Anti-corruption policy

This Policy aims to establish behavioral standards that minimize the risk of corruption within the BOËT Group. This Policy applies to all of us, including those who act on our behalf, anywhere in the world.

Namely: the laws in most countries make attempted or proven acts of corruption liable to prosecution, with significant penalties for companies and employees, including fines and/or prison sentences.

In order to be a responsible and trustworthy company, the BOËT Group has adopted a Zero Tolerance Policy to Corruption. Any non-compliance with this Policy will be treated as a serious problem by the Group and will result in disciplinary action.

What is corruption?’s

Corruption means:

Offer, promise or give (active corruption), or

Request, request, receive or accept to receive (passive corruption)

Something of value in exchange for an incentive to act or fail to act inappropriately, illegally, corrupt, unethically or by breach of trust. Corruption as defined in this policy includes bribes, extortion or solicitation, influence peddling or the laundering of the fruits of these practices.

Corruption occurs when benefits are offered directly or indirectly to third parties, including government agents, suppliers, business partners, customers or prospects, for their personal interest, in order to influence their actions or decisions in the context of their official or professional function.

The benefits can be financial, or not:

They may include cash or equivalents, meals, entertainment, travel, gifts, hiring, contracts, benefits in kind, or any other type of similar goods or services of tangible economic value.

How to behave towards gifts and other forms of hospitality?

Gifts and invitations must never influence decisions, or be perceived as having influenced these decisions.

However, there are exceptions:

The exchange of small gifts or invitations of low value (less than €50) can, occasionally, constitute a simple contribution to current business relationships.

Our local partners should not be offended by refusing a gift when offering such a gift is a local custom acceptable and authorized by local legislation.

In summary, giving or promising free gifts or services is prohibited, unless, in a context of courtesy and hospitality, these gifts have symbolic value.

For any questions, concerns or if you are not sure how to react in a given situation, we advise you to contact your Management. The Management also undertakes to assure you that no harm will be caused to anyone who is in good faith aware of the company of suspected infringement or refuses to take part in corruption activities.

I ask everyone to take an active role in developing a culture where corruption has no place and remains unacceptable in all its forms. Please take the time to read this Policy carefully, to ensure that you understand your obligations, for your protection and that of the company.