Anti-corruption policy of SSARM Ltd.

  1. Goal

    SSARM Ltd. opposes all forms of corruption and declares zero tolerance for bribery.

    Scope of application

    All employees of SSARM Ltd., as well as any person related to the company who provides services on behalf and at the expense of the company, including subcontractors, their staff and business partners, are obliged to comply with this policy.

    Failure to comply with it may result in disciplinary action being taken, which (depending on the case) could lead to termination of employment with an employee or termination of contractual relations with a third party.

    Corruption means any kind of bribery; offering, giving, promising, or agreeing to give, offer or accept money, assets or other improper benefits from government officials, state sectors, private sectors or responsible persons either in direct or indirect activity so that such person may continue or neglect his/her function in order to acquire, retain business, recommend a particular enterprise to the company, or obtain improper benefits in a business transaction.

    Main risks and anti-corruption measures


    The bribe can be in the form of money or a physical object, a service, a contribution to a charity. Bribery can also take the form of inappropriately generous or repeated hospitality.

    Public bribery

    Public bribery is the bribe given to a public official. Gifts and hospitality, which may be quite acceptable to private individuals, are completely inappropriate and dangerous in the case of a public servant.

                       3.1.2     Commercial bribery

    Commercial bribery is a case of bribing a private person.

    SSARM Ltd. is guided by the principle that any other company relies on its employees to act in its interest, and bribery undermines this moral obligation.

    Any action that leads to unscrupulous behavior of an employee or to the breach of trust for his employer or management can be considered a commercial bribe.

    The employees of SSARM Ltd. have no right to offer, promise or gift value to another person with the purpose of inducing or rewarding this person for improper performance of his function in relation to his employer or management.

    Commercial bribery is an inducement to violate a person’s obligations to his company.

    The employees and partners who act on behalf and at the expense of SSARM Ltd. cannot offer, provide, request or accept any advantages and benefits intended to influence the decision-making of other persons with a view to the achievement of a business goal.

    3.2 Payment for facilitation of formalities

    A facilitation payment is the provision of small sums to secure or speed up a certain process. Payment for the facilitation of formalities is prohibited in SSARM Ltd.

    3.3 Business gifts

    Offering, giving, or receiving any gifts of modest value is not considered a form of bribery.

    Offering, giving, or receiving cash or cash equivalents is prohibited in SSARM Ltd.

    It is the responsibility of those offering or accepting a gift to decide whether the gift is appropriate and of adequate value.

    3.4. Events and meetings

    Organizing events and meetings with clear business objectives, such as business lunches and other professional meetings that require modest and reasonable expenses, do not qualify as a form of corruption.

    It is prohibited to organize or accept invitations to expensive or extravagant events by our employees and partners acting on our behalf and at our expense.

    The organizer or the invited person must check that the event does not violate any of the above rules. Travel, accommodation, and other related expenses must be paid by the invited party in all cases.

    3.5. Relations with the public sector

    In all cases, attention should be paid when dealing with public officials and persons holding public posts.

    3.6. Political donations

    The company prohibits making donations to political parties or officials to obtain their support for executive, legislative, administrative, or other actions that may be favorable to SSARM Ltd.

    Roles and responsibilities

    The manager of SSARM Ltd. is responsible for defining the policy, monitoring, and forming an effective system supporting anti-corruption behavior to cultivate anti-corruption mindset as a company culture.

    The employees of SSARM Ltd. may be legally responsible for the actions of partners, suppliers or other third parties, even if SSARM Ltd. has not committed any violations, it may be exposed to legal actions and undermining its prestige.

    The employees of SSARM Ltd. are aware of the potential risks associated with the use of third parties and adequate verification is carried out before engaging them.

    The principle of checking in proportion to the degree of risk that exists in the specific circumstances is observed.


    Business gifts and hospitality


    Giving gifts, organizing entertainment, or providing hospitality to other people to influence a third party to act favorably towards SSARM Ltd. is not allowed under any circumstances.

                  5.1.2. All gifts, entertainment or hospitality provided to public officials must be approved in advance by the Manager, and after their implementation must be documented by the Coordinator of the Anti-corruption Commission at SSARM Ltd. in the register provided for the purpose.

