Belmar's anti-corruption policy

Objectives

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

All persons employed by, working for, or on behalf of Belmar, anywhere in the world, are bound by this policy.

Intermediaries and other business partners are expected to act ethically and may be required to comply with this policy in all their dealings with Belmar.
to this policy in all their dealings with Belmar.

Compliance with this policy and all applicable anti-bribery laws is essential for both your protection and Belmar's. Here are the reasons why each of us must comply:

Corporate culture: corruption is totally at odds with our culture of continuous improvement, irreproachable behavior and intellectual honesty. Compliance with this policy is vital to maintaining this culture;
Reputation: image, reputation and position can very easily be damaged or destroyed by any breach of the law or of this policy. It would also affect the trust and relationships that Belmar has built up in the marketplace 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 subcontractors;
Criminal sanctions: in most countries, corruption is a criminal offence. Breaches can occur even if the offence took place abroad. Assets resulting from an act of corruption may also be seized;
Civil penalties: in many jurisdictions, those who have incurred damages or loss of contract as a result of an act of corruption can claim compensation for these damages;
Investigations: investigating suspected offences can cost the company considerable time and money, and cause bad publicity;
Disciplinary Procedures: Any failure to comply with this policy, or any procedure for enforcing this policy, will be treated as a serious matter by Belmar and may result in disciplinary action and a report to the appropriate authorities. If a business partner fails to comply with this policy, Belmar will consider termination of the partnership.

Corruption: definitions

Corruption is the act of promising, offering, giving, demanding or accepting, directly or through a third party, any advantage or benefit.any advantage to induce or reward improper (illegal, unethical or breach of duty) behavior.

Corruption is proven even if the corrupting process is short-lived or does not have the desired effect.

The "benefits" may be financial or non-financial and include the following:

Money, loans, donations (including to charities), contract awards, employment contracts, consultancy contracts, preferential treatment, confidential information, gifts and invitations, vacations;
Any other advantage or benefit intended, or perceived, to be of value to the recipient or another person close to the recipient.

The act of corruption may be committed by :

Any Belmar employee, regardless of seniority or rank, anywhere in the world;
Any other person performing services on behalf of Belmar anywhere in the world (third parties such as agents, intermediaries, subcontractors and suppliers).

Corruption can occur in both the public and private sectors.

Alarm signals :

Abnormally high commissions or unusual payment methods;
Third parties about whom we have little information. Example: a murky transaction history, with very limited or inaccessible information, or recently created;
Third parties appearing under-qualified or with insufficient human resources, specified or recommended by
public officials;
Repeated or excessive examples of gifts and hospitality;
Requests to hide/cover up unusually high expenses, or expenses incurred by relations or family members;
Hospitality with no legitimate connection to the promotion or demonstration of products or services;
A history or perception of corruption in the country in question;
Payments to or from public officials or individuals who may be politically exposed.

Belmar Policy

Belmar has a zero-tolerance policy when it comes to corruption:

Employees, including subcontractors, must never promise, offer or pay benefits of any kind;
They must never demand or accept a bribe;
No employee will be subject to demotion, sanctions or other adverse consequences for refusing to pay or receive bribes, even though the refusal may result in a loss of business for Belmar;
Our Policy controls the giving and acceptance of gifts, invitations/entertainment, charitable donations or sponsorship.

Conflict of interest

Belmar employees must act in a manner that avoids any conflict of interest:

Private arrangements for goods and services for personal use acquired through Belmar's purchasing services;
Private arrangements regarding the use of discount terms unless this has been formally negotiated by Belmar as a staff benefit and has been advertised as available to all staff;
An employee or agent whose role involves the negotiation or authorization of a contract with a third party must immediately declare any shareholding in that third party company, its holding company, subsidiaries or associated companies, unless the shareholding is
in a listed company and represents less than 5% of the issued share capital;
Employees may not authorize the payment of company funds to any outside organization or charity
of which they are a shareholder, board member, director or other employee;
Business decisions, including appointments and contract awards, must not be influenced by any personal, family or other relationship, or by membership of any religious, social or political association.

Business transactions and contacts

All transactions with private companies, individuals and public officials must remain clear and transparent, and be carried out correctly and appropriately.

Belmar can be held responsible for the actions of agents, intermediaries, and other business partners (including suppliers and subcontractors), therefore :

Belmar only works with agents, intermediaries and other business partners that have been approved by the company's General Management;
Any remuneration payable to agents or other business partners acting on Belmar's behalf must correspond to objectively determined services performed;
Payments must be made by legal means;
Facilitation payments made to a public official to secure or expedite the performance of a routine or necessary action to which the payer has a legal or other right, such as obtaining a permit, license or visa, are illegal payments and are not acceptable under any circumstances.

Belmar's policy is to maintain transparent and accurate financial records, files and reports.

Important

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

Belmar is committed to ensuring that employees can report concerns confidentially. All reports are taken seriously and will be investigated accordingly; retaliation against an employee for reporting a concern is strictly prohibited.

You should also contact Management if you have any general questions about this Policy, or about how the rules apply in specific circumstances.