Legal imprint

4iP Council EU AISBL (international non-profit association)

Avenue de Fré 180
1180, Brussels
BELGIUM

E: info@4ipcouncil.com

4iP / 4iP Council is a brand of 4iP Council EU AISBL

4iP Council and GleimPetri 4IP should not be confused. GleimPetri 4IP is a law firm based in Germany, specialised in the prosecution and litigation of patents, trademarks and designs. 4iP Council is a research council advocating for a strong IP regime in Europe.

Technology, Innovation and Investment Council e.V. has been liquidated and all the activities and Intellectual Property Rights were transferred to 4iP Council EU AISBL

Representative
Axel Ferrazzini, Managing Director

Website contact
Marta Sierra Marco, Editor

OUR PRINCIPLES

At 4iP Council EU AISBL, integrity is a crucial component of our business. 4iP Council EU AISBL, along with its subsidiaries and affiliates (collectively “4iP”), is committed to ethical business practices and to obeying both the spirit and the letter of the law in every country in which it does business. 4iP strictly prohibits bribery or any other improper payments in business dealings.

Under a variety of applicable anti-bribery laws, bribery is a criminal offence punishable by imprisonment and/or fines for both 4iP and, separately, any person involved in the bribery. 4iP takes its legal responsibilities to prevent bribery very seriously and expects you to do the same. The fact that bribery may be a customary business practice in a given country is not a justification for violation of this policy.

The directors and executive management of 4iP fully endorse this Anti-Bribery Policy and expects Third Parties as defined below to comply with its terms in full.

DEFINITIONS

Bribery (or bribe): Giving, offering, promising, requesting, or authorizing the giving of anything of value, directly or indirectly, to any person or entity to induce a person to act, or refrain from acting, in relation to the performance of their duties, in order to obtain or retain any advantage or benefit.

Anything of value: Includes, but is not limited to: cash, cash equivalents (such as gift cards, kickbacks or discounts), benefits or favors, entertainment, gifts, hospitality, meals, travel, charitable contributions, political contributions or employment opportunities. There is no minimum value for something to be considered “of value.”

Facilitating payments: Payments made to public officials to encourage them to expedite a routine or common governmental task that the official is otherwise required to undertake even if the payment were not made, such as issuing permits or licenses.

Gift: Includes any tangible object of any kind, regardless of value.

Public official: A government official, whether elected or appointed; an officer or employee of a government agency or state-owned or state-controlled entity; a person performing a public service on behalf of a government or government agency; a political party or party official; a candidate for political office; any person acting in an official capacity; or an officer or employee of a public international organization.

Hospitality: Meals, lodging, or any event or form of entertainment (including sporting events, parties, plays and receptions).

Travel: All forms of transportation, including ground transit and air travel.

Third Party: Any person or entity who acts on behalf of or represents 4iP, including but not limited to sales agents or representatives, distributors, consultants, lobbyists, transportation or logistics providers, customs clearing agents, or any person or entity retained to represent 4iP  in a matter before a public official, government agency, or in tax or legal matters.

STATEMENT OF POLICY

Bribery and Facilitating Payments: 4iP and Third Parties are prohibited from offering or giving a bribe, whether directly or indirectly, to any person or entity. 4iP and Third Parties are prohibited from requesting or receiving a Bribe, directly or indirectly, from any person or entity. All demands for bribes or kickbacks must be expressly rejected.

4iP and any Third Party are prohibited from offering or making facilitating payments to public officials.

If a Third Party believes there is a serious threat to a person’s health or safety if a payment demand is not met, such payment would not be considered a prohibited bribe. In that situation, the Third Party should report the incident to the Managing Director as soon as possible and the payment must be properly recorded in 4iP’s books and records.

The Third Parties who refuse to pay a bribe will not suffer any penalty, demotion or other adverse consequence as a result, even if 4iP  loses business. Third Parties are required to report any suspected violations of this Anti-Bribery Policy to 4iP’s Managing Director, and no Third Party will suffer any penalty, demotion or other adverse consequence for reports made in good faith. Reports will be treated confidentially to the extent possible, consistent with the need to conduct a thorough investigation.

Charitable Contributions: No charitable donations may be given, offered, promised or authorized without express authorization from the Managing Director. If a donation is authorized, it must fully comply with all applicable laws and be properly and accurately reflected in 4iP’s books and records.

Gifts, Hospitality and Travel: 4iP and any Third Party shall not offer or receive gifts, hospitality or travel whenever these could affect the outcome of business transactions or other matters 4iP is involved in, or where doing so would be in violation of the laws of the recipient’s country.

All gifts, hospitality and travel must be made consistent with 4iP’s Gifts, Hospitality and Travel Policy, be preapproved by the Managing Director, and be properly and accurately recorded in 4iP’s books, records and accounts. 4iP and any Third Party shall not offer or receive gifts, hospitality or travel that are not reasonable and legitimate business expenditures. Any gifts, hospitality or travel offered or provided must be directly related to the promotion or demonstration of 4iP’s products or services, or directly related to the performance of a contract with a government, government agency, or state-owned or -controlled entity. Any expenses that do not meet these criteria will not be reimbursed or otherwise paid for by 4iP.

In order to qualify for reimbursement, proposed expenses must be explicitly detailed in the request, i.e., broken down by names and positions of government officials, dates and places of travel, and the amount and type of specific expenses. 4iP reserves the right to deny, in whole or in part, any expenses related to the travel of a government or political party official (including officers and employees of government-owned or government-controlled enterprises) for any reason.

Conflicts of Interest: 4iP and any Third Party shall avoid any relationship or activity that might impair, or reasonably appear to impair, their ability to render objective and appropriate business decisions in the performance of their tasks.

Books and Records: 4iP is committed to maintaining complete and accurate books, records and accounts. All transactions, including payments, reimbursement requests, expenditures, expense reports, invoices, vouchers, gifts, and business entertainment must be properly and accurately entered into 4iP books, records and accounts in a timely manner, in detail, and with supporting documentation.

Training: 4iP Managing Director must participate in anti-bribery training on a periodic basis and they must certify annually that they have read this policy and that they are acting and will continue to act in compliance with this policy.