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Anti-Corruption, Anti-Fraud and Conflict of Interest Policy

1. Our position

Swiftmade OÜ has zero tolerance for bribery, corruption and fraud. Some of our clients spend public or donor funds meant for people in need, and we take seriously our responsibility to use those funds honestly. We comply with the Estonian Anti-Corruption Act and Penal Code and with anti-corruption laws in the countries where we and our clients operate.

2. Bribery and facilitation payments

  • We do not offer, promise, give, request or accept bribes or any improper advantage, directly or through anyone else, to win or keep business.
  • We do not make facilitation payments (small unofficial payments to speed up routine actions), even where they are locally common.
  • We do not make political donations on behalf of the company.

3. Gifts and hospitality

  • Modest, occasional gifts or hospitality (for example a business meal) are acceptable if they are reasonable, transparent and not intended to influence a decision.
  • We never offer gifts or hospitality to client staff involved in a procurement or evaluation while it is in progress, and we follow the client's own gifts rules, which are often stricter.
  • Anything above EUR 50 in value, and any cash or cash equivalent, must be declined or reported to the Managing Director.

4. Fraud

We do not tolerate fraud, including false timesheets or invoices, charging clients for work not done, misuse of client funds or assets, or misrepresentation of our capabilities, certifications or experience. Our invoices reflect work actually performed under the agreed terms, and we keep accounting records as required by Estonian law.

5. Conflicts of interest

A conflict of interest arises when personal interests (financial, family or other) could influence, or appear to influence, decisions made for Swiftmade or a client. Everyone must:

  • disclose any actual or potential conflict to the Managing Director as soon as they become aware of it, for example a family member working at a client or competitor, or a financial interest in a supplier we recommend;
  • not take part in decisions affected by the conflict until it has been resolved.

We will tell clients about any conflict that could affect our work for them.

6. Sanctions and restricted parties

We comply with the sanctions regimes of the United Nations and the European Union, and with others that apply to a contract (for example US or UK sanctions). We do not work with, pay, or receive funds from sanctioned individuals, entities or countries. When onboarding new clients, suppliers and contractors, we check them against the EU Sanctions Map and the UN Security Council Consolidated List.

7. Contractors and third parties

Our developers are engaged as B2B contractors and must follow this policy, keep accurate records of time and work, and disclose conflicts of interest. All contractor agreements include an explicit anti-corruption and conflict-of-interest clause. We do not use agents or commission-based intermediaries to win public or donor-funded contracts.

8. Reporting concerns and whistleblowing

Anyone (team members, clients, suppliers or the public) can report a suspected breach of this policy:

  • to the Managing Director at [email protected] or +372 5675 8611;
  • if the concern involves the Managing Director, through the client's own integrity or ethics hotline.

Reports will be treated confidentially and looked into promptly. We will not retaliate against anyone who raises a concern in good faith. Where a concern relates to a client project, we will inform the client and cooperate with any investigation by the client or its oversight bodies.

9. Consequences

Breaches of this policy may lead to termination of a contractor's agreement, recovery of losses and referral to the authorities.