Effective date: 1 May 2026 · Last updated: 12 May 2026 · Owner: Board of Directors · Review cycle: Annual
1. Zero-tolerance commitment
ERAM Real Estate Sh.P.K. has zero tolerance for bribery and corruption in any form. We will not offer, promise, give, request, agree to receive or accept any bribe or improper advantage, whether in dealings with public officials or private parties, in Kosovo or anywhere else in the world.
2. Scope and binding effect
This policy is binding on every director, officer, employee, consultant, contractor, agent, joint-venture partner, and third-party intermediary acting on ERAM's behalf, anywhere in the world. The standards of this policy are passed down contractually to ERAM's suppliers and partners.
3. Legal framework
ERAM complies with the Republic of Kosovo Criminal Code provisions on bribery and corruption, the Law on Prevention of Conflict of Interest, the Law on Public Procurement (in dealings with public bodies), and is mindful of the extraterritorial reach of the UK Bribery Act 2010 and the U.S. Foreign Corrupt Practices Act (FCPA) where applicable to counterparties.
4. Definitions
Bribery — offering, giving, requesting or accepting any financial or other advantage with the intention to induce or reward improper performance of a function or activity.
Corruption — abuse of entrusted power for private gain.
Facilitation payment — a small payment to a public official to secure or expedite a routine action. Facilitation payments are strictly prohibited under this policy, regardless of local custom.
Kickback — a payment, gift or other advantage returned to the giver of business, often as a percentage of the contract value. Prohibited.
5. Gifts and hospitality
Gifts and hospitality are permitted only where:
- Reasonable and proportionate, not lavish or extravagant;
- Given openly, not in secret;
- Properly recorded in ERAM's gifts and hospitality register;
- Not intended to influence a business decision improperly;
- Permissible under the recipient's organisation's rules;
- Compliant with applicable law.
Gifts of cash or cash equivalents (vouchers, gift cards) are prohibited. Gifts or hospitality to or from public officials are subject to enhanced scrutiny and pre-approval.
6. Donations and political contributions
ERAM does not make political donations of any kind. Charitable donations are permitted only with documented board approval, transparent disclosure, and verification that the recipient is a bona fide registered charity unrelated to a current or prospective business decision.
7. Third parties and due diligence
ERAM applies risk-based due diligence to every third-party intermediary, agent, joint-venture partner and major supplier. Higher-risk engagements — such as dealings with public bodies, complex procurement, or operations in higher-risk jurisdictions — require enhanced anti-corruption due diligence, contractual representations and warranties, and right-to-audit clauses.
8. Books and records
ERAM maintains accurate and complete books and records of all transactions. No off-the-books accounts, undisclosed liabilities, or false documents are permitted. Expenses must be supported by appropriate documentation.
9. Reporting and protection
Any director, officer, employee, contractor or third party who suspects, witnesses, or is invited to participate in bribery or corruption involving ERAM is obliged to report through the Whistleblowing channel without delay. ERAM strictly prohibits retaliation against good-faith reporters.
10. Discipline and remedies
Breach of this policy is treated as gross misconduct and may result in immediate termination of engagement, civil proceedings, and referral to competent authorities for criminal prosecution.
11. Training and review
Directors, officers and employees in roles exposed to bribery risk receive anti-bribery training on appointment and at least annually thereafter. The policy is reviewed annually.
Contact
Questions regarding this policy, or to report a concern: [email protected]. Confidential reports may also be made via our Whistleblowing channel.
ERAM Real Estate Sh.P.K. · Business no. (NUI) 812052025 · Registered 13/06/2023 · Rruga Agim Ramadani, Nr. 2, 10000 Prishtina, Kosovo