Blackbone has zero tolerance for bribery, corruption and improper conflicts of interest. This policy applies to conduct involving public officials and private business partners, directly or through intermediaries.
1. General principles
Decisions must be based on merit, quality and legitimate business interests. Material transactions must be supported by clear contracts, invoices and records. No one may offer, request or accept an improper benefit to influence a decision.
2. Gifts and hospitality
Gifts must be occasional, reasonable, symbolic and unrelated to an improper business advantage. The published policy limits gifts to EUR 200 per event and requires gifts over EUR 100 to be reported and recorded. Cash and cash equivalents are prohibited. Gifts to public officials are prohibited apart from modest official protocol items where lawful; stricter legal or contractual rules prevail.
3. Conflicts of interest
Team members must disclose relevant competing work, family relationships with business partners, financial interests and incompatible public or political roles. Disclosures are updated when circumstances change. Conflicts are managed through withdrawal from decisions, supervision or removal of the conflicting interest.
4. Facilitation payments
Payments to accelerate routine official action are prohibited, regardless of local practice.
5. Sponsorship and donations
Sponsorships and donations require a written agreement, a verified recipient, management approval and proper accounting. They must not be linked to an improper commercial advantage.
6. Partner checks and procurement
Risk-appropriate checks may cover ownership, sanctions, tax and litigation history. Relevant contracts include integrity obligations. Public procurement communications use official channels; bribery, favours and collusion with other bidders are prohibited. Decisions must be documented.
7. Financial integrity
Payments must comply with applicable anti-money-laundering rules, sanctions and cash limits. Customer checks and reporting obligations are assessed according to the activity and legal requirements.
8. Code of conduct
• Honesty: accurate information and realistic commitments.
• Confidentiality: protect customer and company information.
• Respect: treat colleagues, customers and communities fairly.
• Quality: deliver work responsibly and address defects.
• Accountability: acknowledge mistakes and correct them.
9. Reports and consequences
Report suspected breaches through the Whistleblowing channel. Retaliation is prohibited. Breaches may result in proportionate disciplinary or contractual action and referral to competent authorities where appropriate.
10. Contact
Ethics questions and reports: integritate@blackbone.ro.