Introduction
At Bourgeon Ventures, our integrity and reputation are built upon a foundation of ethical behaviour, transparency, and accountability. This Code of Conduct outlines the standards expected of all employees, contractors, and partners, ensuring our operations align with the highest legal and ethical standards under UK law.

1. Our Commitment
We are committed to operating lawfully, ethically, and with integrity across all areas of our business, including commodity trading, investment facilitation, and real estate advisory. This Code ensures we uphold the values of trust, responsibility and professional conduct.

2. Compliance with Laws and Regulations
All employees and representatives must comply with all applicable UK and international laws, regulations, and industry standards relevant to our operations. This includes anti-money laundering (AML), anti-bribery and corruption (ABC), data protection (GDPR), sanctions compliance and financial conduct rules.

3. Anti-Bribery and Anti-Corruption
Bourgeon Ventures maintains a zero-tolerance approach to bribery and corruption. Bribes or any form of improper payment to gain business or personal advantage are strictly prohibited. This applies to all business dealings and transactions in all countries in which we operate.

4. Conflicts of Interest
Employees and contractors must avoid situations where personal interests conflict, or appear to conflict, with the interests of Bourgeon Ventures. Any actual or potential conflicts must be declared promptly to the compliance officer or management.

5. Confidentiality and Data Protection
We handle sensitive information with care and respect. All data must be protected in accordance with UK GDPR laws. Confidential business information must not be disclosed to unauthorised individuals or used for personal gain.

6. Respect and Non-Discrimination
We are committed to creating a diverse, inclusive, and respectful workplace. Discrimination, harassment, or bullying of any kind will not be tolerated. We value diversity and treat all colleagues, clients, and partners with fairness and respect.

7. Insider Trading and Market Conduct
Employees must not misuse confidential or non-public information for trading purposes or to benefit personally or professionally. Bourgeon Ventures complies fully with the UK Market Abuse Regulation (UK MAR).

8. Anti-Money Laundering and Sanctions
We are committed to combating money laundering, terrorist financing, and financial crime. Robust due diligence, know-your-customer (KYC) processes, and sanctions checks are core to our onboarding and transaction protocols.

9. Environmental and Social Responsibility
We aim to conduct our business in a way that respects the environment and supports sustainable development. Ethical sourcing, responsible investment, and reducing environmental impact are central to our mission.

10. Reporting Misconduct
We encourage employees and stakeholders to report suspected breaches of this Code or other unethical conduct. Reports can be made confidentially and without fear of retaliation. A clear procedure is in place for investigation and resolution.

11. Responsibilities and Enforcement
All employees, contractors, and third parties are expected to understand and comply with this Code. Breaches may result in disciplinary action, including termination of employment or business relationships, and possible legal consequences.

12. Review and Updates
This Code will be reviewed periodically to reflect changes in law, regulation, or business practice. Employees will be informed of any significant updates and are expected to reaffirm their understanding and commitment.

 

Contact & Queries
If you have questions about the Code or wish to report a concern, please contact our Compliance Team at info@bourgeonventures.com.

Bourgeon Ventures Ltd
Registered in England & Wales
www.bourgeonventures.com