1. Purpose and scope
Broco Technologies, Inc. prohibits bribery and corruption in its activities. This Policy applies to directors, staff, contractors and persons acting for Broco, including agents and transporters within their mandate. Customers and other commercial counterparties must not use Broco services to carry out bribery or conceal unlawful payments.
Applicable anti-corruption law remains binding. This Policy establishes conduct rules; it does not state that a certification or complete compliance programme has already been implemented.
2. Prohibited conduct
Do not offer, promise, authorise, give, request or accept a benefit intended to improperly influence a decision, obtain an improper advantage or reward improper conduct. This prohibition covers direct and indirect benefits, public officials and private-sector dealings.
Benefits can include money, gifts, employment, hospitality, discounts, confidential information or advantages provided through another person. An intermediary, family member, merchant account or false invoice must not be used to evade this Policy.
Facilitation payments are prohibited. Do not pay unofficial fees to speed up a routine action, approval, customs process, verification or access to funds.
3. Gifts, hospitality and conflicts
Cash, cash equivalents and personal rewards connected with a business decision are prohibited. Any gift or hospitality involving a public official requires prior written review and may proceed only if lawful, transparent, modest and unrelated to improper influence.
Other business gifts or hospitality require prior written approval under Broco's internal process. No monetary threshold authorises conduct that is otherwise improper. Decline a benefit where approval or its lawfulness cannot be established.
Disclose a personal, financial or family interest that may affect a Broco decision. The person with that interest must not approve their own arrangement. Genuine donations or sponsorships require documented review and must not disguise an inducement.
4. Third parties and records
Appointments of agents and other persons acting for Broco must have a documented purpose, appropriate checks, clear authority and proportionate compensation. Unexplained commissions, payments to unrelated recipients, secret arrangements or requests for false records must be escalated.
Keep accurate records of transactions, approvals and expenses. Do not create false invoices, conceal beneficiaries, maintain off-book funds or split a payment to evade a control. A commercial urgency does not justify misleading records.
5. Threats and safety
Do not put yourself in immediate physical danger to refuse a demand. If a payment is made under a credible immediate threat to health or safety, report the facts as soon as safe and record the payment accurately. This safety rule does not treat ordinary commercial pressure as an exception to the prohibition on bribery.
6. Reporting and review
Report a concern to support@broco.app, with “Confidential ethics concern” in the subject, or through an available internal manager/director route. If the concern involves the proposed reviewer, request review by a person independent of that concern. You may also report directly to a competent authority where law permits or requires it.
Provide the relevant facts and records you can lawfully share. Do not obtain evidence by unlawful access, or include passwords or unnecessary personal information. Anonymous concerns can be assessed where received, but anonymity cannot be guaranteed merely by this Policy.
The proposed process acknowledges an identifiable report within seven calendar days and aims to provide an initial assessment within thirty calendar days. Complex matters may require more time; lawful confidentiality and the rights of affected persons must be respected. A report is an allegation to assess, not proof of wrongdoing.
7. Confidentiality and non-retaliation
Information about a concern must be restricted to persons who need it for handling, lawful reporting or protection of rights. Absolute secrecy cannot be promised where disclosure is legally necessary.
Broco prohibits retaliation for a concern reported honestly or for lawful participation in a review, even where the concern is not substantiated. Deliberately false reports or fabricated evidence are distinct from an honest mistake.
8. Response and accountability
Substantiated breaches may result in proportionate action, including restrictions within lawful authority, termination of a mandate or relationship, corrective measures and reporting to authorities where appropriate. Mandatory employment, contractual and procedural protections remain applicable.
This Policy does not authorise automatic seizure of customer funds, punishment without assessment, or withholding a statutory remedy.
The director appointed to coordinate the Policy must maintain the approval and concern registers, arrange appropriate training and review implementation at least annually. Board/director oversight is required for concerns involving the coordinator.