B2C2 Ltd and its affiliates (“B2C2”) conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate. We also implement and enforce effective systems to counter bribery and corruption. B2C2 is committed to adhering to relevant law, rules and regulation related to bribery and corruption.  This includes the jurisdictions in which B2C2 is based and/or incorporated but also in respect of business it may conduct in other jurisdictions globally.

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It is a criminal offence to offer, promise, give, request, or accept a bribe.  Individuals found guilty can be punished by imprisonment and/or a fine. As an employer, if we fail to prevent bribery, we can face an unlimited fine, exclusion from tendering for public contracts, and damage to our reputation. We therefore take our legal responsibilities very seriously. 

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Bribery is offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage. 

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An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.

A person acts improperly where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organisation of any kind. 

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Corruption is the abuse of entrusted power or position for private gain. 

We do not make, and will not accept, facilitation payments or "kickbacks" of any kind. 

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Giving and receiving of gifts and entertainment is part of normal business practice and is commonly used as a mark of friendship, goodwill and to strengthen working relationships among business partners. However, in some cases the giving and/or receiving of gifts and/or entertainment can create the appearance of, or an actual conflict of interest, improper inducement and/or bribery and corruption.

Consequently, giving or receiving gifts or entertainment is in some cases prohibited. In other situations, giving or receiving gifts or entertainment above certain thresholds requires pre-approval from line managers, Compliance and/or an Exco member.

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B2C2 does not make contributions to political parties and staff are encouraged to discuss with Compliance on a strictly confidential basis if they intend to make a material personal political donation.

B2C2 only makes charitable donations that are legal and ethical under local laws and practices and subject to internal approval.