Policy on Preventing and Detecting Bribery, Corruption, Fraud, Money Laundering, and Terrorism Financing

Objective

Establish measures to prevent and detect bribery, corruption, fraud, money laundering, and terrorism financing within Bulkargo Companies.

Scope

Applies to all employees, executives, suppliers, customers, shareholders, and any person related to Bulkargo Companies.

Responsibility

All Bulkargo Companies employees must comply with this policy, acting with integrity and ethics in all activities. The Ethics Committee oversees the implementation and compliance of this policy.

Prohibitions

Accepting or offering bribes, inappropriate gifts, or favors to any person related to the company or any other entity.
Engaging in any act of corruption, including paying bribes or illegal commissions.
Engaging in fraudulent activities, such as falsification of documents or manipulation of information systems.
Participating in money laundering or terrorism financing activities.

Reporting

Employees must report any suspicion or knowledge of policy violations immediately to the Ethics Committee. Confidentiality is guaranteed, and whistleblowers will be protected from retaliation.

Training

Employees will receive periodic training on laws and regulations related to bribery, corruption, fraud, money laundering, and terrorism financing, as well as on this policy and the company’s procedures for preventing and detecting violations.

Monitoring and Compliance

The Ethics Committee will regularly monitor and evaluate compliance with this policy and address any identified violations.

Compliance Processes

Establish procedures to identify and assess risks related to bribery, corruption, fraud, money laundering, and terrorism financing in company operations.
Maintain records of all financial transactions and implement controls to detect suspicious activity.
Implement internal monitoring and audit mechanisms to ensure policy compliance.

Cooperation with Authorities

Bulkargo Companies will fully cooperate with regulatory and government authorities in any investigation related to bribery, corruption, fraud, money laundering, and terrorism financing.

Consequences of Violation

Violations of this policy may result in disciplinary measures, including termination of employment, and legal actions where applicable.

Policy Modifications

This policy is a statement of principles and may not cover every situation. Bulkargo Companies reserves the right to modify this policy at any time at its discretion.