OUR CODE OF EHTICS
CODE OF ETHICS: PRINCIPLE OF RECTITUDE & ANTI-CORRUPTION PRACTICES
This document describes Boardsfera’ s Code of Ethics (also referred to hereafter as the "Code") and how Boardsfera addresses compliance with anti-corruption requirements in its business activity. This Code is governed by the generally accepted principle of rectitude.
Within the framework of its business activity, Boardsfera’ s directors, managers and employees agree to comply with applicable laws, statutes, regulations and anti-corruption codes (also referred to below as the "Anticorruption Regulations") in the jurisdictions where it carries out its business.
Similarly, Boardsfera encourages the application of the principle of rectitude and compliance with the Anticorruption Regulations to those third parties acting in conjunction with or on behalf of Boardsfera (also hereinafter referred to as "Business and Commercial Partners"), particularly those who may interact with civil servants / public employees.
This Code establishes behavior guidelines, seeking to ensure the absence of any potential exercise and/or acceptance of corrupt practices, both from Boardsfera, from individuals and third parties related to Boardsfera’ s activity.
Boardsfera will cooperate in good faith in any investigation in case of any alleged violation of this Code.
Any proven irregular behaviours or founded suspicion involving Boardsfera partners, administrators or employees can be denounced through the "CONTACT US" section of this web page. Any communication in this regards will be treated confidentially and anonymously.
1. SCOPE OF APPLICATION AND INTERPRETATION
This Code is observed by all directors, managers and employees of Boardsfera. Boardsfera also promotes the compliance with the principles of action reflected in this Code amongst its Business and Commercial Partners.
2. DEFINITIONS
Element of Value: any object, service or situation of tangible or intangible value.
Official / Public Employee: refers to: (i) any public or elected official, agent, employee or person acting on behalf of a national, province or local government, department, agency, agency, state owned or controlled company, organization international public, political party or entity that is financed mostly by public funds, which is generally perceived as an entity that performs governmental functions, or that has key executives or directors appointed by a government; and (ii) any political party, political candidate for a position or any person acting on behalf of the party or candidate for political office.
3. GIFTS AND INVITATIONS
3.1 General prohibitions
3.1.1. It is forbidden to offer, promise, pay, give or authorize the delivery of any Element of Value directly or indirectly (through a third party) to: (i) any Public official / employee, or (ii) any individual or legal entity (public or private) with the purpose of improperly influencing a
decision of a Public Official / Employee to obtain or maintain a business or any other advantage.
3.1.2. It is forbidden to offer, promise, pay, give, authorize the delivery to third parties or accept from third parties Elements of Value of such relevance that may unlawfully condition the conduct of the recipient of the Element of Value.
3.1.3. It is forbidden to offer, promise, pay, give or authorize the delivery of any Element of Value to third parties, knowing that third parties, in turn, will offer, promise or provide any advantage prohibited in this section 3.1.
3.2 Acceptable practices
Gifts and business invitations must never be offered or accepted for illicit purposes and must be, in all cases:
Boardsfera directors, executives and employees may accept, within the reasonable business social uses, invitations to promotional or business events, in which the organizing entity other than Boardsfera assumes the costs. These will not be considered irregular when based on reasonable grounds of travel, accommodation and subsistence expenses.
It is equally acceptable that Boardsfera assumes, within reasonable business social uses, expenses directly related to promotional events or demonstrations of Boardsfera business services. Boardsfera may invite third parties assuming their reasonable travel, lodging and subsistence expenses; all of these provided they do not have as a purpose to achieve any advantage prohibited in section 3.1 above.
Similarly, Boardsfera’ s clients or Commercial Partners may assume reasonable expenses, directly related to training events or training forums in which Boardsfera is involved, including those of travel, lodging and subsistence provided they are not intended to achieve any Advantage prohibited in section 3.1 above.
4. ACCOUNTING RECORDS
The accounting books will not contain false or misleading records or statements, such as recording expenses for invitations as something other than their nature. Transactions must not be intentionally recorded in an equivocal manner in relation to the accounts.
5. COMMERCIAL PARTNERS
Boardsfera will not hire or conduct business with a Commercial Partner if it is believed there is a risk of violation of this Code. Before establishing a business relationship with any Commercial Partner which may interact on behalf of Boardsfera, particularly in interactions with Officials / Public Employees, Boardsfera will ensure that the Commercial Partner certifies its compliance with this Code of Ethics, reserving Boardsfera’ s right to terminate the contract in case of breach of the Code.
This document describes Boardsfera’ s Code of Ethics (also referred to hereafter as the "Code") and how Boardsfera addresses compliance with anti-corruption requirements in its business activity. This Code is governed by the generally accepted principle of rectitude.
