ASG Cert-GmbH | Anti-Corruption and Bribery Policy

ASG Cert GmbH, with its registered office at Innere Wiener Straße 30, 81667 München (Handelsregister Augsburg HRB 306207), under the leadership of Managing Director Pedro F. Pitzinger, is unwavering in its commitment to lawful, honest and transparent business practices. We fully comply with all applicable anti-corruption and anti-bribery laws, including the U.K. Bribery Act and the U.S. Foreign Corrupt Practices Act, and we prohibit any form of bribery, whether involving public officials or private parties.

No director, officer, employee, contractor, consultant or agent of ASG Cert may offer, promise, give, solicit or accept a bribe—directly or indirectly—to obtain or retain business or to secure any improper advantage. Facilitation payments—small sums paid to expedite routine government actions—are likewise banned, even where they are customary; any request for such a payment must be reported immediately. We also forbid any alteration of documents, misrepresentation of evidence or other acts of audit fraud: clients or third parties found engaging in such behaviour will be held responsible for all costs of investigation and may face contractual penalties.

In certain limited circumstances, token gifts of nominal value—such as branded pens or calendars—and modest business hospitality—like reasonable lunches or event invitations—are permissible, provided they are unsolicited, infrequent, not tied to any expectation of favour, pre-approved by our Finance function and compliant with local law. All personnel must record such gifts and hospitality in our central register.

Any actual or suspected breach of this policy—be it a corrupt request, a facilitation-payment solicitation or evidence of audit fraud—must be reported without delay to the Managing Director or via our confidential whistle-blower channel at mail@asg-cert.com. We treat all reports with strict confidentiality, and we forbid retaliation against anyone who reports in good faith. All allegations will be investigated promptly and impartially.

To ensure ongoing compliance, ASG Cert provides regular training on anti-corruption and anti-bribery obligations to all employees and relevant third parties. Management reviews the effectiveness of this policy at least annually, updating it as necessary to reflect changes in law or business practice. By adhering to these principles, ASG Cert GmbH safeguards its integrity, protects its stakeholders and upholds the highest ethical standards in every aspect of its work.

 

Sincerely Yours,
Pedro Francisco Pitzinger
ASG Cert GmbH Director