Anti-Corruption Policy

Anti-Corruption Policy

Our commitment to conducting business with integrity, transparency, and in compliance with anti-corruption laws worldwide.

Policy Overview

Zero Tolerance

BagginsHQ maintains a zero-tolerance approach to bribery and corruption in all its forms. We are committed to:

  • Acting professionally and ethically
  • Implementing robust controls

Global Compliance

We comply with all applicable anti-corruption laws and regulations worldwide, including but not limited to:

  • U.S. Foreign Corrupt Practices Act
  • UK Bribery Act

Scope

This policy applies to all individuals working at all levels within BagginsHQ, including:

  • Employees and management
  • Contractors and third parties

Key Provisions

Prohibited Activities

  • Bribery:
    Offering, promising, giving, or accepting anything of value to improperly influence a decision or gain an unfair advantage.
  • Facilitation Payments:
    Small payments made to secure or expedite a routine government action.
  • Kickbacks:
    Payments made in return for a business favor or advantage.

High-Risk Areas

  • Gifts & Hospitality:
    Must be reasonable, proportionate, and made in good faith.
  • Third-Party Relationships:
    Due diligence required for agents, consultants, and partners.
  • Political Contributions:
    Strictly regulated and require senior management approval.

Compliance Program

Due Diligence

We conduct risk-based due diligence on third parties before entering into business relationships.

  • Background checks
  • Risk assessment

Training

Regular anti-corruption training is provided to all employees and relevant third parties.

  • Annual certification
  • Role-specific training

Monitoring

We maintain a robust monitoring system to detect potential violations.

  • Regular audits
  • Transaction reviews

Reporting Violations

All employees and business partners are encouraged to report any suspected violations of this policy through our established reporting channels:

Email:
corporate-relations@bagginshq.com
Online Portal:
Confidential Reporting Portal
Direct Reporting:
To Compliance Officer or Legal Department

For more information on reporting procedures, please refer to our Whistleblower Policy.

Contact Our Compliance Team

Have questions about our compliance policies? Our team is here to help.

Contact us at corporate-relations@bagginshq.com
Please include "Anti-Corruption Inquiry" in your email subject line for a response within 5-14 business days.
For more information on our ethical standards, please review our Code of Conduct.

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Global Offices

Europe

United Kingdom

Part of Gerizon UK
71-75, Shelton Street, Covent Garden
London, WC2H 9JQ
England & Wales

Netherlands

Baggins Tech Netherlands B.V.
World Trade Center (WTC)
Strawinskylaan 1
1077 XW Amsterdam

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Middle East

Baggins Qatar Technologies
Office 1502, 15th Floor, Palm Tower B
Majlis Al Taawon Street, West Bay
Doha, State of Qatar

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(UAE entity: Baggins Technologies FZE)

Africa

Baggins SA Digital Solutions
Suite 7A, The Modernist
35 Loop Street, Cape Town CBD
Cape Town, 8001, Western Cape
South Africa

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(KE entity: Baggins Technology Enterprises)

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