Company Policies

POLICY STATEMENT

This policy is intended to assist everyone in conducting our business legally, ethically and with integrity. It is not meant to stop legitimate business activities so long as those activities comply with the law and with the Company’s internal policies.

Company Employees must comply with applicable laws in the countries where the Company operates, including local anti-corruption and anti-bribery laws. The laws that may apply to the Company include the Prevention of Corruption Act 1988 of India (“Prevention of Corruption Act”)

The Prevention of Corruption Act in India makes it a crime for any person, by himself or together with any other person, to corruptly give, promise or offer to any person any gratification as an inducement to or reward for any person doing or forbearing to do anything in respect of any matter or transaction whatsoever, actual or proposed. The Act specifically prohibits such payments, promises or offers to any member, officer or servant of a public body.

The Prevention of Corruption Act also makes it a crime for any person, by himself or in conjunction with any other person, to corruptly solicit or receive, or agree to receive for himself or for any other person, any gratification as an inducement to or reward for any person doing or forbearing to do anything in respect of any matter or transaction, actual or proposed.

Provide information and guidance on how to recognise and deal with bribery and corruption issues.

WHO IS COVERED BY THE POLICY?

This policy applies to all individuals working at all levels and grades whether permanent, fixed-term or temporary. In this policy, third party means any individual or organisation CUSTOMER come into contact with during the course of CUSTOMER’s work, and includes actual and potential clients, customers, suppliers, agents and government and public bodies.

WHAT IS BRIBERY?

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

HOSPITALITY AND GIFTS

The Company recognizes that the exchange of business courtesies, such as modest gifts (but not cash), meals and entertainment (including invitations to attend events), is a common practice for various legitimate reasons, including to create goodwill, establish trust in relationships, improve the image of a commercial organization, or better present products or services.

WHAT IS NOT ACCEPTABLE?

Give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

Give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure;

Accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;

accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;

Threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or

Engage in any activity that might lead to a breach of this policy.

FACILITATION PAYMENTS AND KICKBACKS

We do not make, and will not accept, facilitation payments or "kickbacks" of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.

If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment.

DONATIONS/SOLICITATIONS

We do not make charitable donations or contributions to political parties. This policy disallows payment even where an employee has been requested or demanded by a government official or of the Government official threatens adverse actions against the company unless the payment has been made.

INTERNAL FINANCIAL CONTROLS AND RECORD KEEPING

The Company should record all financial transactions according to the Company's financial and internal control policies and procedures. Payments and other compensation to third parties should be accurately recorded in the Company’s corporate books, records, and accounts in a timely manner and in reasonable detail. No undisclosed or unrecorded accounts of the Company may be established for any purpose. False, misleading, incomplete, inaccurate, or artificial entries in the books, records, or accounts of the Company are prohibited. Personal funds should not be used to accomplish what is otherwise prohibited by this Policy.

YOUR RESPONSIBILITIES

You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your manager and/or the Compliance Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with us, or indicates to you that a gift or payment is required to secure their business.

HOW TO RAISE A CONCERN

All employees are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with the Manager immediately.

WHAT TO DO IF YOU ARE A VICTIM OF BRIBERY OR CORRUPTION

It is important that you inform Manager as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity. All report of a suspicious conduct will be treated as confidential

PROTECTION

Employees who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. 1We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future.

TRAINING AND COMMUNICATION

All employees operating in areas that are perceived as high risk as far as the Prevention of Corruption Act is concerned will receive regular, relevant training on how to implement and adhere to this policy. Our zero-tolerance approach to bribery and corruption is communicated to all suppliers, contractors, agents and business and other partners at the outset of our relationship with them and as appropriate thereafter.

MONITORING AND REVIEW

The Manager will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.

POTENTIONAL RISK SCENARIOS:

The following is a list of possible that may arise during the course of your work which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.

If you encounter any of these while working, you must report them promptly to your Manager:

You become aware that a third party engages in, or has been accused of engaging in, improper business practices;

You learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a "special relationship" with foreign government officials;

A third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;

A third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;

A third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;

A third party requests an unexpected additional fee or commission to "facilitate" a service;

A third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;

A third party requests that a payment is made to "overlook" potential legal violations;

You receive an invoice from a third party that appears to be nonstandard or customized;

A third party refuses to put terms agreed in writing;

You notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;

A third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us;

You are offered an unusually generous gift or offered lavish hospitality by a third party.

Data (Privacy) Protection Procedure

B. M. International Pvt. Ltd. maintains personal information from relocating individuals or corporate, as a part of the international relocations process. B.M. International is committed to respect the data by handling all the personal information collected in connection with their international relocation in accordance with applicable local laws as well as our own privacy policy. This document explains our practices with regard to your personal information.

Management:

We will, through appropriate management and strict application of criteria and controls:

Observe fully conditions regarding the fair collection and use of information.

Meet our legal obligations to specify the purposes for which information is used.

Collect and process appropriate information, and only to the extent that it is needed to fulfill our operational needs or to comply with any legal requirements.

We ensure that we have a responsible person in the Company for ensuring compliance with up to date Data (Privacy) Protection Procedure / Operational Control Procedure.

We ensure that everyone processing personal information understands that they are contractually responsible for following good data protection practice aligned with internal procedures and legal requirements.

We collect, process and transfer personal information about client /relocating Individual through computerized and paper-based data processing systems.

We ensure that all processing and transfers of personal information are subject to reasonable confidentiality and privacy safeguards.

Notice:

We provide notice about our privacy policies and procedures in our contract agreements and individual quotations; we communicate the same to our customers, vendors, staff and also planning to make it available on our company website – www.bminternational.com . We are committed to respect our customer (relocating individual/corporate and /or agent) by handling all their personal information collected in connection with their international relocation procedure in accordance with applicable law as well as company’s own Privacy Policies.

