Under this Midas Games – Policy on Combating Corruption and Bribery (“Policy”), MIDAS GAMES KFT (“Company”); Registration number: 01-09-432808 Registered Seat: 1064 Budapest, Izabella utca 68/B A. lház. Fsz. 5. Ajtó Hungarian VAT Number: 32600207-2-42 EU VAT Number: HU32600207 commits to acting in a manner that ensures the prevention of crimes, particularly corruption, bribery, and kickbacks. This Policy is established to ensure the Company’s compliance with relevant national and international regulations and to guarantee that its business operations adhere to legal, ethical, and professional standards. Regardless of the principle of territoriality, this Policy applies to all of the Company’s national and international business operations.
The Company commits to full compliance with national and international regulations regarding corruption and bribery. This includes, but is not limited to, the Turkish Penal Code No. 5237 (“TPC”), the Declaration of Property, Anti-Bribery and Anti-Corruption Law No. 3628 (“DAA”), the United Nations Convention Against Corruption (“UNCAC”), the United States Foreign Corrupt Practices Act (“FCPA”), and the United Kingdom Bribery Act (“UKBA”). The Company diligently follows the guidelines issued by the Organization for Economic Co-operation and Development (“OECD”), the Commission of the European Communities (“CEC”), and other relevant organizations. Subsequently, the Company reviews and updates the Policy accordingly.
The Company, aiming to establish business relationships based on trust, has adopted a zero-tolerance policy towards corruption, bribery, and incentive payments. Committed to raising standards of business ethics, the Company upholds integrity and transparency in all its operations to promote an ethical and compliant culture. The Company pledges to treat all stakeholders and business partners fairly and honestly under this Policy, with a primary focus on its employees.
Corruption refers to any activity in the public or private sector that involves the abuse of power for personal or institutional gain. Bribery means offering, giving, receiving, or soliciting money, gifts, services, or other advantages to misuse one's authority or position for unfair gain. Incentive payments are small payments made to expedite or secure routine business processes. The Company strictly enforces a zero-tolerance policy regarding these matters and takes all necessary measures through its operating units to prevent such activities.
Gifts and hospitality generally encompass any gifts, hospitality, or courtesies received or given by employees in the context of business relationships. While employees may accept gifts of low nominal value, this does not apply to high-value gifts that could potentially influence business decisions. In other words, accepting gifts is permissible only to strengthen existing or potential business relationships while maintaining professional boundaries. Similarly, participation in hospitality activities is allowed if it is reasonable and directly related to business. Any offered gifts or hospitality, even if declined, must be individually reported to the Ethics and Compliance Committee and the Human Resources Department of the Company. The Company evaluates the appropriateness of gifts and hospitality based on the principles of transparency, honesty, and professionalism. It provides detailed guidance to prevent any conflicts of interest, especially concerning employees and business partners.
In the fight against corruption, bribery and incentive payments, the Company’s board of directors is the unit primarily responsible for determining policies and strategies, implementing, monitoring, developing, and reporting these strategies in daily business operations. Additionally, the board of directors allocates the necessary resources and ensures the formation of required units to effectively implement this Policy. The strict application of the Policy is essential for all employees and business partners of the Company. Under the principle of accountability, these individuals and entities are obligated to understand the Policy thoroughly and act in accordance with the duty of care concerning any form of bribery, corruption, and incentive payments. They must also contribute to the effective operation of the internal control and audit mechanisms established within the Company.
The Company acts with utmost diligence in its relationships with business partners to combat corruption, bribery, and incentive payments. Adopting a zero-tolerance policy on these issues, the Company ensures that its business partners share the same commitment, appropriateness, and reliability. Ultimately, it assesses the purpose and nature of the business relationship. The Company does not establish any business relationship without verifying the declared information.
The Company continuously strengthens and enhances its internal control and audit mechanisms established within itself for the effective implementation of combating corruption, bribery, and incentive payments. The aim of these internal control and audit mechanisms is to detect and evaluate suspicious activities and, if necessary, ensure their reporting to the relevant authorities. In addition, the Company agrees to voluntarily undergo external inspections by relevant public authorities or independent institutions regarding this matter when necessary. Furthermore, each department manager is responsible for managing corruption, bribery, and incentive payment risks within their units and taking necessary measures.
The Company operates within the principles identified under this Policy in all business operations and decision-making mechanisms. The control mechanisms determined individually by the Company in terms of working methods and principles are effectively operated by the Company, thus ensuring regular risk analysis on corruption, bribery, and incentive payments, followed by the prompt implementation of necessary measures. The Company, which supervises the effectiveness of this Policy in all units established within itself, has the ability and authority to initiate separate investigations regarding corruption, bribery, and incentive payments.
All employees and business partners operating within the Company are obligated to report violations of corruption, bribery, and incentive payments, whether actual or potential. In accordance with the zerotolerance principle, the Company considers all reports without any discrimination. These violations are reported to the Company within the framework of procedures and principles determined solely by the Company, and investigations are initiated entirely at the Company's discretion following the effective and prompt evaluation of reports. Any measures necessary for conducting a fair internal investigation are taken by the Company, with the identities of individuals or legal entities reporting such matters kept confidential, except when requested by judicial authorities. Thus, the Company aims to ensure that employees and business partners operating within its scope can report their concerns regarding corruption, bribery, and incentive payments securely. The investigation process is conducted impartially and confidentially. Upon detection of a violation, appropriate disciplinary measures are promptly taken, and if necessary, relevant legal proceedings are initiated thereafter.
Regardless of their nature, violations that could harm the Company's business operations and reputation are subject to disciplinary measures by the Company at its discretion, acting as a deterrent for employees acting contrary to the Policy. In this regard, following the conclusion of investigations initiated within the Company regarding employees involved in corruption, bribery, and incentive payment activities, disciplinary measures such as termination of employment contracts unilaterally or sanctions including warnings, reprimands, suspensions, or dismissals may be imposed. Additionally, depending on the seriousness of the violations, the Company, at its discretion, may report the situation to the judicial authorities.
This Policy is subject to periodic reviews, and necessary amendments are made to ensure its compliance with legal regulations and practices. The Company provides mandatory training and resources to all employees regarding the contents of the Policy. The Policy is communicated to all employees and business partners of the Company upon its approval and any amendments are promptly announced. The implementation of this Policy is regularly monitored, and employees are notified of any changes. Ultimately, the Company expects all employees and business partners to comply with the Policy.
This Policy, drafted by the Company’s authorized representatives, is approved and entered into force by the Company’s Board of Directors. This Policy is published and made publicly available on the Company’s website. The Policy is subject to changes according to the Company’s discretion and is applicable in its entirety. In case of any conflict between the provisions of this Policy and the laws, regulations, or contracts in force, the latter shall prevail. Any invalidity or unenforceability of any provision of this Policy does not affect the validity or enforceability of any other provision. This Policy shall remain in effect until amended or repealed.