Purpose
The purpose of this policy is to establish clear guidelines and controls to ensure Ísfell ehf (“Ísfell”) and its associated personnel comply with all applicable anti-bribery and anti-corruption laws, regulations, and standards. This policy reinforces the company’s commitment to conducting business ethically, with integrity, transparency, and social responsibility.

2. Scope
This policy applies to all Ísfell employees, directors, officers, contractors, consultants, agents, and any third parties acting on behalf of the company, in all locations where Ísfell operates.

3. Policy Statement
Ísfell is committed to conducting its business with honesty, integrity, and fairness. The company maintains a zero-tolerance approach to bribery, corruption, and facilitation payments. All personnel associated with Ísfell are expected to act professionally and ethically in all business dealings.

4. Compliance with Laws and Regulations

• All personnel must comply with all applicable anti-bribery and anti-corruption laws in the jurisdictions in which the company operates.
• Employees and associated personnel must maintain an understanding of laws relevant to their role.
• If there is uncertainty regarding the legality of any action, prior consultation with the company’s legal counsel is required before proceeding.
• Personnel have an obligation to prevent violations and report any suspected breaches to senior management immediately

5. Definition of Bribery

• Bribery refers to offering, giving, promising, soliciting, accepting, or receiving anything of value to influence the actions, decisions, or conduct of an individual in a position of trust.
• A bribe can include money, gifts, favors, services, or any other benefit intended to improperly influence a business outcome.
• · Engaging in bribery, whether directly or indirectly through third parties, is strictly prohibited.

6. Gifts, Hospitality, and Entertainment

• Ísfell permits reasonable and proportionate gifts or hospitality, provided they:

• Are not intended to influence the recipient to obtain or retain business or a business advantage.
• Do not imply an expectation of favor in return.
• Comply with local laws.
• Are given in the company’s name, not in an individual’s personal capacity.
• Are appropriate in type, value, and timing.
• Are given or received openly and transparently.
• Any gifts or hospitality offered to or received from government officials, politicians, or political parties require prior approval from the CEO.
  
  
• 7. Political and Charitable Contributions
• Contributions to political parties, politicians, or candidates are prohibited unless explicitly approved by the CEO and are compliant with local laws.
• Charitable donations must be transparent, properly recorded, and cannot be used as a mechanism to conceal bribery.
• Ísfell follows sponsor policy that is officially published at the company´s homepage.

8. Responsibilities

• All personnel are responsible for understanding and complying with this policy.
• Any suspected violations or concerns must be reported to the CEO or a member of the Board of Directors.
• Managers and supervisors are responsible for promoting compliance within their teams and ensuring employees receive appropriate training.

9. Reporting and Whistleblowing

• Ísfell encourages reporting of concerns in good faith without fear of retaliation.
• Confidential reporting channels should be used when necessary. All reports will be investigated promptly and appropriately.

10. Disciplinary Actions

• Breaches of this policy may result in disciplinary action, including termination of employment or contractual arrangements.
• Violations may also constitute criminal offenses; in such cases, Ísfell will report the matter to law enforcement or regulatory authorities.

11. Record-Keeping

• Accurate records of transactions, gifts, and hospitality must be maintained in accordance with company procedures
• All accounts, invoices, and financial records must reflect the true nature of transactions.

12. Training and Communication

• Ísfell will provide regular training on anti-bribery and anti-corruption practices to all employees and relevant third parties.
• The company will communicate this policy and updates to all personnel to ensure understanding and compliance.

13. Monitoring and Review

• The CEO and Board of Directors are responsible for monitoring compliance with this policy.
• This policy will be reviewed periodically and updated as necessary to reflect changes in laws, regulations, and best practices.