We may process sensitive information if it is needed to for business objectives (statistics) or if it is required to comply with applicable law. Depending on the services required by the customer, the information / documents are requested from customer. These information/s are copy of passport, copy of visa, address, phone & email address for communication/operational purposes, flight details & other as per required by customs for clearing the cargo etc.

In general personal and/or sensitive information will not be collected, processed or transferred, except where adequate privacy protection mechanisms are in place.

Choice and consent:

By engaging B.M. International, for handling / relocation services, you give your explicit consent with respect to the collection, use, and disclosure of personal information as described in this notice. Explicit consent here means you were clearly presented with an option to agree or disagree with the collection, use, or disclosure of personal information.

Collection:

By engaging B.M. International, for handling / relocation services, you give your explicit consent with respect to the collection, use, and disclosure of personal information as described in this notice. Explicit consent here means you were clearly presented with an option to agree or disagree with the collection, use, or disclosure of personal information.

Collection:

We shall obtain and process personal data fairly and in accordance with statutory and other legal obligations. We collect personal information for the sole purposes to facilitate the door to door process of the international Relocations for the relocation individual and his / her family. We use customer information to service our accounts, process claims – if any, ensure proper billing, and to offer you other services and products that may suit your needs.

Use, retention, and disposal:

We limit the use of personal information to the sole purpose of executing your International Relocations and for which you have given your implicit Consent.

We retain personal information for only as long as necessary to fulfil the stated purposes or as required by law or regulations and thereafter appropriately dispose of such information. For example we will retain your personal information for FIVE (5) years as require by law. After this time relocation files and personal data are destroyed. Files are kept behind locked doors and are only accessed on an as needed basis.

Access:

You may reasonably access and update your personal information by contacting B.M. International Pvt. Ltd.

Disclosure to third parties:

We shall use and disclose your personal data only in circumstances that are necessary for the purposes for which we collected the data. For example we will disclose your personal information on a need to know basis to - Customs authorities and partners involved in the relocations process. We will never sell your personal information to third party.

Security for privacy:

We protect personal data against unauthorized access (both physical and logical) aligned with our internal IT policy and procedures as defined in Electronic Data Protection OCP. We shall take appropriate security measures against unauthorized access to, or alteration, disclosure or destruction of personal data and against its accidental loss or destruction. Personal data will only be accessible to authorized staff.

Quality:

We maintain accurate, complete, and relevant personal information as reasonable possible and only for the purposes identified in this notice.

We retrieve your personal data from emails you shared with us, your employer and or relocation company / our associate provides and from documents you shared with us.

Please note that we have shared responsibility with regard to the accuracy of your personal information. Please let us know of any changes to your personal information.

Monitoring and enforcement:

We monitor compliance with our privacy policies and procedures and have procedures to address privacy related complaints and disputes. All B.M.I. staff are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them. If you believe that your personal information is not handled in accordance with the applicable law or our privacy policies, you may submit a complaint to B.M.I’ s responsible person who will investigate the complaint.

Glossary of Terms

Privacy:

The rights and obligations of individuals and organizations with respect to the collection, use, retention, disclosure, and disposal of personal information.

Personal information:

(sometimes referred to as personally identifiable information) information that is about, or can be related to, an identifiable individual. It includes any information that can be linked to an individual or used to directly or indirectly identify an individual.

Individuals, for this purpose, include prospective, current, and former customers, employees, and others with whom the entity has a relationship. Most information collected by an organization about an individual is likely to be considered personal information if it can be attributed to an identified individual. Some examples of personal information are as follows:

• • Name
• • Home or e-mail address
• • Date of Birth
• • Identification number (for example, a Social Security or Social Insurance Number)
• • Physical characteristics
• • Consumer purchase history

Sensitive information:

Some personal information is considered sensitive. Some laws and regulations define the following to be sensitive personal information:

• • Information on medical or health conditions
• • Financial information
• • Racial or ethnic origin
• • Political opinions
• • Religious or philosophical beliefs
• • Trade union membership
• • Sexual preferences
• • Information related to offenses or criminal convictions

Non-personal information: information about or related to people that cannot be associated with specific individuals. This includes statistical or summarized personal information for which the identity of the individual is unknown or linkage to the individual has been removed. In such cases, the individual’s identity cannot be determined from the information that remains because the information is de-identified or anonymized. Non-personal information ordinarily is not subject to privacy protection because it cannot be linked to an individual. However, some organizations may still have obligations over non-personal information due to other regulations and agreements

Privacy or Confidentiality?

Unlike personal information, which is often defined by law or regulation, no single definition of confidential information exists that is widely recognized. In the course of communicating and transacting business, partners often exchange information or data that one or the other party requires be maintained on a “need to know” basis. Examples of the kinds of information that may be subject to a confidentiality requirement include the following:

• • Transaction details
• • Engineering drawings
• • Business plans
• • Banking information about businesses
• • Inventory availability
• • Bid or ask prices
• • Price lists
• • Legal documents
• • Revenue by client and industry

Also, unlike personal information, rights of access to confidential information to ensure its accuracy and completeness are not clearly defined. As a result, interpretations of what is considered to be confidential information can vary significantly from organization to organization and, in most cases, are driven by contractual arrangements.

Explicit consent:

Is a freely given, specific and informed agreement by a customer (Relocating Individual / Corporate or agent) in the processing of personal information about her/him. Explicit consent is needed for processing sensitive data.

Processing:

Means collecting, amending, handling, storing or disclosing personal information.