Integrity, Anti-Corruption and Conflict of Interest Policy

Version: January 2025

At Lerian-Online, we believe in working together in an honest, transparent and professional way. Integrity is an essential part of how we operate every day. This policy outlines our commitments regarding anti-corruption, fraud prevention and the avoidance of conflicts of interest.

We apply a zero-tolerance policy towards any form of corruption, bribery or improper influence. This applies to all our activities: sales, administration, planning, training assignments and relations with suppliers.

Our commitments

• Bribes, improper payments or advantages in exchange for contracts are strictly prohibited.
• Employees must report any attempt to offer inappropriate advantages or any form of external pressure.
• Gifts or invitations from clients or suppliers are only allowed when they are modest, occasional and reasonable.
• Commercial and operational decisions are always based on quality, professionalism and objective criteria.
• Any suspected irregularity is investigated without delay.

We take measures to avoid any form of financial or administrative manipulation. Transparency and accuracy in all processes are essential.

Our commitments

• Invoicing, financial transactions and supplier management follow defined internal procedures.
• Documents may not be altered or falsified.
• Fraud, deception or attempts to manipulate information are strictly prohibited and will be investigated immediately.

We avoid situations where personal interests could influence professional decisions.

Our commitments

• Employees must report any potential conflict of interest, including side activities or personal relationships with clients or suppliers.
• Private assignments for Lerian-Online clients are not allowed unless approved in writing beforehand.
• All decisions must be made in the interest of the company and the client, never for personal benefit.

New employees receive information about this policy during their onboarding. The policy is shared internally and reviewed regularly.

Employees can raise questions or report concerns to:

• their direct manager,
• the internal prevention advisor,
• or the managing director.

All reports are handled discreetly and carefully.

Lerian-Online is committed to maintaining a professional environment where integrity, transparency and responsibility are the norm. This policy supports an ethical and reliable way of working for everyone.