Beings Bribery and Corruption Policy

Beings is committed to conducting all business activities with integrity and in compliance with all applicable laws and regulations. We have a zero-tolerance policy towards bribery and corruption in any form. This policy applies to all Beings employees, contractors, consultants, agents, and any other individuals or entities acting on behalf of Beings.

Definitions

• Bribery: The act of offering, giving, receiving, or soliciting something of value with the intention of influencing the actions or decisions of another person in a way that is illegal or unethical.
• Corruption: The abuse of entrusted power for private gain.
• Facilitation payments: Small payments made to expedite or secure the performance of a routine or necessary action to which the payer is legally entitled. While facilitation payments are not considered bribery under this policy, they should be avoided whenever possible.

Prohibited Activities

The following activities are strictly prohibited:

• Offering, promising, giving, demanding, or accepting bribes or kickbacks.
• Engaging in any activity that could be construed as bribery or corruption.
• Providing or accepting gifts, hospitality, or entertainment that could be seen as influencing a business decision.
• Making facilitation payments, except in limited circumstances where they are unavoidable and properly documented.
• Failing to report any suspected or actual instances of bribery or corruption.

Gifts and Hospitality

Gifts and hospitality should only be offered or accepted if they are of nominal value, appropriate in the circumstances, and comply with applicable laws and regulations. Any gifts or hospitality offered or accepted should be properly documented.

Reporting and Investigation

All employees have a responsibility to report any suspected or actual instances of bribery or corruption to their supervisor, the Beings Compliance Officer, or through the Beings confidential reporting hotline. All reports will be investigated promptly and thoroughly.

Consequences of Non-Compliance

Employees who violate this policy will be subject to disciplinary action, up to and including termination of employment. Beings may also take legal action against individuals or entities involved in bribery or corruption.

Training and Awareness

Beings will provide training and awareness programs to ensure that all employees are aware of this policy and their responsibilities under it.