Anti-Corruption
and Compliance Policy
ATOGEN is committed to sustainable growth as a global company by fostering a corporate culture built on integrity and trust, and by practicing ethical and transparent management. To this end, ATOGEN hereby establishes and declares its Anti-Corruption and Compliance Policy.
1.
The Company and its employees shall comply with all applicable domestic and international compliance obligations.
2.
The Company applies a zero-tolerance policy toward violations of compliance obligations, including corrupt practices by employees.
3.
The Company shall continuously operate and improve a Compliance Management System designed to achieve the objectives of anti-corruption and compliance management.
4.
The Compliance Officer shall have the authority and independence necessary to operate the Compliance Management System and shall have the obligation to report directly and regularly to the governing body.
5.
Employees shall neither offer nor accept any improper benefits, including money, entertainment, or bribes, to or from business stakeholders.
6.
Employees are responsible for managing compliance issues and reporting them to the Compliance Officer.
7.
If employees become aware of any compliance violations, including corrupt practices, they must immediately report them to the Company. The Company guarantees the anonymity of whistleblowers and the confidentiality of reported information and protects whistleblowers from any disadvantage or retaliation resulting from such reports.
8.
If employees violate compliance obligations or fail to take reasonable measures to prevent known violations, the Company shall not assume liability on their behalf and may take disciplinary action in accordance with Company regulations.