Bribery, Corruption & Counterfeit, Ethical Behaviour Policy

In our continued efforts to support human rights, ethical practices and environmental responsibility, BIE Magnum Limited are in compliance with, and are asking the valued members of its Supply Chain to comply with the Conflict Minerals Rule.

The United States 2010 Dodd–Frank Wall Street Reform and Consumer Protection Act (Conflict Minerals Rule), requires manufacturers to audit their supply chains and report conflict minerals usage.  Conflict minerals covered by this rule are Tin, Tantalum, Tungsten and Gold that has originated from the Democratic Republic Congo or any of its nine adjoining nations; Angola, Burundi, Central African Republic, Congo Republic, Rwanda, Sudan, Tanzania, Uganda, or Zambia.

Conflict minerals are minerals which are mined in dangerous areas of conflict and sold to fund the continuation of the conflict.  Securing and controlling lucrative mines have become military objectives and miners (including women, children and other vulnerable individuals) are illegally forced to work abusing human rights and ethical practices, as well as having devastating effects on the environment.

To this end, BIE Magnum Limited is asking that all suppliers work with their respective supply chains to ensure that all material supplied to BIE Magnum Limited complies with the Conflict Minerals Ethical obligations in trade and will help wherever possible to assist in compliance.  Failure to carry out this request may result in BIE Magnum Limited discontinuing trade with suppliers who are unwilling to comply.

Bribery, Corruption & Ethical Behaviour Policy

BIE Magnum Limited will not tolerate bribery or corruption in any form.

The firm prohibits the offering, giving, solicitation or the acceptance of any bribe or corrupt inducement, whether in cash or in any other form:

  • to or from any person or company wherever located, whether a public official or public body, or a private person or company;
  • by any individual employee, director, agent, consultant, contractor or other person or body acting on the firm’s behalf;
  • in order to gain any commercial, contractual, or regulatory advantage for the firm in any way which is unethical or to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.

This policy is not intended to prohibit the following practices provided they are appropriate, proportionate and are properly recorded:

  • Normal hospitality, provided that it complies with the below ‘Key Risk Areas’;
  • Fast tracking a process which is available to all on the payment of a fee; and/or
  • Providing resources to assist a person or body to make a decision more efficiently, provided that it is for this purpose only.

It may not always be a simple matter to determine whether a possible course of action is appropriate.  If you are in any doubt as to whether a possible act might be in breach of this policy or the law, the matter should be referred to your Director.  If necessary, guidance should also be sought from the companies Legal Consultants.

The firm will investigate thoroughly any actual or suspected breach of this policy, or the spirit of this policy.  Employees found to be in breach of this policy may be subject to disciplinary action which may ultimately result in their dismissal.

Key Risk Areas:

Bribery can be a risk in many areas of the firm.  Below are the key areas you should be aware of in particular:

Excessive gifts, entertainment and hospitality:  can be used to exert improper influence on decision makers.  Gifts, entertainment and hospitality are acceptable provided they fall within the firm’s Corporate Entertainment Policy.

Counterfeit Parts:

BIE Magnum Limited implement appropriate controls to prevent the incorporation of counterfeit parts and materials into the product by managing the following;

  • Approved suppliers list
  • Suppliers certification
  • Materials only purchased through approved UK, European or USA sources

Facilitation payments:

Are used by businesses or individuals to secure or expedite the performance of a routine or necessary action to which the payer has an entitlement as of right.  The firm will not tolerate or excuse such payments being made.

Reciprocal agreements:

Or any other form of ‘quid pro quo’ are never acceptable unless they are legitimate business arrangements which are properly documented and approved by management.  Improper payments to obtain new business, retain existing business or secure any improper advantage should never be accepted or made.

Actions by third parties for which the firm may be held responsible: can include a range of people i.e. agents, contractors and consultants, acting on the firm’s behalf.  Appropriate due diligence should be undertaken before a third party is engaged.  Third parties should only be engaged where there is a clear business rationale for doing so, with an appropriate contract.  Any payments to third parties should be properly authorised and recorded.

Record keeping:

Can be exploited to conceal bribes or corrupt practices.  We must ensure that we have robust controls in place so that our records are accurate and transparent.

Employee responsibility and how to raise a concern

The prevention, detection and reporting of bribery or corruption is the responsibility of all employees throughout the firm.  If you become aware or suspect that an activity or conduct which is proposed or has taken place is a bribe or corrupt, then you have a duty to report this.

Any such incidents should be reported in accordance whistle blowing regulations, the company will endeavour to maintain anonymity of any such persons reporting incidents.

This policy was last reviewed in July 2019.