Anti-Corruption and Anti-Bribery Policy
of
Next Logistics Ltd.
Plovdiv, 36 Rogoshko Shose St.

Version 1.2
Last updated: 11.11.2025

As a leader in the logistics sector, “Next Logistics” Ltd. recognizes its contribution and responsibility towards the entire logistics industry, as well as towards all its counterparties and employees. The company is fully committed to conducting ethical, transparent, and lawful business operations and maintains zero tolerance for all forms of bribery and corruption.
This policy establishes the principles and rules that all employees, managers, partners, and suppliers must follow in order to prevent, recognize, and report cases of bribery and corrupt practices.

Main principles and rules of “Next Logistics” Ltd.:

  • Zero tolerance for bribery and corruption – “Next Logistics” Ltd. ensures that the company and all employees and counterparties are aware of the meaning and significance of these terms, in order to prevent, recognize, and report them.
  • “Next Logistics” Ltd. conducts verification and identification of all individuals and organizations it works with. In case of suspicion of abuse, bribery, or corruption, it is reported to the competent persons and/or authorities, according to the established procedure.
  • Participation in any form of bribery, whether directly or through intermediaries, is prohibited.
  • Prohibition of offering or accepting benefits – No employee has the right to offer, provide, receive, or request gifts, money, or services that could affect the objectivity of business decisions.
  • Counterparties we work with are not allowed to offer bribes to influence the company’s business decisions.
  • Only symbolic gifts or gestures of courtesy are allowed, which do not create obligations and are in accordance with good business practices.

The policy aims to:

  • Ensure that all company activities are conducted honestly and in accordance with the law;
  • Prevent any form of bribery, fraud, abuse of influence, conflict of interest, money laundering, or corruption, emphasizing that these are illegal actions and crimes under the laws of the Republic of Bulgaria and international legislation;
  • Protect the reputation and trust in “Next Logistics” Ltd.

Objectives to be achieved by 31.12.2026:

  • Establish a culture of ethics and transparency among employees and partners;
  • Improve procedures for recognizing and preventing bribery, fraud, abuse of influence, conflict of interest, money laundering, or corruption;
  • Increase awareness of suppliers and counterparties regarding company requirements;
  • Implement annual monitoring and checks regarding corruption risks.

Definitions:

  • Bribery – Giving, receiving, or requesting an unlawful benefit (such as money, gifts, services, or others) with the purpose of influencing the decisions or actions of a person holding a position of authority or responsibility.
  • Corruption – Using one’s official or professional position for personal gain or the benefit of third parties, in violation of the law or ethical norms.
  • Conflict of interest – A situation in which a person faces a choice between their duties to the organization and personal interests that may affect the objectivity of their decisions.
  • Fraud – Deliberately misleading others to illegally or unfairly obtain a benefit.
  • Money laundering – Actions taken to conceal the origin, ownership, or intended use of funds obtained illegally or unfairly.

Actions required from employees and counterparties:

  • Comply with the principles of zero tolerance for bribery, fraud, abuse of influence, conflict of interest, money laundering, or corruption;
  • Report any suspected violations;
  • Participate in ethics and anti-corruption trainings and briefings;
  • Provide documents and evidence for compliance with the policy;
  • Implement internal procedures to prevent corruption and abuse.

Transparency and accountability:

All financial and business operations must be accurately, correctly, and properly documented, in accordance with legal requirements.

Expected results:

  • Transparent and ethical business relationships based on trust;
  • Reduction of corruption risks and incidents;
  • Improved accountability and business process management;
  • Documented traceability of actions and policy implementation.

Scope of the policy:

  • All employees and managers of “Next Logistics” Ltd.;
  • All business partners, suppliers, subcontractors, and consultants working on behalf of or with the company.

Relevance:

Requirements apply according to the nature of the employee’s or counterparty’s activity, taking into account:

  • Role and responsibilities within the company;
  • Potential risks of bribery, fraud, abuse of influence, conflict of interest, money laundering, or corruption;
  • Frequency and significance of interaction with the company.

Traceability and monitoring:

  • Maintaining registers and archives of reported violations and actions taken;
  • Annual compliance assessment and risk analysis;
  • Documenting incidents, corrective measures taken, and results;
  • Possibility of extraordinary checks in case of suspicion or increased risk.

Evidence:

  • Internal anti-bribery, fraud, abuse of influence, conflict of interest, money laundering, or corruption policies and procedures;
  • Training and briefing documents;
  • Registers of submitted reports and actions taken;
  • Declarations of understanding the meaning of terms and compliance with the principles of zero tolerance for bribery, fraud, abuse of influence, conflict of interest, money laundering, or corruption;
  • Audits or compliance checks, where available.

Reporting violations:

Any employee who suspects bribery, corruption, or any other form of abuse is obliged to immediately report to:

  • Their direct supervisor;
  • The Legal Department;
  • Through the internal reporting channels of “Next Logistics” Ltd.

If necessary and after verification, the company reports to the relevant competent authorities. All reports are treated confidentially, and good-faith reporters are protected from retaliation.

Sanctions for non-compliance with the policy and/or the law:

  • Official written warning;
  • Requirement for corrective actions within 30 days;
  • Temporary suspension of access or participation in work;
  • Financial penalties provided in the contract/order;
  • Termination of the contract/cooperation and removal from the approved partner list;
  • Notification of competent state authorities in case of legal violations.

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