Boldbeam B.V. ("Boldbeam") builds technology decision intelligence for its clients. The trust our clients place in us depends on how we work and on the standards of the people we work with. This Code sets out what we expect of our suppliers, contractors, consultants and their personnel and subcontractors (together, "Suppliers") whenever they provide goods or services to or on behalf of Boldbeam.
Suppliers must comply with this Code and with all applicable laws. Where this Code and the law differ, the stricter standard applies. This Code supplements, and does not replace, the terms of any agreement between a Supplier and Boldbeam; where a specific contract term conflicts with this Code, the contract governs. We ask Suppliers to apply equivalent standards across their own supply chain for work related to Boldbeam.
01Legal and regulatory compliance
Suppliers shall comply with all laws and regulations applicable to their business and to the services they provide to Boldbeam, including the following.
- Anti-corruption. Suppliers shall not offer, promise, give, request or accept any bribe, kickback or improper payment or advantage, directly or indirectly, including to or from any government official. Suppliers shall comply with all applicable anti-bribery and anti-money-laundering laws, including the U.S. Foreign Corrupt Practices Act and the UK Bribery Act 2010.
- Fair competition. Suppliers shall conduct business in compliance with applicable antitrust and fair-competition laws.
- Trade, sanctions and export controls. Suppliers shall comply with applicable export-control and sanctions laws, and shall not cause Boldbeam to breach them. Suppliers confirm they are not owned or controlled by, and do not act on behalf of, any sanctioned or restricted party.
- Accurate records. Suppliers shall keep honest, accurate books and records, and shall not falsify records or misrepresent facts in their dealings with Boldbeam.
02Business ethics
Suppliers shall act with integrity, honesty and transparency in all dealings with Boldbeam.
- Conflicts of interest. Suppliers shall avoid actual or apparent conflicts of interest and shall promptly disclose any personal, family or financial relationship with a Boldbeam employee that could influence, or appear to influence, their engagement with Boldbeam.
- Gifts and entertainment. Suppliers shall not offer gifts, hospitality or anything of value to Boldbeam personnel that could improperly influence a business decision or create the appearance of doing so. Modest, infrequent business courtesies in the normal course are acceptable.
- No improper use of information. Suppliers shall not trade in any company's securities, or enable others to, on the basis of material non-public information obtained through their work with Boldbeam.
- Honest dealing. Suppliers shall be truthful and straightforward in all communications with Boldbeam, including about issues, delays or problems affecting their work.
03Confidentiality, intellectual property and data
Boldbeam's business depends on protecting sensitive information: our methods, our analyses, and information about our clients and their portfolios. This is the area we hold most firmly.
- Confidentiality. Suppliers shall keep confidential all non-public information they receive from or about Boldbeam and its clients, use it only to perform their work for Boldbeam, and not disclose it without authorisation. The existence of a Supplier's relationship with Boldbeam is itself confidential.
- Intellectual property. Suppliers shall respect intellectual property rights and shall honour Boldbeam's ownership of work product created for Boldbeam, as set out in their contract.
- Data protection and security. Suppliers shall comply with applicable privacy and data-protection laws (including the GDPR where it applies), maintain appropriate technical and organisational security measures, use any personal data only as authorised, and promptly notify Boldbeam of any actual or suspected data or security incident affecting Boldbeam or its clients.
- Responsible use of AI and third-party tools. Suppliers shall not input Boldbeam's confidential information or client data into external tools, including AI or machine-learning services, in a way that allows that information to be retained, disclosed or used to train third-party systems, without Boldbeam's prior written consent.
04Use of the Boldbeam name
Suppliers shall not use Boldbeam's name, logo or trade marks, or refer to Boldbeam or its clients in any marketing, website, client list or public material, without Boldbeam's prior written consent in each case.
05People: human rights and fair labour
Boldbeam expects its Suppliers to treat their people with dignity and respect and to uphold internationally recognised human-rights and labour standards.
- Fair and lawful employment. Suppliers shall comply with applicable employment, wage and working-hours laws and provide fair, lawful conditions of work.
- No discrimination or harassment. Suppliers shall provide a workplace free from unlawful discrimination, harassment, bullying and retaliation, and shall provide equal opportunity.
- No forced or child labour. Suppliers shall not use forced, bonded, indentured or involuntary labour, human trafficking or child labour in any form, shall uphold workers' freedom of association, and shall take reasonable steps to ensure the same standards are met within their own supply chain and by any subcontractor working on Boldbeam-related work. Boldbeam's Labour Rights and Modern Slavery Statement sets out the fuller position on these matters and applies alongside this Code.
- Health and safety. Suppliers shall provide a safe and healthy working environment and comply with applicable health-and-safety laws.
06Environmental responsibility
Suppliers shall comply with applicable environmental laws and conduct their operations responsibly, taking reasonable steps to reduce waste, emissions and resource use where they can.
07Raising concerns
Boldbeam wants to hear about conduct that may breach this Code. Suppliers and their personnel are encouraged to raise concerns with their usual Boldbeam contact or by emailing ethics@boldbeam.ai. Boldbeam will treat reports confidentially so far as possible and will not tolerate retaliation against anyone who raises a concern in good faith.
08Compliance
This Code applies to Suppliers through the agreement under which they provide goods or services to Boldbeam, and forms part of doing business with us. Boldbeam may ask Suppliers to confirm their compliance with this Code, and may review or seek information to verify it. A Supplier's failure to meet this Code may lead to corrective action up to and including termination of the relationship.