Within the framework of its business activity, Boardsfera’ s directors, managers and employees agree to comply with applicable laws, statutes, regulations and anti-corruption codes (also referred to below as the "Anticorruption Regulations") in the jurisdictions where it carries out its business.
Similarly, Boardsfera encourages the application of the principle of rectitude and compliance with the Anticorruption Regulations to those third parties acting in conjunction with or on behalf of Boardsfera (also hereinafter referred to as "Business and Commercial Partners"), particularly those who may interact with civil servants / public employees.
This Code establishes behavior guidelines, seeking to ensure the absence of any potential exercise and/or acceptance of corrupt practices, both from Boardsfera, from individuals and third parties related to Boardsfera’ s activity.
Boardsfera will cooperate in good faith in any investigation in case of any alleged violation of this Code.
Any proven irregular behaviours or founded suspicion involving Boardsfera partners, administrators or employees can be denounced through the "CONTACT US" section of this web page. Any communication in this regards will be treated confidentially and anonymously.
1. SCOPE OF APPLICATION AND INTERPRETATION
This Code is observed by all directors, managers and employees of Boardsfera. Boardsfera also promotes the compliance with the principles of action reflected in this Code amongst its Business and Commercial Partners.
2. DEFINITIONS
Element of Value: any object, service or situation of tangible or intangible value.
Official / Public Employee: refers to: (i) any public or elected official, agent, employee or person acting on behalf of a national, province or local government, department, agency, agency, state owned or controlled company, organization international public, political party or entity that is financed mostly by public funds, which is generally perceived as an entity that performs governmental functions, or that has key executives or directors appointed by a government; and (ii) any political party, political candidate for a position or any person acting on behalf of the party or candidate for political office.
3. GIFTS AND INVITATIONS
3.1 General prohibitions
3.1.1. It is forbidden to offer, promise, pay, give or authorize the delivery of any Element of Value directly or indirectly (through a third party) to: (i) any Public official / employee, or (ii) any individual or legal entity (public or private) with the purpose of improperly influencing a
decision of a Public Official / Employee to obtain or maintain a business or any other advantage.
3.1.2. It is forbidden to offer, promise, pay, give, authorize the delivery to third parties or accept from third parties Elements of Value of such relevance that may unlawfully condition the conduct of the recipient of the Element of Value.
3.1.3. It is forbidden to offer, promise, pay, give or authorize the delivery of any Element of Value to third parties, knowing that third parties, in turn, will offer, promise or provide any advantage prohibited in this section 3.1.
3.2 Acceptable practices
Gifts and business invitations must never be offered or accepted for illicit purposes and must be, in all cases:
- Compliant with the laws and regulations, both in the country where the invitation is made, and the country where the invitation it is received.
- Delivered or accepted without awaiting reciprocity: the intention or purpose pursued by the gift or invitation must be simply to build a business relationship within normal standards of courtesy and not to influence a person in charge of adopting a business decision.
- Socially acceptable: other people (such as colleagues, competitors or the press) would agree that the gift or invitation is reasonable and that it could be communicated without possible fear of social reproach.
- Consistent with the business interests of Boardsfera, as well as with the usual business practices.
- Occasional and not excessive, according to local or industry standards.
- Boardsfera clients or business partners may have their own internal rules on this matters which may/may not coincide with the standards established in this policy. Consequently, clients or business partners internal rules should be considered when offering gifts or invitations to directors, managers and employees of these companies to avoid compromising their own reputation.
Boardsfera directors, executives and employees may accept, within the reasonable business social uses, invitations to promotional or business events, in which the organizing entity other than Boardsfera assumes the costs. These will not be considered irregular when based on reasonable grounds of travel, accommodation and subsistence expenses.
It is equally acceptable that Boardsfera assumes, within reasonable business social uses, expenses directly related to promotional events or demonstrations of Boardsfera business services. Boardsfera may invite third parties assuming their reasonable travel, lodging and subsistence expenses; all of these provided they do not have as a purpose to achieve any advantage prohibited in section 3.1 above.
Similarly, Boardsfera’ s clients or Commercial Partners may assume reasonable expenses, directly related to training events or training forums in which Boardsfera is involved, including those of travel, lodging and subsistence provided they are not intended to achieve any Advantage prohibited in section 3.1 above.
4. ACCOUNTING RECORDS
The accounting books will not contain false or misleading records or statements, such as recording expenses for invitations as something other than their nature. Transactions must not be intentionally recorded in an equivocal manner in relation to the accounts.
5. COMMERCIAL PARTNERS
Boardsfera will not hire or conduct business with a Commercial Partner if it is believed there is a risk of violation of this Code. Before establishing a business relationship with any Commercial Partner which may interact on behalf of Boardsfera, particularly in interactions with Officials / Public Employees, Boardsfera will ensure that the Commercial Partner certifies its compliance with this Code of Ethics, reserving Boardsfera’ s right to terminate the contract in case of breach of the Code.