Statement of commitment
Sternberg Consulting operates a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships.
This policy sets the minimum standards for business decisions, gifts, hospitality, payments, intermediaries, and cooperation with third parties. It is intended to ensure that decisions are objective, transparent, and free from improper influence.
Scope
This policy applies to employees, contractors, consultants, agents, and any other party acting on behalf of Sternberg Consulting.
It applies to all business contacts in Germany and abroad, including clients, suppliers, certification bodies, cooperation partners, public authorities, and other third parties.
What is prohibited
- Offering, giving, requesting, or accepting any bribe, kickback, or improper payment
- Using a third party to offer or accept a bribe on our behalf
- Making facilitation payments to public authorities or other parties
- Any conduct that could be perceived as an attempt to improperly influence a business decision
Indirect advantages are also prohibited, including private benefits, disproportionate discounts, hidden commissions, sham fees, or other benefits that could create the appearance of improper influence.
Gifts and hospitality
Reasonable and proportionate gifts or hospitality are permitted only where they are modest in value, transparent, properly recorded, and not intended to influence a business decision.
Gifts, hospitality, or other benefits must not be offered or accepted where they could impair independence during tenders, contract negotiations, audit decisions, or comparable decision situations.
All benefits above a nominal value must be approved in advance and recorded. Cash, cash equivalents, and personal payments are generally prohibited.
Donations, sponsorship, and political contributions
Donations and sponsorship may be made only transparently, lawfully, and without expectation of a business advantage in return. Political contributions in the name of Sternberg Consulting are not intended.
Conflicts of interest
Actual or potential conflicts of interest must be disclosed. This includes personal relationships, economic interests, side activities, or other circumstances that could affect an independent business decision.
Third parties
We carry out appropriate due diligence on business partners, subcontractors, and suppliers, and expect equivalent standards from them.
Where risk is elevated, additional checks may be required, for example regarding identity, beneficial ownership, service scope, payment routes, and references. Payments may be made only to traceable, contractually agreed accounts.
Records and documentation
Business transactions must be documented correctly, completely, and transparently. Sham invoices, unclear service descriptions, disguised payments, or untraceable expenses are prohibited.
Training and awareness
People acting on behalf of Sternberg Consulting must know this policy and ask questions early where they are unsure. When new risks arise, this policy is reviewed and updated if needed.
Reporting concerns
Suspected breaches can be reported confidentially under the Whistleblower Policy. Reports are taken seriously and reviewed promptly.
No person may be disadvantaged for reporting a concern in good faith or refusing an improper payment.
Consequences of breach
Violations may result in termination of employment or contract and, where required, may be reported to relevant authorities.
Depending on severity, consequences may also include claims for damages, contract termination, exclusion from future cooperation, or further legal steps.
Review
This policy is reviewed annually. Last reviewed: March 2026.