Financial Crime World

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Bribery and Corruption Policy

Scope

This policy applies to all employees, contractors, and third-party vendors working with BIL Group worldwide.

Definition of Bribery and Corruption

Bribery and corruption include offering, giving, or receiving anything of value, directly or indirectly, in exchange for an improper advantage. This includes but is not limited to:

  • Paying bribes
  • Soliciting or accepting bribes to influence a decision or commit an act
  • Making facilitation payments
  • Using another party to conduct these activities
  • Processing funds known to be proceeds of bribery or corruption

Prohibited Activities

BIL Group prohibits the following activities:

Giving, Promising, or Offering Payments, Gifts, or Hospitality

Giving, promising, or offering a payment, gift, or hospitality with expectation or hope of receiving business advantage is strictly prohibited.

Accepting Payments from Third Parties

Accepting payment from a third party offered with expectation of obtaining business advantage is also prohibited.

Accepting Gifts or Hospitality

Accepting gifts or hospitality if it’s suspected to be offered or provided with expectation of business advantage in return is not allowed.

Retaliating Against Individuals Who Refuse to Commit Bribery Offenses

Retaliating against or threatening individuals who refuse to commit bribery offenses or raise concerns under this policy is strictly prohibited.

Gifts, Favors, and Invitations

BIL Group has a separate policy governing the provision and receipt of gifts, favors, and business hospitality. Employees must declare all gifts, favors, and invitations above thresholds defined in the internal policy.

Money Laundering

The bank is committed to combating financial crime through:

  • Preventing financial crime through procedures and controls
  • Protecting the BIL Group from criminal abuse by identifying vulnerabilities and remedying them
  • Applying two levels of controls and prevention measures for establishing or pursuing business relationships related to certain countries, sectors, and customer profiles

Charitable Donations and Sponsorships

BIL Group does not allow charitable donations, sponsorships, or direct or indirect contributions to political parties or organizations as it may be used as a subterfuge for bribery.

Conflicts of Interests

To avoid any risk of influence or conflict of interest, all employees must maintain complete independence in their relationships with clients, business partners (suppliers, subcontractors, etc.), and other BIL Group entities.

Implementation

BIL Group is committed to:

  • Embedding the Bribery and Corruption policy throughout the group through internal communication
  • Raising awareness among new joiners together with other compliance topics
  • Providing all employees with comprehensive compliance training on financial crime risks, including bribery and corruption
  • Implementing disciplinary and criminal sanctions in case of failure to comply with this Policy

Governance

Every employee is responsible for respecting the policy in regards to any potential act(s) of bribery and corruption. Senior management is responsible for putting a framework in place and implementing systems, controls, and procedures to prevent, identify, escalate, and manage act(s) of bribery and corruption.

Reporting

The bank maintains internal whistleblower arrangements which enable staff to draw attention to serious and legitimate concerns about internal governance and potential acts of bribery and corruption.