Code of Ethics (Anti-Bribery & Anti-Corruption)

At International Armour, we uphold the highest standards of ethical conduct and integrity in all our business dealings worldwide.


This Code of Ethics and Anti-Bribery & Anti-Corruption Policy (the "Code") applies to all employees, officers, directors, agents, consultants, contractors, and any individual acting on behalf of International Armour.


The Code affirms our unwavering commitment to ethical practices and legal compliance in every market and community in which we operate.


Commitment to Ethics


International Armour is committed to full legal compliance and ethical conduct. Our reputation for integrity, both in the marketplace and the communities where we operate, is of paramount importance.


This commitment means conducting all business dealings with honesty, fairness, transparency, and respect for the rule of law.


Anti-Bribery and Anti-Corruption


Prohibition of Bribery: Bribery is strictly prohibited in all business interactions and transactions. No form of bribe, kickback, facilitation payment, or other corrupt practice—whether direct or indirect—is authorized or permitted.


Compliance with Anti-Corruption Laws: International Armour conducts its business in full compliance with applicable anti-bribery and anti-corruption laws, including but not limited to:


- The U.S. Foreign Corrupt Practices Act (FCPA),

- The UK Bribery Act,

- All relevant local laws and international conventions.


Gifts and Hospitality: Gifts, entertainment, or hospitality may only be offered or accepted if they are:


- Reasonable in value,

- Infrequent,

- Non-cash in nature,

- Consistent with customary and legitimate business practices,

- Not intended to secure any improper business advantage.


Political Contributions and Lobbying: Political contributions made on behalf of International Armour must fully comply with applicable laws and must never be used to gain improper or unlawful business advantages.


Ethical Principles


Integrity and Accountability: All individuals must carry out their business responsibilities with the highest levels of integrity, professionalism, and accountability.


Conflicts of Interest: Actual or potential conflicts of interest must be disclosed promptly and managed with transparency and fairness.


Respect for Intellectual Property and Information: We respect the intellectual property rights of others and safeguard the confidentiality of all information entrusted to us.


Compliance and Reporting


Training and Communication: All relevant personnel will receive regular training on this Code and on anti-bribery and anti-corruption laws relevant to their roles.


Reporting Mechanisms: Employees are required to report any request for a bribe, suspected corruption, or any other violation of this Code through designated reporting channels.


Non-Retaliation: International Armour strictly prohibits retaliation against any individual who reports a suspected violation in good faith.


Auditing and Monitoring: Compliance with this Code will be regularly audited and monitored to ensure its ongoing effectiveness and relevance.


Enforcement


Disciplinary Action: Violations of this Code may result in disciplinary measures, including suspension, termination of employment or contracts, and potential legal consequences.


Investigation of Violations: All allegations of bribery or corruption will be investigated promptly, thoroughly, and impartially.


This Code forms the foundation of our commitment to ethical conduct and compliance with all applicable anti-bribery and anti-corruption laws.


Every individual associated with International Armour has a personal responsibility to uphold these principles.


We also expect our partners, suppliers, and third parties associated with International Armour to adhere to these standards, as their conduct reflects directly upon our reputation and integrity.


Compliance Notice


International Armour (Greece) and Interarmour (Bulgaria) operate in full compliance with all applicable Greek, Bulgarian, and European Union laws and regulations.


Both companies engage exclusively in contractual, administrative, and invoicing activities related to defence and security products. No physical trading, import, export, transit, or storage of defence-related goods is carried out within the territories of Greece or Bulgaria.


In accordance with the European regulatory framework,and specifically the EU Common Position 2003/468/CFSP on arms brokering, as implemented under both Greek and Bulgarian national legislation, it is hereby clarified that the companies operate solely as traders (buyers/sellers) of defence and military equipment in international transactions.


Since no defence-related goods requiring a special licence enter, exit, transit through, or are stored within Greece or Bulgaria, and no brokering activities are conducted from the territory of either country, neither company is required to obtain a brokering or defence-trade licence from the respective national authorities.


These activities fall under the permissible exemptions of the applicable European and national export-control regimes, as neither Greece nor Bulgaria is physically or operationally involved in the movement or handling of the defence material.