Compliance & Ethics Program

Last updated: 15-01-2024

Our compliance & ethics program mission at Be-Bookable is to conduct business with the utmost integrity and adhere to the highest ethical standards. We are committed to complying with all applicable laws and regulations while fostering a culture of transparency and accountability.

The primary objectives of our compliance and ethics program include preventing violations of ethical and legal standards, ensuring accountability for actions taken, and creating a workplace culture that prioritizes integrity.

1. Code of Conduct and Ethical Standards

  • Core Values and Principles: Our core values include honesty, integrity, respect for diversity, and fairness in all our business interactions. We are committed to acting with transparency and accountability in all dealings.

  • Responsibilities of Employees, Management, and Leadership: All employees, including management and leadership, are responsible for upholding our ethical standards. Management is accountable for setting an example and fostering a culture of ethics and compliance within the organization.

2. Anti-Bribery and Corruption

  • Policy Statement: Be-Bookable has a zero-tolerance policy for bribery and corruption. We prohibit all forms of bribery and corruption, including offering, receiving, or facilitating bribes, whether domestically or internationally.

  • Prohibited Activities: Prohibited activities include offering bribes to public officials, accepting kickbacks, or engaging in any corrupt practices. Employees must avoid any involvement in corrupt acts.

  • Due Diligence for Business Partners: We conduct thorough due diligence on potential business partners, including suppliers and agents, to ensure they align with our anti-bribery and corruption standards before entering into agreements.

3. Fraud Prevention

  • Fraud Prevention Policy: Our fraud prevention policy outlines our commitment to preventing fraudulent activities within Be-Bookable, including financial fraud, misappropriation of assets, and misrepresentation of information.

  • Fraud Detection and Reporting Procedures: Employees must promptly report any suspicions of fraudulent activities through internal reporting channels. If necessary, we will involve external authorities in the investigation.

  • Disciplinary Measures for Fraudulent Activities: Violators of our fraud prevention policy may face disciplinary actions, up to and including termination, and we may pursue legal actions to recover losses.

4. Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF)

  • AML/CTF Policy: Be-Bookable is committed to complying with all AML and CTF laws and regulations. We have implemented stringent policies and procedures to ensure our compliance.

  • Customer Due Diligence Procedures: We conduct thorough customer due diligence to verify the identities of our clients and regularly monitor transactions for signs of suspicious activities.

  • Monitoring Fraudulent Transactions: Be-Bookable actively monitor transactions for signs of fraudulent activity to prevent money laundering and terrorism financing.

5. Accounting Principles and Tax Compliance

  • Accounting Principles Policy: Our accounting principles policy outlines our commitment to transparent and accurate financial reporting, following generally accepted accounting principles (GAAP).

  • Tax Compliance Procedures: We strictly adhere to tax laws and regulations, including proper documentation, reporting, and timely payment of taxes in all jurisdictions where we operate.

  • Reporting and Documentation Requirements: Employees involved in financial reporting and tax compliance must maintain accurate records and provide documentation as needed for audits and regulatory inquiries.

  • Collaboration with Tax Authorities: We collaborate with tax authorities in all jurisdictions to address inquiries, provide necessary information, and ensure compliance with tax regulations.

6. Information Security

  • Information Security Policy: Our information security policy outlines safeguards for protecting sensitive data, including encryption, access controls, and cybersecurity measures.

  • Data Classification and Handling: Employees are trained to classify and handle data appropriately, ensuring that sensitive information is protected from unauthorized access or disclosure.

  • Access Controls and Authentication: Access to our systems and data is controlled through authentication processes, and employees have access only to the information necessary for their roles.

  • Logging Data Access: We maintain detailed logs of data access, recording who accesses data and when they access it, to ensure accountability and track any unauthorized access.

  • Incident Response and Reporting: In the event of a security breach or data incident, our incident response team follows established procedures for reporting, containment, and resolution, including notification to affected parties and regulatory authorities.

7. Diversity Policy

  • Diversity and Inclusion Policy: Our diversity and inclusion policy express our commitment to creating a diverse and inclusive workplace.

  • Equal Opportunity Employment: We strictly adhere to equal opportunity employment principles, ensuring that all employees are treated fairly and without discrimination.

  • Non-Discrimination and Harassment Policies: We have policies in place to prevent and address discrimination and harassment, promoting a respectful and inclusive work environment.

  • Reporting Mechanisms for Diversity Issues: Employees can report diversity-related issues or concerns through our confidential reporting channels, and we will take appropriate action to address them.

8. Reporting and Whistleblower Mechanism

  • Confidentiality and Non-Retaliation: We maintain strict confidentiality when handling reports, and we have a non-retaliation policy to protect whistleblowers.

  • Investigations and Follow-Up Procedures: Reports are thoroughly investigated, and appropriate actions are taken, including corrective measures and disciplinary actions when necessary.

9. Auditing and Monitoring

  • Internal Audits: Our internal audit team conducts regular audits to assess compliance with policies and procedures, identify weaknesses, and recommend improvements.

  • Risk Assessments: We periodically perform risk assessments to identify and mitigate potential compliance risks within the organization.

  • Dashboarding and Notifications: We utilize a comprehensive dashboarding system that provides real-time insights and notifications, enabling us to proactively address compliance issues and potential violations.
  • Corrective Action Plans: Any issues identified during audits or risk assessments are addressed through corrective action plans designed to prevent future violations.

10. Enforcement and Consequences

  • Disciplinary Measures: Violations of our compliance and ethical standards may result in disciplinary actions, including verbal warnings, written warnings, suspension, or termination, depending on the severity of the violation.

  • Corrective Actions: In addition to disciplinary measures, we take corrective actions to prevent further violations, such as revising policies or enhancing training.

  • Legal Actions (if necessary): In cases of severe violations or violations that have caused significant harm, we may pursue legal actions to recover losses or seek justice.

11. Continuous Improvement

  • Program Evaluation and Review: Our compliance and ethics program is subject to regular evaluation and review to ensure it remains effective and up-to-date.

  • Feedback Mechanisms: We encourage feedback from employees and stakeholders to identify areas for improvement and enhancements to our program.

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