ANTY-BRIBERY AND CORRUPT POLICY
Be Talent Limited (the “Company”) strives to undertake our business fairly with honesty and transparency. This must be reflected in every aspect of our business affairs.
This policy affects all our employees and associates.
Good relations with our partners, customers, governments and other stakeholders are one of the keys to our success. We can all help build healthy relationships by behaving honestly, with integrity and with respect for people. Failure to do so erodes trust and undermines the foundations on which we build our lives and our business.
Please do your part by studying this policy and acting in accordance with its guidelines.
The Company is committed to implementing and enforcing effective systems to counter bribery. It is the Company’s policy to conduct all aspects of its business in an honest and ethical manner at all times.
The Law in the UK and Jersey
Under the UK Bribery Act 2010 (the “Bribery Act”), bribery and corruption is punishable for individuals by up to ten years' imprisonment. If any company is found to have taken part in the corruption or lacks adequate procedures to prevent bribery, it could face an unlimited fine and be excluded from tendering for government contracts.
We expect that compliance with the Bribery Act will help with compliance with our international obligations in this regard. However, it is your responsibility to ensure you comply with all local statutory and regulatory obligations.
The aim of adopting this policy across the Company is to meet the higher requirements of the Bribery Act, and to maintain the highest possible standards of business practice, and advise individuals of the Company’s 'zero-tolerance' to bribery.
Be Talent does not tolerate bribery, insider dealing, market abuse, fraud or money laundering. Facilitation payments are bribes and must not be paid. Any real or potential conflicts of interest (or the appearance of a conflict) must be avoided and inappropriate gifts or hospitality should never be offered or accepted.
Even unsubstantiated claims of corruption can damage reputations and the business.
The guidelines contained in this policy are the boundaries within which every Be Talent employee must operate every day.
This policy applies to all individuals working for the Company and any subsidiary or entity under the control of Be Talent Ltd. Contractors, partners or consultants who are our agents or working on our behalf or in our name will be required to act consistently with the policy.
Policy Statement for Employees, Contractors and Agents
Bribery occurs when you: offer, pay, seek or accept a payment, gift or favour to influence a business outcome improperly. Bribery and corruption, whether involving government officials or commercial entities can be direct or indirect through third parties such as agents and joint venture partners. It includes facilitation payments, even though in some countries facilitation payments are legal. Even turning a blind eye to your suspicions of bribery and corruption can result in liability to the individual or the Company.
You should not:
- Make or receive contributions of any kind with the purpose of gaining any improper commercial advantage;
- Provide or accept gifts or hospitality in return for favourable treatment, to influence a business outcome or to gain a business advantage;
- Make, or accept, “kickbacks” of any kind.
- Ensure people you work with understand bribery and corruption is unacceptable;
- Encourage employees to raise concerns about any issue or suspicion of malpractice at the earliest possible stage;
- See that anyone raising a concern about bribery will not suffer any detriment as a result, even if they turn out to be mistaken.
Be Talent is required to keep financial records and to have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
Gifts and Hospitality
This policy does not prohibit giving and receiving promotional gifts of low value, or normal and appropriate hospitality.
Gifts and hospitality should never be allowed to influence your business decisions or cause others to perceive an influence.
- Receiving promotional gifts of low value is normal and appropriate;
- Any gift offered and then refused because of its value, must be reported to the relevant officer noted below;
- Business gifts are primarily aimed at thanking customers and suppliers for their custom and loyalty, only authorised gifts may be given.
- The acceptance of corporate hospitality must be transparent; all invitations must be reported to the relevant officer before an employee accepts any invitation. Business and travel expenses incurred and normal business lunches and meals are exempt.
- Any gifts or hospitality offered to a government official must have prior approval from the relevant officer;
- Gifts and hospitality must never be offered to the spouses, family members or guests of a government official;
- Non-business travel and hospitality should never be offered to any government official.
You should decline gifts or hospitality if you would feel uncomfortable telling your line manager or supervisor, colleagues, family, friends or the public that you have accepted them.
- Relevant company board approval is required before any charitable donations are made;
- The Company does not make political donations. Such donations may impact our business or reputation.
Be Talent is committed to free, fair and ethical enterprise. You must follow all applicable trade laws and ensure that Be Talent’s core values are applied in all business dealings.
Competition laws protect free enterprise and prohibit behaviour that limits trade or that restricts fair competition such as: price-fixing, market-sharing or bid-rigging. The laws apply to every level of business.
You must not:
- Agree with others not to compete in particular markets or for particular customers or accounts;
- Rig bids or tenders;
- Agree on minimum resale prices with resellers or partners.
Import & Export Controls
Import and export sanction laws give countries legal control over the sale, purchase, shipment, electronic transfer or disclosure of information, software, goods and services across borders.
Controls, sanctions and embargoes can be imposed on countries, entities, individuals or goods.
While in the context of the Be Talent activities it is viewed as unlikely that we would fall foul of these regulations, we endeavour to not knowingly trade in countries or with entities that are subject to controls and sanctions.
In the event of a breach of the policy by other organisations, or individuals, the Company will take appropriate action which may include terminating any business relationships.
If you have any concerns or require any advice you should talk to:
- Your line manager or supervisor;
- Your account manager if you are not an employee;
- The relevant officer noted below or any other Director or senior manager with whom you feel comfortable having a conversation.
The policy will be monitored on an ongoing basis to ensure that it addresses issues effectively.
The following will be monitored:
- That all individuals working for the Company are advised of the policy;
- Assessment of any reported incident or related occurrence.
Monitoring of the policy is essential to assess how effective the Company has been to establish control of its obligations.
This policy will be reviewed and, if necessary, revised in the light of legislative or organisational changes. Improvements will be made by learning from experience.
The Board of Be Talent Limited is committed to and has overall responsibility for the policy.
The relevant officers who are responsible for logging matters relating to this policy and giving approvals where appropriate are the following Director:
Managers must ensure compliance by their teams.
All employees should play an active role in ensuring compliance with the policy.
Policy Statement for Partners
The Company only wishes to do business with partners who operate with ethical standards that match international best practice. Be Talent expects its partners to have a ‘zero-tolerance’ approach to bribery and corruption and to abide by sanction orders and trading laws applicable to their business. By accepting Be Talent’s standard terms and conditions each partner confirms that they have appropriate measures in place to prevent such practices. Be Talent reserves the right to request documentation and further assurance in this regard.
Translations of the Be Talent Anti-Bribery and Corrupt Practices Policy into languages other than English are provided for information and convenience. For the definitive and binding version, please refer to the English language version which shall prevail in the case of any discrepancies between it and the translated versions.
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