Defence Armament OÜ, registry code 17555647, registered in the Republic of Estonia, European Union, trading as Defence.us

Purpose

At Defence.us, we are committed to conducting business with honesty, integrity, and transparency. We maintain a zero-tolerance approach to bribery, corruption, fraud, and unethical business practices in all our operations, regardless of where we conduct business.

This Anti-Bribery & Corruption Policy establishes the standards expected from our employees, management, business partners, suppliers, distributors, consultants, contractors, and any third party acting on behalf of Defence.us.


Our Commitment

We are committed to:

  • Conducting business ethically, fairly, and transparently.
  • Complying with all applicable anti-bribery and anti corruption laws and regulations in the countries where we operate.
  • Preventing bribery, corruption, facilitation payments, kickbacks, and any improper financial or non-financial advantage.
  • Maintaining accurate financial records and internal controls.
  • Promoting a culture of integrity and accountability throughout our organization.

Scope

This policy applies to:

  • Directors
  • Officers
  • Employees
  • Temporary staff
  • Contractors
  • Consultants
  • Agents
  • Suppliers
  • Vendors
  • Business partners
  • Representatives acting on behalf of Defence.us

Compliance with this policy is a condition of doing business with Defence.us.


Prohibited Conduct

No individual acting on behalf of Defence.us may:

  • Offer, promise, authorize, give, request, or accept any bribe or improper payment.
  • Offer gifts, hospitality, or entertainment intended to improperly influence a business decision.
  • Make facilitation payments unless required to protect health or safety in exceptional circumstances.
  • Offer kickbacks or receive undisclosed commissions.
  • Use third parties to circumvent anti-bribery laws or this policy.
  • Conceal or misrepresent financial transactions.

Bribery is prohibited whether it involves public officials, private organizations, customers, suppliers, or any other third party.


Gifts, Hospitality & Business Courtesies

Reasonable business courtesies may be acceptable when they:

  • Are lawful.
  • Are modest and infrequent.
  • Are transparent.
  • Do not create an obligation or expectation of favorable treatment.
  • Cannot reasonably be perceived as influencing business decisions.

Cash gifts or cash equivalents are never permitted.


Conflicts of Interest

Employees and representatives must avoid situations where personal interests conflict, or appear to conflict, with the interests of Defence.us.

Any actual or potential conflict of interest must be disclosed promptly to management.


Third-Party Due Diligence

Defence.us seeks to work only with reputable business partners who share our commitment to ethical conduct.

Appropriate due diligence may be conducted before entering into relationships with:

  • Suppliers
  • Contractors
  • Consultants
  • Sales representatives
  • Distributors
  • Service providers
  • Joint venture partners

Business partners are expected to comply with applicable anti-corruption laws and maintain ethical business practices.


Accurate Books and Records

All financial transactions must be:

  • Properly authorized.
  • Completely and accurately recorded.
  • Supported by appropriate documentation.
  • Maintained in accordance with applicable accounting standards and legal requirements.

False, misleading, or incomplete records are strictly prohibited.


Reporting Concerns

Employees and business partners are encouraged to report any suspected bribery, corruption, unethical conduct, or violations of this policy as soon as possible.

Reports made in good faith will be treated confidentially to the extent permitted by law.

Defence.us prohibits retaliation against anyone who raises a genuine concern or participates in an investigation.


Training and Awareness

Defence.us promotes awareness of ethical business practices by communicating this policy to relevant personnel and encouraging compliance throughout the organization and its supply chain.


Compliance

Failure to comply with this policy may result in disciplinary action, termination of employment or business relationships, and, where appropriate, referral to relevant authorities.


Policy Review

This policy will be reviewed periodically to ensure it remains effective, relevant, and aligned with applicable legal and regulatory requirements, as well as international best practices.


Our Ethical Commitment

Integrity is fundamental to the way Defence.us conducts business. We are committed to building trusted relationships with customers, suppliers, government organizations, and stakeholders by maintaining the highest standards of ethical conduct, accountability, fairness, and transparency in every aspect of our operations.