Code of Ethics (Anti-Bribery & Anti-Corruption)
International Armour (Greece) and Interarmour (Bulgaria) are separate and legally independent companies.
Each company conducts its business independently and is solely responsible for its own activities, while adhering to high standards of integrity, transparency, professionalism, and legal compliance.
This Code of Ethics and Anti-Bribery & Anti-Corruption Policy (the “Code”) establishes the principles and rules governing ethical conduct and applies to:
- Employees
- Officers and directors
- Agents, consultants, and representatives
- Contractors and intermediaries
- Any third party acting on behalf of International Armour or Interarmour, as applicable
Compliance with this Code is mandatory and forms an integral part of the internal governance and compliance framework of each respective company.
Commitment to Ethics
The reputation of each company for integrity is fundamental to its long-term success. All business activities must be conducted in a manner that reflects:
- Honesty and fairness
- Respect for applicable laws and regulations
- Accountability and transparency
- Zero tolerance for unethical or corrupt practices
No commercial objective or business opportunity justifies deviation from these principles.
Anti-Bribery and Anti-Corruption
Prohibition of Bribery
Bribery and corruption are strictly prohibited in all forms.
- No employee, officer, agent, or third party acting on behalf of International Armour or Interarmour may, directly or indirectly:
- Offer, promise, give, or authorise a bribe
- Request, accept, or receive any improper advantage
- Make facilitation payments or kickbacks
- Engage in any conduct intended to improperly influence a decision or secure an unlawful business advantage
This prohibition applies equally to interactions with public officials and private-sector counterparties.
Legal Compliance
Each company conducts its activities in full compliance with all applicable anti-corruption laws and international standards, including but not limited to:
- The U.S. Foreign Corrupt Practices Act (FCPA)
- The UK Bribery Act
- Relevant European Union legislation
- Applicable national anti-corruption laws in all jurisdictions of operation
- International conventions and treaties relating to anti-corruption and ethical business conduct
Gifts and Hospitality
Gifts, hospitality, or business courtesies may only be offered or accepted when they are reasonable, infrequent, transparent, non-cash in nature, consistent with legitimate business practices, and not intended, or reasonably perceived, to improperly influence business decisions.
Any gift or hospitality that could create a conflict of interest or reputational risk is prohibited.
Political Contributions and Lobbying
Political contributions, sponsorships, or lobbying activities carried out by either company must fully comply with applicable laws, receive appropriate internal authorisation, and must never be used to obtain improper or unlawful advantages.
Ethical Principles and Corporate Responsibility
Integrity and Accountability
All individuals subject to this Code must perform their duties with professionalism, integrity, and personal accountability, ensuring that decisions withstand legal, ethical, and public scrutiny.
Conflicts of Interest: Actual, potential, or perceived conflicts of interest must be disclosed promptly and managed transparently. Personal interests must never interfere with the interests of the relevant company or its business partners.
Confidentiality and Intellectual Property: Each company respects intellectual property rights and protects confidential, proprietary, and sensitive information entrusted to it by clients, partners, and counterparties.
Compliance, Training, and Reporting
Each company provides appropriate training and guidance on ethical conduct, anti-bribery, anti-corruption, and compliance obligations relevant to applicable roles.
Any request for a bribe, suspicion of corruption, or violation of this Code must be reported promptly through designated internal reporting channels. Reports may be made in good faith without fear of retaliation.
Retaliation against any individual who reports a concern in good faith is strictly prohibited.
Compliance with this Code is subject to ongoing monitoring, internal controls, and audits to ensure effectiveness and alignment with evolving legal and regulatory requirements.
Enforcement and Disciplinary Measures
Violations of this Code may result in disciplinary action, including suspension or termination of employment or contractual relationships, reporting to competent authorities where required, and potential civil or criminal legal consequences.
All allegations of misconduct are investigated promptly, independently, and impartially by the relevant company.
Third-Party and Partner Expectations
Each company expects its partners, suppliers, intermediaries, and service providers to adhere to equivalent ethical and compliance standards.
Third-party relationships are subject to risk-based due diligence, particularly where defence, security, or other regulated international trade activities are involved.
Sanctions and Embargo Compliance
All transactions conducted by either company are screened against applicable United Nations, European Union, United States, and other relevant sanctions and embargo regimes. Neither company engages in any activity that would violate such restrictions.
Notice
International Armour (Greece) and Interarmour (Bulgaria) operate in compliance with all applicable Greek, Bulgarian, European Union, and international laws and regulations governing defence and security trade.
The companies’ activities primarily involve contractual, commercial, administrative, and invoicing functions in relation to international defence and security transactions. Defence-related goods traded in connection with these activities do not physically enter, exit, transit through, or are stored within the territories of Greece or Bulgaria.
End-user certificates and export licences are issued to and held by the relevant manufacturers, who act as exporters of record and deliver the goods directly to the final end-users. Neither company acts as exporter of record and neither physically handles defence-related goods.
In accordance with the applicable European regulatory framework, including Council Common Position 2008/944/CFSP, as implemented under national legislation, each transaction is assessed on a case-by-case basis to determine whether any export, brokering, or trade-related licence, authorisation, or notification is required.
Where required by applicable law, all necessary licences and regulatory approvals are obtained prior to execution. This compliance position is subject to continuous legal and regulatory review to ensure alignment with evolving national, European Union, and international export-control and sanctions frameworks.