Effective Date: 25.11.2024

1. Introduction
Bourgeon Ventures Ltd ("Bourgeon Ventures", "we", "our", or "us") is committed to conducting business with integrity, transparency, and accountability. This Anti-Bribery and Corruption (ABC) Policy outlines our zero-tolerance approach to bribery and corruption and is aligned with the UK Bribery Act 2010 and other applicable laws.

This Policy applies to all employees, directors, officers, consultants, contractors, intermediaries, and third parties acting on behalf of Bourgeon Ventures.

2. Our Commitment
We do not tolerate bribery or corruption in any form. We are committed to:

• Acting professionally and fairly in all business dealings;

• Complying with all applicable anti-bribery laws in jurisdictions where we operate;

• Promoting a culture of ethics and compliance.

3. What Is Bribery?
Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal, unethical, or a breach of trust. Bribes can take many forms, including:

• Cash payments;

• Gifts, hospitality, or entertainment beyond reasonable business courtesies;

• Political or charitable donations made to obtain undue advantage;

• Favourable treatment or job offers in return for influence.

4. Prohibited Conduct
You must not:

• Offer, promise, give, request, or accept a bribe;

• Facilitate payments (unofficial payments made to secure or expedite routine government actions);

• Authorise third parties to act on our behalf without appropriate due diligence and contractual protections;

• Ignore or fail to report any signs of potential bribery or corruption.

5. Gifts and Hospitality
Gifts and hospitality must:

• Be reasonable and proportionate;

• Not be intended to influence a business decision;

• Be properly recorded in our internal registers.
  Lavish or frequent gifts and entertainment are prohibited.

6. Third Parties and Intermediaries
Bourgeon Ventures expects all third parties, including agents, consultants, and joint venture partners, to comply with this Policy. We conduct due diligence before entering relationships and include appropriate ABC clauses in our contracts.

7. Political and Charitable Contributions
Political contributions must not be made on behalf of Bourgeon Ventures. Charitable donations require prior approval and must not be used as a substitute for bribery.

8. Record Keeping
All transactions, expenses, and payments must be accurately recorded in our books and financial systems. False, misleading, or incomplete records are strictly prohibited.

9. Reporting Concerns
Employees and stakeholders are encouraged to report any concerns about bribery or corruption. Reports can be made confidentially and without fear of retaliation. Email: info@bourgeonventures.com

10. Training and Awareness
We provide regular ABC training to relevant employees and contractors. All personnel are expected to familiarise themselves with this Policy and uphold its principles.

11. Breaches and Consequences
Breaches of this Policy are taken seriously and may result in disciplinary action, including termination of employment or contracts, and potential legal prosecution.

12. Review and Updates
This Policy will be reviewed periodically and updated as needed to reflect legal and operational changes. All staff will be notified of any updates.

Contact
For further information or questions about this Policy, please contact:

Compliance Team
Bourgeon Ventures Ltd
Email: info@bourgeonventures.com

By engaging with Bourgeon Ventures, you acknowledge and agree to adhere to this Anti-Bribery and Corruption Policy.