Beagle Talent’s Anti-Bribery Policy

1. Introduction

At Beagle Talent, we are committed to conducting our business with the highest standards of integrity and ethics. We have a zero-tolerance policy towards bribery and corrupt practices. This Anti-Bribery Policy outlines our commitment to preventing bribery and sets forth the guidelines and procedures that all employees, agents, and representatives of Beagle Talent must adhere to.

2. Policy Statement

Beagle Talent prohibits any form of bribery, including offering, giving, receiving, or soliciting bribes, whether directly or indirectly, to gain an improper advantage. We are committed to:

a. Complying with all applicable anti-bribery laws and regulations, including the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and any other relevant legislation in the jurisdictions in which we operate. b. Conducting our business in an honest, transparent, and ethical manner. c. Preventing bribery in all our operations, including our interactions with clients, candidates, suppliers, government officials, and any other stakeholders. d. Promoting a culture of integrity and ethical conduct throughout Beagle Talent.

3. Definitions

a. Bribery: Offering, promising, giving, receiving, or soliciting anything of value, whether directly or indirectly, with the intent to influence the actions or decisions of an individual in a position of trust, in order to gain an improper advantage. b. Bribe: Anything of value, such as money, gifts, hospitality, loans, kickbacks, or favors, given or received with the intent to influence an individual’s actions or decisions improperly.

4. Prohibited Conduct

The following actions are strictly prohibited under this policy:

a. Offering, promising, giving, or accepting bribes, kickbacks, or any other form of improper payments or inducements. b. Influencing or attempting to influence the actions or decisions of individuals, including clients, candidates, suppliers, or government officials, through bribery or corrupt practices. c. Misusing company funds, assets, or resources for improper payments or personal gain. d. Facilitating or participating in money laundering or other illicit financial activities. e. Engaging in any conduct that may create an appearance of impropriety or compromise the reputation of Beagle Talent.

5. Gifts, Hospitality, and Expenses

a. Employees must not offer or accept gifts, hospitality, or expenses that could be perceived as influencing or compromising their professional judgment or creating a conflict of interest. b. Gifts, hospitality, or expenses must be modest, infrequent, and consistent with customary business practices. They must also comply with applicable laws and regulations. c. Approval from the appropriate authority within Beagle Talent must be obtained for any gifts, hospitality, or expenses that exceed predetermined thresholds or may raise concerns.

6. Due Diligence and Third-Party Relationships

a. We will conduct thorough due diligence on all third parties, such as clients, suppliers, agents, and business partners, to ensure they meet our standards of integrity and are not involved in corrupt activities. b. Contracts and agreements with third parties will include anti-bribery and corruption provisions, requiring compliance with this policy. c. We will regularly review and monitor the conduct of third parties to identify and mitigate any potential risks of bribery or corruption.

7. Reporting and Whistleblowing

a. All employees have a responsibility to report any suspected or actual instances of bribery or corrupt practices promptly. b. Beagle Talent will provide a confidential reporting mechanism for employees, job applicants, clients, and other stakeholders to report concerns or suspicions related to bribery. c. Whistleblowers will be protected from retaliation, and all reports will be handled in accordance with applicable laws and the company’s whistleblower protection policy.

8. Training and Communication

We will provide regular training and communication initiatives to ensure that all employees, agents, and representatives of Beagle Talent are aware of and understand this Anti-Bribery Policy. This includes:

a. Conducting training programs to educate employees on the risks of bribery, applicable laws and regulations, and the company’s expectations regarding ethical conduct. b. Promoting open and transparent communication channels to discuss concerns, seek guidance, and report any suspected or actual instances of bribery or corrupt practices. c. Periodically reviewing and updating employees on changes to anti-bribery laws, regulations, and best practices.

9. Compliance and Monitoring

a. Beagle Talent will implement internal controls, risk assessments, and monitoring processes to detect and prevent instances of bribery and corrupt practices. b. Regular audits and reviews will be conducted to assess compliance with this policy and identify areas for improvement. c. Non-compliance with this Anti-Bribery Policy may result in disciplinary action, up to and including termination of employment or contractual relationships, and may be reported to relevant authorities.

10. Review and Publication

This Anti-Bribery Policy will be reviewed periodically to ensure its continued relevance and effectiveness. Updates and improvements will be made as necessary to address emerging risks and changing legal requirements.

We will make this policy available to all employees, agents, and representatives of Beagle Talent, as well as relevant stakeholders, on our website and other appropriate communication channels.

11. Conclusion

At Beagle Talent, we are committed to upholding the highest standards of integrity, ethics, and compliance with anti-bribery laws and regulations. This Anti-Bribery Policy reflects our dedication to preventing bribery and corrupt practices in all our operations. By adhering to this policy, we protect our reputation, build trust with our stakeholders, and contribute to a fair and ethical business environment.