BeamSec Anti-corruption and Bribery Policy

 

1. About this policy

BeamSec Ltd is committed to conducting all aspects of our business in an honest, ethical, and lawful 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. BeamSec Limited is located at Britannia House, 11 Glenthorne Road, London, W6 0LH, United Kingdom.

We take our legal obligation to prevent bribery and corruption seriously, and we will ensure that our business is always conducted with compliance to both the UK’s Bribery Act 2010 and the US’s principal anti-bribery legislation, the Foreign Corrupt Practices Act (FCPA).

2. Purpose and Scope of This Policy

This policy outlines our responsibilities in observing and upholding our position on bribery and corruption. It also provides a coherent and consistent framework to enable our employees to understand and implement arrangements for compliance.

This policy applies to all persons working for us or on our behalf in any capacity, wherever located, including Overseas Employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

3. What is bribery and corruption?

Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.

Bribery includes offering, promising, giving, accepting, or seeking a bribe.

The Bribery Act: There are 4 key offences under the Act.

1. Bribery of another person
2. Accepting a bribe
3. Bribing a foreign official
4. Failing to prevent bribery.

All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with your manager as soon as possible

Specifically, you must not:

• give or offer any payment, gift, hospitality, or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
• accept any offer from a third party that you know, or suspect is made with the expectation that we will provide a business advantage for them or anyone else;
• give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or expedite speed up an action
• retaliate against or threaten a person who has refused to commit a bribery offence or who has raised concerns under this policy
• engage in activity in breach of this policy

You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

4. Corruption is the abuse of entrusted power or position for private gain.
5. Gifts and hospitality

This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.

A gift or hospitality will not be appropriate if it is unduly lavish or extravagant or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).

Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers) or be given in secret. Gifts must be given in our name, not your name. Gifts must be reasonable, proportionate, and made in good faith.

Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers, and business partners.

6. Record-keeping

We must keep financial records and have appropriate internal controls in place to evidence the reasons for making payments to any third parties. You must declare and keep a written record of all hospitality or gifts given or received. These will be subject to managerial review. You must also submit all expenses claims relating to hospitality, gifts, or payments to third parties in accordance with our expenses policy and record the reason for expenditure.

7. Donations

We do not make contributions or charitable donations to political parties. We only make charitable donations that are legal and ethical under U.K. laws and practices.

All accounts, invoices, and other records relating to dealings with third parties should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

8. How to raise a concern

We encourage openness, and will support anyone who raises a genuine concern about the potential occurrence of bribery or corruption in good faith under this policy. We want our staff to know how they can raise any concerns.

You are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible opportunity. We have a duty to help detect, prevent and report instances of bribery.

We are committed to ensuring that no one suffers any detrimental treatment as a result of refusing to take part in any corruption or bribery, or as a result of reporting any corruption or bribery.

9. Breaches of this policy

Any employee who breaches this policy will face disciplinary action, which can result in dismissal for misconduct or gross misconduct. We may terminate any relationships with other individuals or parties working on our behalf if they breach this policy.

BeamSec Ltd commits to regular, comprehensive training programs to foster a deep understanding and adherence to our Anti-corruption and Bribery Policy. This training will be mandatory for all employees, with a focus on those in high-risk positions and regions. Additionally, we will extend relevant training modules to our business partners to align with our ethical standards. The training will be conducted annually, with refresher sessions following any significant policy updates or relevant changes in anti-corruption legislation.

 

10. Risk Assessment

To proactively manage and mitigate the risks of bribery and corruption, BeamSec Ltd will conduct bi-annual risk assessments across all business units and operations. These assessments will identify potential risk areas and inform necessary updates to our policy and internal control measures. The results and recommendations from these assessments will be reviewed by the compliance team and shared with senior management for action.

11. Monitoring and Review

BeamSec will establish ongoing monitoring mechanisms to ensure compliance with our Anti-corruption and Bribery Policy. This will include regular audits and reviews of our practices, procedures, and transactions, especially those related to high-risk areas. The policy will be reviewed and updated annually, or more frequently if required, by the compliance officer in collaboration with senior management to ensure it remains current and effective.

12. Third-Party Due Diligence

Recognizing the risks third parties might pose in relation to bribery and corruption, BeamSec Ltd will conduct thorough due diligence before establishing any new partnerships or contracts. This due diligence process will assess the third party’s reputation, legal compliance, and anti-corruption policies. Ongoing monitoring of existing third parties will also be conducted to ensure continued compliance. All due diligence findings will be documented and reviewed periodically.

13. Response Plan

Upon receipt of a bribery or corruption allegation, BeamSec Ltd will initiate a prompt, thorough investigation led by our compliance team. The process will include steps from the initial report to conclusion, ensuring fairness and confidentiality throughout. Follow-up actions may include disciplinary measures, policy revisions, or additional training, as appropriate.

14. Governance and Oversight

The Board of Directors of BeamSec Ltd appoints a senior executive as the Anti-corruption and Bribery Compliance Officer. This officer is tasked with overseeing the implementation, enforcement, and periodic review of the Anti-corruption and Bribery Policy, demonstrating the importance of this matter at the highest organisational level.

15. Policy Accessibility

BeamSec Ltd is committed to making the Anti-corruption and Bribery Policy accessible to all employees and relevant third parties. The policy will be available on the company’s internal website or portal, in clear, understandable language. All stakeholders are encouraged to familiarise themselves with the policy to understand their role in maintaining our ethical standards.

 

If you have any questions regarding this policy, please contact hello@beamsec.com