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Anti-Corruption Policy

Anti-Corruption Policy


The purpose of this Policy is to establish behavioral standards that minimize the risk of corruption within Belmar.

Any person employed by, working for, or acting on behalf of Belmar, anywhere in the world, is bound by this Policy.

Intermediaries and other trading partners must act in an ethical manner, and they may be requested to comply with this policy for all their transactions with Belmar.

Compliance with this Policy and all applicable anti-corruption laws is critical, both for your protection and for Belmar’s protection. Here are the reasons why we must each comply with it:

  • corporate culture: corruption is totally contrary to the culture of ongoing improvement, irreproachable behavior and intellectual honesty. Compliance with this Policy is vital to maintaining this culture;
  • reputation: an image, a reputation and a position can very easily be injured or destroyed by any breach of the law or this Policy. This will also impact the trust and the relationships that Belmar has established on the market with its customers and other stakeholders since 1978;
  • legal obligations: according to the law, Belmar will be found guilty if the company does not take the necessary measures to prevent acts of corruption being caused by its employees or sub-contractors;
  • criminal sanctions: in most countries, corruption is a criminal act. Failures can occur even if the offense takes place abroad. Goods that come from an act of corruption can also be seized;
  • civil sanctions: in many jurisdictions, those who have incurred damage or a loss of contract because of an act of corruption can claim compensation for such damages;
  • investigations: investigations into suspected offenses may represent a loss of time and money for the company and create bad publicity;
  • disciplinary procedures: any non-compliance with this Policy, or with any procedure for the implementation of this Policy, will be treated as a serious problem by Belmar and may result in disciplinary action and a report made to the appropriate authorities. If a trading partner does not comply with this Policy, Belmar will consider terminating the partnership.



Corruption: definitions

Corruption is the act of promising, offering, giving, requiring or accepting, directly or through the intermediary of a third party, any advantage aimed to induce or reward inappropriate behavior (illegal, unethical or a breach of an obligation).

Corruption has taken place even if the process of corruption stops short or does not produce the expected effect.

The “advantages” may be financial or not and include the following:

  • money, loans, donations (including to charitable associations), market attribution, work contracts, consulting contracts, preferential treatment, confidential information, gifts and invitations, vacations;
  • any other advantage or benefit designed to have, or perceived as having value for the recipient or another close person.

The act of corruption may be committed by:

  • any employee of Belmar, regardless of his or her seniority or grade regardless of the place in the world;
  • any other person performing services on behalf of Belmar regardless of the place in the world (third parties such as agents, intermediaries, subcontractors and suppliers).

Corruption can occur in both the public sector and the private sector.

Warning signs:

  • abnormally high commissions or unusual payment methods;
  • third parties about which we have little information. Example: a dubious transaction history, with very limited information or inaccessible or recently created information;
  • third parties that are under-qualified or with insufficient human resources, specified or recommended by public officials;
  • repeated or excessive examples of gifts and hosting;
  • requests to hide/cover unusually high expenditure, or expenses of relations or family members;
  • hosting a promotion or a demonstration of products or services without a legitimate reason;
  • a history or a perception of corruption in the country in question;
  • payments to or from officials or individuals who may be politically exposed.

Belmar Policy

Belmar has a Policy of zero tolerance with regard to corruption, therefore:

  • employees, including sub-contractors, should never promise, offer or issue advantages, of any nature;
  • they must never demand or accept a bribe;
  • no employee will be the victim of a demotion, sanctions or other negative consequences for refusing to pay or accept a bribe, even if the refusal may result in the loss of a transaction for Belmar;
  • our policy controls the donation and the acceptance of gifts, of invitations/entertainment, charitable donations or sponsorship.



Conflicts of interest

Employees of Belmar must act in such a way as to avoid any conflict of interest:

  • private arrangements concerning goods and services intended for personal use acquired through the procurement departments of Belmar;
  • private arrangements concerning the use of discounted terms and conditions unless they have been formally negotiated by Belmar as a staff benefit and have been announced as available to all staff.
  • any employee or agent whose role involves negotiating or authorizing a contract with a third party must immediately declare any shareholding in this third party company, its holding company, its subsidiaries or associated companies, unless the shareholding is in a publicly traded company listed on the stock exchange and represents less than 5% of the issued share capital;
  • employees may not authorize the payment of company funds to an external organization or a charity of which they are shareholders, board members, a director or are otherwise employed;
  • commercial decisions, in particular meetings and market attributions, must not be influenced by any personal, family or other relationship, or by membership of any religious, social or political association.

Commercial Transactions and Contacts

Any transaction with companies or private individuals, public officials, must remain clear and transparent and be conducted in a correct and appropriate manner.

Belmar can be held responsible for the actions of its agents, intermediaries, and other trading partners (including suppliers and sub-contractors). Therefore:

  • Belmar only works with agents, intermediaries and other trading partners that have been approved by the General Management of the company;
  • any compensation payable to agents or other trading partners acting on behalf of Belmar must correspond to the services performed, determined in an objective manner;
  • the payments must be made by legal means;
  • facilitation payments made to an official to perform or accelerate the performance of a routine action or necessary action to which the payer has a legal or other right, such as obtaining a license or a visa, are illegal payments and are in no case acceptable;

Belmar has a policy of keeping records, files, and transparent and accurate financial reporting.




If you know that an act of corruption has taken place, or suspect that one has taken place, within (or in connection with) Belmar, you must immediately inform Senior Management.

Belmar commits to ensuring that employees can report their problems in complete confidentiality. All reports are taken seriously and we shall investigate accordingly; reprisals against an employee who reported a problem are strictly prohibited.

You should also contact Senior Management if you have any general questions regarding this Policy, or the way in which the rules apply in specific circumstances.