                  5.1.3. Gifts, entertainment, and hospitality in general, whether in the public or private sector, must be of reasonable value, decent in nature or in terms of place, and intended for a legitimate relationship.

                  5.1.4. Gifts that are unsolicited and of small value may be given either on a festive occasion (for example, on New Year’s holidays or other holidays) or on a special occasion (wedding, birth of a child, retirement, funeral) when non giving or not accepting a gift would be seen as impolite or rude. Such gifts must be previously authorized and approved by the Management of SSARM Ltd.

                  5.1.5. The management of SSARM Ltd. pays reasonable representative funds according to pre-approved costs by the Manager for each specific case.


    Employees of SSARM Ltd. at every level must be familiar and comply with the Anti-Bribery Policy by avoiding direct or indirect participation in a corruption process.

    All employees must notify designated officials at SSARM Ltd. of bribery/suspicion of bribery.

    A person who has committed an act of bribery is subject to disciplinary sanctions in accordance with the internal standards of SSARM Ltd.

    SSARM Ltd. supports the distribution of information, sharing of knowledge and communication with third parties that are involved with or influence SSARM Ltd., so that these parties comply effectively with the fight against bribery.

    The manager of SSARM Ltd. is committed to guaranteeing tolerance and security of the persons who reported bribery.

    Charitable contribution or aid

    Granting or receiving aid is decided on a case-by-case basis, it is applied transparently and in accordance with established laws, demonstrating that this transaction will not be considered an act of bribery.

    Business relations and the procurement process in the public sector

    All types of bribery or illegal payments are prohibited in all SSARM Ltd. business transactions and government relations. The participation of SSARM Ltd. in public tenders is carried out transparently and in full compliance with the relevant laws and regulations.


    When an employee has become subject of a bribery attempt, or knows or has a reasonable suspicion of bribery, he should inform the Coordinator of the Anti-Bribery Commission or directly the Manager of SSARM Ltd.

    Such reports will always be treated with strict confidentiality, so those reporting these matters will always be protected by the management of SSARM Ltd. Suppliers, subcontractors, consultants, and other contractors of SSARM Ltd., who become the subject of an act of bribery by an employee of the company or know or have reasonable suspicions about corrupt practices in its activity, can report the case by means of a written report or complaint, submitted according to the order of communication established in SSARM Ltd. – on the website or directly by using both forms.

    Final provisions

    The observance and implementation of this Policy is in accordance with the applicable law, and the Bulgarian Criminal Code, according to which both active and passive bribery is prohibited and can be classified as a crime.

    SSARM Ltd. takes serious measures against those who violate the rules. The strictest disciplinary measures will be applied to such violations.

    This Policy applies when new business relationships are established, through the creation of joint ventures/consortia or relationships with new customers and suppliers.

    In such new relationships, SSARM Ltd. requires a careful judgment regarding the ethical behavior and reliability of each business partner. This Anti-Bribery Policy is reviewed regularly to assess its relevance and to keep it in line with changes in business, regulation, standards, and laws.


    Violations of this Policy may result in disciplinary action against an employee, including termination of an employee’s contract and termination of business relationships in the case of a third party.

    SSARM Ltd. has the right to alert the law enforcement authorities if the assessment of the situation requires it.

    Violations of anti-bribery laws may subject individuals to civil and criminal penalties, including fines and imprisonment.

    Evidence of deliberate non-reporting/concealment of alleged violations of this Policy is considered with extreme seriousness by the Management of SSARM Ltd.

    It is possible to make a complaint to a dedicated email address on the website, but always keep in mind that anonymous complaints are more difficult to investigate.

    The designated e-mail of the authorized officer for reports of corruption or suspicion of corruption is available on the website http://ssarm.bg/.

    For the purposes of implementing the current anti-corruption policy, an anti-bribery management system has been introduced in SSARM Ltd. in accordance with the requirements of the International Standard EN ISO 37001:2016, according to which we define anti-bribery objectives, promote concern and involvement in the fight against bribery based on a reasonable belief in trust, without fear of repressions.

    The management of SSARM Ltd. supports the authority and independence of the Anti-Bribery Compliance Commission!

    We, the Managers of SSARM Ltd., Nikolay Paunov and Nikolay Dimchev, hereby declare our personal commitment to compliance with the requirements and continuous improvement of the anti-bribery management system!