Anti Bribery and Corruption Policy

Introduction

Blanco Goldfarb Associates has a number of fundamental principles and values which it believes are the foundation of sound and fair business practice and as such are important to uphold. One such principle is a zero tolerance position in relation to corruption, wherever and in whatever form that it may be encountered. This document clearly states the standards and principles required to ensure conformance to legal requirements in the areas that Blanco Goldfarb Associates operate.

Legal Obligation

It is Blanco Goldfarb Associates policy to comply with all laws, rules and regulations governing anti bribery and corruption law. We believe it is fundamental operating principle that as a United Kingdom (UK) company Blanco Goldfarb Associates are bound by the laws of the UK.

Under UK law, bribery and corruption is punishable for individuals by up to seven years imprisonment, and if the company is found to have taken part in corruption it could face an unlimited fine, be excluded from tendering for Government contracts and face untold damage to its reputation. Under UK law the payment, or offer to pay bribes, or provision of or offer to provide gifts or anything of value for improper purposes to obtain or retain business or any other benefit, (whether for Blanco Goldfarb Associates or any other party) is prohibited. Such payments or gifts are also forbidden under the terms of this policy and may result in immediate dismissal for those involved in their payment or receipt. Blanco Goldfarb Associates is required to keep financial records and to have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

Policy

This policy applies to individual employees, agents, sponsors, intermediaries, consultants or any other people or bodies associated with Blanco Goldfarb Associates or any of its employees. Bribery is committed when an inducement or reward is provided in order to gain any commercial, contractual, regulatory or personal advantage for Blanco Goldfarb Associates or another party. No bribes of any sort may be paid to or accepted from customers, suppliers, politicians, government advisors or representatives, private person or company. It is not permitted to establish accounts or internal budgets for the purpose of facilitating bribes or influencing transactions (slush funds).

This policy does not prohibit the following practice providing it is customary in a particular market, or is proportionate and properly recorded:

• Normal and appropriate hospitality (Given and Received)

 

Expectations of Blanco Goldfarb Associates and Staff

The prevention, detection and reporting of bribery and corruption is the responsibility of all employees at Blanco Goldfarb Associates.

The Directors of the Company are committed to and take lead responsibility for policy implementation within Blanco Goldfarb Associates.