Anti-bribery policy

Introduction

This Anti‑Bribery and Anti‑Corruption Policy sets out BOND47’s commitment to conducting all business honestly, fairly, and in full compliance with applicable anti‑corruption laws. It applies to all employees, directors, contractors, and anyone acting on our behalf, as well as to third parties we work with, including agents, distributors, and intermediaries.

Zero‑tolerance approach

BOND47 has a zero‑tolerance approach to bribery and corruption in any form. No one may offer, give, request, or accept a bribe, kickback, facilitation payment, or any other improper advantage, whether in dealings with public officials or in private business relationships. This applies to financial and non‑financial benefits, including gifts, hospitality, services, or favours intended to improperly influence a decision.

Gifts, hospitality, and entertainment

Reasonable, proportionate hospitality and business gifts may be acceptable when they are transparent, infrequent, and clearly not intended to secure an improper advantage. Lavish or extravagant gifts or entertainment are prohibited. All employees must follow internal approval and recording procedures for gifts and hospitality, and local limits may apply depending on role and jurisdiction.

Third parties and intermediaries

BOND47 can be held responsible for the actions of third parties acting on its behalf. Agents, consultants, distributors, and other intermediaries must be carefully selected, contractually bound to comply with anti‑bribery requirements, and monitored where appropriate. No payments may be made to third parties if there is reason to believe that any part of the payment will be used for bribery or other improper purposes.

Political and charitable contributions

BOND47 does not make political donations on behalf of the company unless approved at the highest appropriate level and in full compliance with the law. Charitable donations and sponsorships must be transparent, properly documented, and never used as a channel for bribery or personal gain.

Books, records, and controls

All transactions must be accurately recorded in BOND47’s books and records, and supported by appropriate documentation. False or misleading entries are strictly prohibited. The company maintains internal controls and approval processes designed to prevent and detect bribery and corruption risks.

Responsibilities and training

Every employee and representative is responsible for understanding and following this Policy, completing any required training, and seeking guidance when in doubt. Managers are expected to lead by example, promote a culture of integrity, and ensure that their teams are aware of the rules and how to apply them in daily work.

Reporting concerns

Anyone who suspects actual or potential bribery, corruption, or related misconduct is encouraged to report their concerns promptly through their usual management channels or via designated reporting mechanisms. Reports will be handled sensitively and, as far as possible, confidentially. Retaliation against any person who raises a concern in good faith is not tolerated.

Consequences of violations

Breaches of this Policy or applicable anti‑corruption laws may result in disciplinary action, up to and including termination of employment or contract, as well as civil or criminal penalties for the individuals involved and for the company. BOND47 reserves the right to terminate relationships with third parties who fail to comply with this Policy.