Introduction:

Lima Sprachschule is committed to upholding the highest ethical standards and integrity in all its business activities. We reject any form of corruption and bribery and strive to create a transparent and honest working environment.

Scope:

This policy applies to all employees of Lima Sprachschule, including the founder, freelance teachers, and any person acting on behalf of the company.

Definition of Corruption and Bribery:

Corruption and bribery are defined as the offering, promising, giving, accepting, or soliciting of any undue advantage of any kind (money, gifts, favors, etc.) to influence a decision or action or to gain an undue advantage.

Principles:

• Honesty: We act transparently and truthfully in all our interactions.
• Integrity: We uphold our ethical values at all times, even when faced with challenges.
• Impartiality: We make decisions based on merit and objective criteria, without favoritism or discrimination.
• Responsibility: We take responsibility for our actions and decisions.
• Compliance: We respect all applicable laws and regulations, including local and international anti-corruption laws.

Prohibited Practices:

• Offering, promising, giving, soliciting, or accepting bribes, either directly or indirectly.
• Participating in activities that could be perceived as corruption or bribery.
• Using insider information to gain personal or commercial advantage.
• Facilitating or concealing acts of corruption.

Gifts and Hospitality:

The offering or acceptance of gifts or invitations to events that could influence a business decision or create a conflict of interest is prohibited. Small tokens of appreciation or invitations to events of low value are permitted, provided they are appropriate and proportionate.

Conflicts of Interest:

Employees must avoid situations where their personal or family interests could conflict with the interests of Lima Sprachschule. Any potential conflict of interest must be reported immediately to the founder of the company.

Reporting and Whistleblower Protection:

Lima Sprachschule encourages all employees to report any suspicion of corruption or violation of this policy. Confidentiality and protection of whistleblowers from reprisals are guaranteed.

Consequences:

Non-compliance with this policy may result in disciplinary action, including termination of employment or business relationship.

Training and Communication:

All employees will be trained on this anti-corruption policy and regularly reminded of its importance. The policy will be available on the Lima Sprachschule website and communicated to all new employees.

Review:

This policy will be reviewed and updated regularly to ensure its relevance and effectiveness.

Approval:

This anti-corruption policy has been approved by the founder of Lima Sprachschule.

June 6, 2024

Rosa De Paz

CEO Lima Sprachschule