Ethics, Compliance & Anti-Corruption Policy

Bravo1Alpha maintains a robust Ethics, Compliance, and Anti-Corruption framework governing all operations, personnel, contractors, partners, and third-party representatives. Our policies are designed to ensure full compliance with applicable international legislation, including the U.S. Foreign Corrupt Practices Act (FCPA), the Canadian Corruption of Foreign Public Officials Act (CFPOA), and the UK Bribery Act, as well as relevant national laws and international best-practice standards.

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Bravo1Alpha applies a zero-tolerance approach to bribery, corruption, facilitation payments, improper gifts or hospitality, conflicts of interest, and unethical conduct. All interactions with government authorities, defence institutions, military organisations, law-enforcement bodies, and state-owned enterprises are governed by strict internal controls and documented approval processes.

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To manage risk across complex operational environments, Bravo1Alpha implements risk-based due diligence for clients, partners, intermediaries, suppliers, and agents prior to engagement and throughout the lifecycle of each relationship. Financial transparency, accurate books and records, segregation of duties, and audit-ready documentation are mandatory across all projects.

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Oversight of ethics and compliance is assigned to senior management and the governing authority, with clearly defined responsibility for compliance monitoring, periodic ethics and corruption risk assessments, and enforcement of policy requirements. Compliance obligations are supported by mandatory training, awareness briefings, and contractual compliance clauses with third parties.

Bravo1Alpha provides confidential reporting and whistleblowing channels, enabling employees and partners to raise concerns without fear of retaliation. All reports are assessed and investigated in a timely, independent, and proportionate manner, with corrective actions implemented where necessary.

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Our Ethics and Compliance policies are reviewed regularly to reflect changes in legislation, operational risk, and client requirements, ensuring Bravo1Alpha operates with integrity, transparency, and accountability across all engagements.

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B1A Code of Conduct

1. Purpose and Scope

This Code of Conduct sets out the ethical principles, professional standards, and compliance obligations that apply to B1A (Bravo1Alpha), its directors, officers, employees, contractors, consultants, and any third parties acting on its behalf. It applies to all business activities, in all jurisdictions in which B1A operates.

B1A operates in sensitive, high-risk, and regulated environments. Integrity, accountability, and lawful conduct are fundamental to our operations and relationships with clients, partners, and authorities.

2. Ethical Conduct and Integrity

All individuals representing B1A shall act with honesty, professionalism, and integrity at all times. Decisions must be taken objectively, without improper influence, personal gain, or unethical behaviour.

B1A does not tolerate:

• Bribery, corruption, facilitation payments, or kickbacks

• Fraud, misrepresentation, or deceptive practices

• Abuse of authority or misuse of position

3. Legal and Regulatory Compliance

B1A is committed to full compliance with all applicable laws, regulations, and international standards, including but not limited to:

• Anti-bribery and anti-corruption legislation

• Export controls, trade restrictions, and sanctions regimes

• Defence, security, and intelligence-sector regulations

• Data protection and information-security requirements

All personnel are expected to understand and comply with the legal obligations relevant to their role.

4. Anti-Bribery and Anti-Corruption

B1A applies a zero-tolerance approach to bribery and corruption. No person acting on behalf of B1A may offer, promise, give, request, or accept anything of value to improperly influence a decision or obtain an unfair advantage.

This applies equally to dealings with:

• Government and public officials

• Military and law-enforcement bodies

• State-owned or state-controlled entities

• Commercial partners and intermediaries

Gifts, hospitality, donations, or sponsorships must be reasonable, transparent, documented, and approved in accordance with B1A policy.

5. Conflicts of Interest

All individuals must avoid situations where personal, financial, or external interests could conflict with the interests of B1A or its clients.

Any actual or potential conflict of interest must be disclosed promptly. Failure to disclose conflicts may result in disciplinary action.

6. Confidentiality and Information Security

B1A handles sensitive, operational, and mission-critical information. All individuals are required to:

• Protect confidential and proprietary information

• Apply strict need-to-know principles

• Follow approved information-security and data-handling procedures

Unauthorised disclosure, misuse, or negligent handling of information is strictly prohibited.

7. Professional Conduct and Respect

B1A is committed to a professional, respectful, and lawful working environment. Discrimination, harassment, intimidation, or abusive behaviour will not be tolerated.

B1A respects internationally recognised human-rights principles and expects all activities to be conducted in a lawful, ethical, and proportionate manner.

8. Use of Company Assets

Company assets, systems, data, and resources must be used responsibly and exclusively for legitimate business purposes. Misuse, unauthorised access, or improper disclosure is prohibited.

9. Reporting Concerns and Whistleblowing

B1A encourages the reporting of suspected misconduct, breaches of this Code, or illegal or unethical behaviour. Reports may be made confidentially and without fear of retaliation.

All reports will be assessed and investigated in a timely, impartial, and appropriate manner.

10. Enforcement and Disciplinary Measures

Breaches of this Code of Conduct may result in disciplinary action, including termination of employment or contracts, and referral to relevant authorities where required.

Compliance with this Code is a condition of engagement with B1A.

11. Responsibility and Review

All individuals subject to this Code are responsible for understanding and complying with its requirements and for seeking guidance where uncertainty exists.

This Code of Conduct is reviewed periodically to ensure continued legal compliance, operational relevance, and alignment with B1A’s ethical standards.