This Compliance Framework describes the fundamental standards of BE Global Commerce Ltd. for acting with integrity, in compliance with the law, and responsibly. It serves to create transparency toward business partners, customers, suppliers, and authorities, and does not constitute a contract or legal advice.
1. Compliance Commitment
BE Global Commerce Ltd. regards compliance as an integral part of responsible corporate governance. Integrity, transparency, fairness, and compliance with all applicable laws form the basis of all business decisions.
2. Scope
This Framework applies to directors, officers, employees, and consultants, as well as — where contractually agreed — representatives and business partners of the company.
3. International Standards
Our compliance principles are guided, where relevant to our business activities, by internationally recognized standards and best practices, including the FATF Recommendations, the OECD principles on combating corruption, and applicable sanctions and export control regulations.
4. Risk-Based Approach
Compliance measures are implemented on a risk-based approach. The nature and scope of reviews depend on the respective business model, transaction, business partner, and market involved.
5. Anti-Money Laundering (AML)
The company takes appropriate measures to prevent money laundering and the financing of terrorism. Suspicious matters are documented and, where legally required, reported to the competent authorities.
6. Know Your Customer (KYC)
Prior to entering into significant business relationships, identity, beneficial owners, corporate structure, company registers, sanctions lists, and other risk-relevant information may be appropriately reviewed.
7. Anti-Bribery & Anti-Corruption
Corruption, bribery, and improper granting of advantages are not tolerated. Cash gifts or other improper advantages are prohibited. Business invitations and courtesies must be appropriate, transparent, and lawful.
8. Export Control and Sanctions
International trade transactions are reviewed with regard to applicable export control and sanctions regulations. Any required authorizations must be obtained prior to conducting a transaction.
9. Business Partner Due Diligence
Suppliers, customers, and other business partners are assessed on a risk-based approach. This may take into account ownership structure, economic reputation, regulatory risks, and publicly available information.
10. Conflicts of Interest
Actual or potential conflicts of interest must be disclosed without delay. Personal interests must not influence business decisions.
11. Documentation
Compliance-relevant decisions and reviews are documented in a traceable manner and archived in accordance with statutory retention obligations.
12. Whistleblowing
Reports of possible violations of laws, policies, or compliance requirements may be submitted confidentially. Whistleblowers must not be subjected to any disadvantage for reports made in good faith.
13. Responsibilities
Management bears overall responsibility for the implementation of this Framework. All employees are required to comply with the principles described herein.
14. Violations
Violations of this Framework may, depending on their nature and severity, result in employment-law, civil, or criminal consequences, as well as the termination of a business relationship.
15. Training and Review
Compliance-relevant functions receive regular awareness training. This Framework is reviewed at regular intervals and updated as necessary.
16. Compliance Contact
Questions or reports regarding the Compliance Framework may be directed to the compliance contact point designated by the company.
Compliance Guidelines
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