1. Zero tolerance for corruption
BREAIX prohibits bribery, kickbacks, facilitation payments, extortion, fraud and any other attempt to obtain an improper business or official advantage. The prohibition applies whether the conduct is direct or routed through a third party, and whether the proposed benefit is money, a gift, travel, employment, a donation, a discount or another thing of value.
A commercial opportunity, onboarding decision, approval, inspection, permit, customs action, payment or access right must not be conditioned on an improper benefit. Local custom, urgency, a small amount or a request from a senior person does not make a prohibited payment acceptable.
2. Third parties and conflicts
Intermediaries, agents, consultants, representatives and partners can create risk even when they do not work for BREAIX. Their role, ownership, authority, compensation, services and relevant reputation should be understood before engagement and monitored when circumstances change.
People working with BREAIX must disclose a personal, family or financial interest that could influence a decision or create the appearance of divided loyalty. The appropriate response may be recusal, additional review, a written mitigation or ending the relationship.
- Gifts and hospitality must be reasonable, transparent, infrequent and never tied to a pending decision.
- Charitable or community support must not be used to reward or influence a decision maker.
- Payments must match a documented, legitimate service and be made through approved channels.
3. Records and controls
Books, records, invoices, approvals and operational data must describe transactions accurately and with enough detail to explain the business purpose. False descriptions, undisclosed side agreements, off-book funds and payments to unknown accounts are prohibited.
Risk-based due diligence, approval thresholds, segregation of duties, training and monitoring should be used for relationships and transactions that could expose BREAIX or its customers to corruption risk.
4. Speaking up and consequences
Anyone who suspects bribery, retaliation, falsified records or a conflict that has not been disclosed should report it through the BREAIX contact channel. Reports should be handled confidentially to the extent possible and without retaliation for a good-faith concern.
BREAIX may suspend a relationship, preserve records, investigate, require remediation, notify a customer or authority, and seek contractual or legal remedies. A failure to report a serious concern can itself create compliance risk.