ANTI-BRIBERY, CORRUPTION & MONEY LAUNDERING POLICY

Associates

Associates stands as a collective term for all individuals working at all the levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, volunteers, service providers, seconded staff, casual workers and agency staff, agents, or any other person associated with rm-ecommerce, wherever located.

Business Partners

Business Partner stands as a collective term used for Consultants, Logistic partners, Vendors, Contractors, Youtubers, Agents, Intermediaries, any other Service Providers and associates of such third parties with whom boodmo enters into contract(s).

Bribery

Bribery means the offering, promising, giving, receiving, soliciting or accepting of a financial or other advantage, or any other thing of value, with the intention of influencing or rewarding the behaviour of a person in a position of trust to perform a public, commercial or legal function to obtain or retain a commercial advantage. Bribery includes any attempt to do any of the foregoing as well. Bribes are payments made in the form of money or anything else of value in return for a business favour or advantage.

Cross Border Transactions

Cross-border transactions are any interactions or transactions involving a Government Official where:

- An Associate is in a country other than the home country of the Government Official, or

- The interaction or transaction is reasonably expected to occur in a country other than the home country of the Government Official. 

Improper Payments

Improper payments means receiving or paying bribes or giving, offering, or promising to give money or anything else of value to any person, including any Government Official, in order to improperly influence any act or decision of a person, or to otherwise gain an improper benefit for the Company.

Extortion

Extortion means to directly or indirectly demand or accept a bribe, facilitation payment or kickback.

Facilitation Payments

Facilitation payments are unofficial payments made to secure or expedite a routine government action by a government official. 

Gift

A gift is anything of value and would encompass any gratuitous monetary or non-monetary benefit. It includes tangible items such as cash, precious metals, stones, jewellery, art, and any of their equivalents, but also intangible items such as discounts, services, loans, favours, special privileges, advantages, benefits and rights that are not available to the general public. A “gift” also includes meals, entertainment, hospitality, vacations, trips, use of vacation homes, tickets to sporting or music events, outings, vendor familiarization trips, and use of recreational facilities. 

Kickbacks

Kickbacks are typically payments made in return for a business favour or advantage.

Money Laundering

Money laundering is the process of concealing the source of funds and ownership of illegally gained proceeds that is then reintroduced into the economy for legitimate purposes.