ANTI-CORRUPTION POLICY of the Agricultural Paying Agency

• korupcia@apa.sk
• protispolocenska.cinnost@apa.sk

1. This Anti-Corruption Policy of the Agricultural Paying Agency (hereinafter referred to as the ‘Anti-Corruption Policy’) is adopted by the Agricultural Paying Agency (hereinafter referred to as the ‘PPA’) in accordance with the requirements of the ISO 37001:2025 standard (hereinafter referred to as ‘ISO 37001’) and in line with the National Anti-Corruption Strategy of the Slovak Republic for the years 2026–2029 (hereinafter referred to as the ‘Slovak Republic’s Anti-Corruption Policy’).
2. The purpose of the Anti-Corruption Policy is to create, support, continuously improve and further develop a culture of combating corruption based on integrity, transparency, accountability and ethical conduct; to strengthen the prevention of corruption; to minimise the opportunities for corruption and other anti-social activities; to minimise the emergence of corruption risks; and to provide a framework for determining, evaluating and achieving the intended outcomes in the field of corruption prevention. The PPA actively promotes a zero-tolerance policy towards corruption and creates the conditions for detecting and addressing corrupt behaviour.
3. The adopted Anti-Corruption Policy provides a framework for determining anti-corruption objectives and measures.
4. The Anti-Corruption Policy applies to all PPA employees and all persons acting on its behalf, and all of the PPA’s contractual partners are also obliged to comply with it.

For the purposes of the PPA’s Anti-Corruption Policy:

Corruption is defined as the offering, promising, granting, accepting or soliciting of an undue advantage of any pecuniary or non-pecuniary value, or the performance or refraining from performing an action, either directly or through an intermediary, in connection with the procurement of a matter of public interest or in contravention of applicable legislation, as well as a bribe or a reward paid to a person to act or refrain from acting in connection with the performance of their duties, the exercise of their powers, profession or office. The term ‘corruption’ also refers to the abuse of power or position for one’s own benefit or for the benefit of others.

Corrupt behaviour is defined as conduct detrimental to the public interest, in particular the abuse of power, authority, influence or position, incitement to such abuse, clientelism, nepotism, favouritism; extortion, prioritising personal interests over the public interest when performing official or work-related duties, the provision and acceptance of undue advantages without a legitimate claim to a reciprocal service, the misappropriation of public funds, and conduct from which it can reasonably be inferred that a person is signalling their intention to participate in a corrupt relationship.

In accordance with the Anti-Corruption Policy of the Slovak Republic, the Anti-Corruption Programme of the Ministry of Agriculture and Rural Development of the Slovak Republic, organisations within its founding and establishing remit and advance-funded agency under the Ministry’s authority, and the United Nations Convention against Corruption, the term ‘corruption’ is also understood to mean the abuse of power or position for one’s own benefit or for the benefit of others.

A conflict of interest is understood to mean a situation where the impartial, objective and independent performance of the office, work duties or decision-making of an employee or any other person carrying out activities for or on behalf of the PPA is, or may be, compromised, whether for family or emotional reasons, for reasons of political or national affiliation, economic, financial, commercial, organisational or any other direct or indirect personal interest, or where such a situation may appear to be the case from the outside.

1. Any form of corruption is prohibited. Neither PPA employees nor persons acting on its behalf shall accept any gifts, hospitality or benefits which might appear to be intended to influence a decision, undermine the independence and/or impartiality of decision-making, or the acceptance or offering of which might be perceived as corruption.
2. Any natural or legal person with whom the PPA comes into contact has the right to report any suspicion of corruption or other anti-social behaviour on the part of any PPA employee in good faith and on the basis of reasonable grounds, anonymously or non-anonymously, via the anti-corruption line korupcia@apa.sk, electronically at protispolocenska.cinnost@apa.sk, or in person to the person responsible.
3. Employees have the right to report, in good faith, on the basis of reasonable grounds and without fear of any retaliatory action, suspicions of corruption and other anti-social conduct to the person holding the anti-corruption role, i.e. a role responsible for overseeing compliance with and the implementation of anti-corruption regulations and rules, and for combating corruption at the PPA (hereinafter referred to as the ‘supervising officer’).
4. The PPA undertakes to create conditions for the reporting of suspected corruption in accordance with paragraphs 2 and 3, to ensure the proper and timely investigation of such reports, to prevent direct and/or indirect retaliatory action or measures against whistleblowers, and to take corrective measures.
5. Retaliation is prohibited. No one may be penalised for raising concerns about a breach of the anti-corruption management system’s rules and/or for a decision taken in accordance with the regulations and rules governing the PPA.
6. The PPA undertakes to ensure the confidentiality and protection of the identity of any whistleblower.
7. The Director-General shall appoint a supervising officer to the anti-corruption role, who possesses the relevant competence, standing, authority and independence, responsible for the anti-corruption management system at the PPA, and who must not be in a conflict of interest whilst exercising their powers.
8. Contractual partners entering into a contractual relationship with the PPA commit to complying with the principles of the Anti-Corruption Policy set out in this document, at least for the entire duration of the contractual relationship, or, where the nature of the contractual relationship so requires, especially where funds have been provided by the PPA, even after the contractual relationship has ended.

