seen as a bribe
creates a conflict of interest
breaches P1’s standards or applicable law
P1 maintains strict guidelines and approval procedures for gifts and hospitality.