Anti-Bribery and Anti-Corruption Statement
INTRODUCTION:
BGO SOFTWARE LTD strives to conduct business honestly, fairly, ethically, free from corruption, and in compliance with the applicable laws. BGO SOFTWARE LTD does not tolerate corruption or bribery and requires our employees, subcontractors, vendors, customers, and other business partners to comply with applicable anti-bribery and anti-corruption laws including local legislation, Bribery Act 2010 of the United Kingdom (often referred to as the UK Bribery Act) and European Union’s November 2015 Anti-Corruption Law.
Bribery is a form of corruption in which there is an abuse of entrusted power or position for private gain.
A bribe refers to any form of inducement, reward, or compensation offered, promised, provided, or received with the intention of securing an unfair commercial, contractual, regulatory, or personal advantage. It is illegal to offer, promise, give, request, or accept a bribe, and those found guilty can face criminal penalties, including imprisonment and/or fines.
Bribery is unacceptable in all its forms. BGO SOFTWARE LTD considers it unacceptable for its employees, subcontractors, vendors, customers, and other business partners to, for example:
- Offer, promise, or provide a payment, gift, or hospitality with the intention of gaining an unfair business advantage.
- Provide a payment, gift, or hospitality to a government official, agent, or representative in exchange for expedited or facilitated services.
- Accept a payment from a third party if you know or suspect it was offered with the expectation that it would benefit your organization.
- Accept a gift or hospitality from a third party if you believe it was provided with the expectation of receiving a business advantage in return.
- Intimidate or threaten another employee who has refused to engage in bribery or has reported concerns under our company's policies.
- Engage in any activity that might lead to a breach of any applicable BGO SOFTWARE LTD policy.
DONATIONS:
BGO SOFTWARE LTD makes charitable donations that are legal and ethical under local laws and practices. BGO SOFTWARE LTD does not permit facilitation payments.
RECORD KEEPING:
The company maintains accurate financial records and have established robust internal controls to ensure transparency and accountability. Additionally, we keep a written record of all hospitality and gifts received or provided, in compliance with our internal policies. All transactions, including those with third-party suppliers and customers, are subject to rigorous internal audits and monitoring. Furthermore, we do not permit the creation of "off-book" accounts, which could be used to facilitate or conceal improper payments.
RAISING CONCERNS:
At BGO SOFTWARE LTD, we foster an open culture where our employees, subcontractors, vendors, customers, and other business partners are encouraged to report any concerns or suspicions of corruption or bribery at the earliest opportunity. We do not tolerate retaliation against anyone who refuses to engage in corrupt practices or reports such concerns, even if it results in a loss of business. Instead, we support employees who raise genuine concerns in good faith, regardless of the outcome.
We also take disciplinary action against any employee who fails to comply with our anti-corruption and anti-bribery policies, which may result in penalties up to and including termination. Similarly, we reserve the right to terminate relationships with consultants, contractors, suppliers, customers, or other business partners if they breach our anti-corruption or anti-bribery policies or related laws.
Ivan Lekushev
Chief Executive Officer
January 17th, 2024