1. The Director-General of the PPA, the Secretary-General of the Agricultural Paying Agency (hereinafter referred to as the ‘Secretary-General’) and all PPA employees shall comply with this Anti-Corruption Policy and must not be in a conflict of interest whilst exercising their powers.
2. All employees are shall inform the PPA without delay of any situation which constitutes or may constitute an actual, potential or apparent conflict of interests.
3. Senior employees in organisational units are responsible and obliged, within their remit, to ensure the application of and compliance with the Anti-Corruption Policy.
4. Any wilful failure to comply with or breach of the rules and regulations arising from the Anti-Corruption Policy, as well as any conduct in contravention of the procedures adopted within the anti-corruption management system, shall be deemed a breach of service or work discipline.
5. Where necessary, the supervising officer shall provide counsel to PPA employees and stakeholders on matters relating to the application of the Anti-Corruption Policy, relevant regulations and rules.

1. PPA enhances the effectiveness of corruption prevention and the anti-corruption management system through mechanisms of corruption risk management. Measures are taken where necessary.
2. The implementation of the anti-corruption management system, as well as the Anti-Corruption Policy in the form of documented information, is regularly monitored, evaluated, subject to proposals for continuous improvement and, where necessary, updated by the supervising officer and the management of the PPA.
3. PPA commits to meeting the requirements arising from the anti-corruption management system and to continuously improving this system. To this end, PPA employees may submit their suggestions to the supervising officer.

1. For the purposes of this document, a ‘contractual partner’ means a supplier, customer, applicant and/or beneficiary who supplies goods and/or services to the PPA or to whom the PPA provides funds in accordance with the relevant legislation, including its owners, statutory bodies, employees, subcontractors and agents who carry out activities in connection with the negotiation, conclusion or performance of a contract with the PPA.
2. PPA expects contractual partners to condemn corruption in any form and to adopt appropriate anti-corruption measures in connection with the negotiation, conclusion or performance of a contract with the PPA. Contractual partners and/or any person acting on its behalf, including its employees and business partners, shall refrain from any form of corruption or activities that could be considered corruption.
3. Contractual partners shall not permit, approve or authorise any conduct in connection with the negotiation, conclusion or performance of a contract with the PPA that would result in the contractual partners breaching any applicable generally binding anti-corruption legislation.
4. Contractual partners shall not offer, provide or undertake to provide any employee, representative or third party acting on behalf of the PPA, nor must it accept or undertake to accept from any employee, representative or third party acting on behalf of the PPA any inappropriate gift or other benefit, whether monetary or otherwise, in connection with the negotiation, conclusion or performance of a contract with the PPA.
5. PPA reserves the right, in cases of doubt, to carry out such checks as it deems necessary in order to ensure compliance with the Anti-Corruption Policy as set out in this document; in the event of suspected corruption, contractual partners are obliged to provide PPA or other relevant authorities with the necessary cooperation.
6. Any breach of this Anti-Corruption Policy by the contractual partner shall be subject to sanctions commensurate with the seriousness of the conduct and the severity and extent of the consequences of the breach, in accordance with the contract concluded with the business partner or in accordance with generally applicable legislation. Any breach of the anti-corruption principles set out in this document constitutes a material breach of contract by the contractual partner, and the PPA is entitled to terminate the contract immediately, unless other penalties are agreed in the contract.
    

Version 2 of the document

In Bratislava, July 7, 2026