Anti-Bribery and Corruption Policy

We believe that the success of Blackchair is built on strong, ethical foundations. This policy reflects our commitment to maintaining a business environment where integrity is paramount and where we all work together to prevent bribery and corruption in every aspect of our operations.

01.Purpose

At Blackchair, we are committed to conducting business with the highest standards of integrity and transparency. Our goal is to ensure full compliance with anti-bribery and corruption laws, which means adhering to regulations and doing the right thing in every business decision. This policy applies to all Blackchair employees, directors, officers, contractors, and third parties acting on our behalf, no matter where we operate. We follow the U.S. Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act 2010 (where applicable), and other relevant laws. Violating these laws can result in severe consequences—including legal penalties, reputational damage, and disciplinary actions such as termination. It’s not just about legal compliance; it’s about living up to the trust we’ve built with our clients, partners, and each

 

02.Prohibited conduct

We take a strong stand against any form of unethical behavior, and the following actions are strictly prohibited:

• Bribery – Offering, promising, giving, or receiving anything of value to influence a business decision unfairly. It’s as simple as that—bribery is never acceptable.
  
  
• Facilitation payments – Small, unofficial payments to speed up routine government actions. These are strictly prohibited, no exceptions. Routine actions are not something we should be paying for; they should be carried out fairly and without shortcuts.
  
  
• Kickbacks – Any type of payment made in return for preferential treatment. This kind of behavior undermines trust and fairness.
  
  
• Improper gifts and hospitality – Giving or accepting gifts, entertainment, or hospitality intended to influence a business decision crosses the line. If it’s meant to sway a decision, it’s not okay. And that includes any gifts that are excessive or offered in inappropriate contexts.
  
  
• Political and charitable donations – Contributions made to gain a business advantage, directly or indirectly. These types of donations should always be made with the right intentions.

No matter the pressure or request, employees are never to make or authorize bribes, improper payments, or any form of unethical behavior—even if a client, vendor, or government official asks for it.

03.Employee responsibilities

Each one of us plays a crucial role in maintaining Blackchair’s high standards. Here’s what is expected from all employees:

• Complete mandatory anti-bribery and corruption training. It’s there to ensure that we all understand the rules and how to apply them.
  
  
• Keep accurate records of any transactions and interactions that could fall under the scope of this policy. Transparency is key.
  
  
• Report any suspected violations immediately. If something feels off, we need to address it quickly. No concern is too small to report.

Failure to comply with this policy isn’t just about breaking the rules; it can affect the reputation of the company and its trust with clients. We take violations seriously, and that may result in disciplinary actions, including termination.

04.Reporting and whistleblower protection

We understand that speaking up might be challenging, but it’s essential to maintaining an ethical work environment. Employees are encouraged to report concerns confidentially through the following channels:

• The Legal or Compliance Department.
• HR or the CFO/CEO.

We take any form of retaliation seriously. If you report a concern in good faith, you are protected. We want everyone to feel safe and confident in coming forward without fear of retaliation. Your voice matters, and reporting issues is key to maintaining the trust critical to our business

05.Consequences of non-compliance

Violating this policy is serious and can have

far-reaching consequences:

• Immediate termination of employment or contracts.
• Civil and criminal penalties, including fines and imprisonment.
• Legal action against individuals and Blackchair as a company.

These consequences are not just about penalties—they are about preserving the integrity of Blackchair. Every decision we make reflects on the company and the reputation we’ve built.

06.Policy review and updates 

We review this policy annually to ensure it stays up-to-date with any changes in the law or our business environment. We’ll communicate any necessary updates, and the Chief Financial Officer (CFO) is responsible for overseeing the review and ensuring the policy meets all legal and operational needs