At Beverly Frazier LLC, our commitment to ethical business practices is unwavering. To maintain our high standards of integrity, we have developed comprehensive policies addressing various aspects of our operations. These policies are designed to ensure that our business activities are conducted transparently and ethically, fostering trust and respect among our clients, partners, and employees.

1. Prohibition of Bribes and Kickbacks

Beverly Frazier LLC maintains a zero-tolerance policy towards bribery and kickbacks. All employees, contractors, and business partners are strictly prohibited from offering, giving, soliciting, or accepting any form of bribe or kickback. This includes, but is not limited to, cash payments, gifts, favors, or any other form of inducement designed to gain an unfair advantage or influence business decisions. Any violation of this policy will result in severe disciplinary action, including termination of employment or contracts, and may also lead to legal prosecution. We are committed to creating a business environment where ethical behavior is the norm and where all transactions are conducted with transparency and honesty.

2. Acceptable Gifts, Travel, and Business Entertainment Expenses

While we recognize the role that gifts, travel, and entertainment can play in fostering strong business relationships, Beverly Frazier LLC has established clear guidelines to ensure these activities remain ethical and within acceptable limits. All gifts, travel, and entertainment expenses must be reasonable, proportionate, and transparent. They should never be used to influence business decisions or create a perception of impropriety. Employees are required to obtain prior approval for any significant expenditures and to document all expenses accurately. Regular audits are conducted to ensure compliance with these guidelines. Our aim is to maintain the highest standards of integrity while nurturing valuable business relationships.

3. Maintaining Accurate Books and Records

Accurate and honest record-keeping is essential for the integrity of our business operations. Beverly Frazier LLC mandates that all financial transactions are recorded accurately, promptly, and in accordance with applicable accounting standards and legal requirements. Employees are required to provide truthful and complete information in all reports and documentation. Our internal controls and auditing processes are designed to prevent and detect any discrepancies, ensuring that our financial statements reflect the true nature of our business activities. Falsifying records or engaging in any form of financial misrepresentation is strictly prohibited and will result in disciplinary action.

4. Responding to Demands for Facilitating or Expediting Payments

Beverly Frazier LLC strictly prohibits the use of facilitating, expediting, or "grease" payments to secure or expedite routine government actions or business transactions. If an employee encounters a demand for such payments, they are required to report the incident immediately to our compliance officer. We will not acquiesce to such demands and will take appropriate action to address the situation, which may include refusing the payment and reporting the incident to the relevant authorities. Our policy ensures that we operate within the bounds of the law and uphold our ethical standards, regardless of external pressures.

5. Mandatory Anti-Corruption Training

To reinforce our commitment to ethical practices, Beverly Frazier LLC provides mandatory anti-corruption training to all employees. This training covers our anti-corruption policies, the legal implications of corruption, and practical guidance on recognizing and addressing potential corruption-related issues. Regular training sessions, updates, and assessments are conducted to ensure that our team remains informed and vigilant. By equipping our employees with the knowledge and skills to act ethically, we aim to prevent corruption and promote a culture of integrity within our organization.

Through these comprehensive policies, Beverly Frazier LLC is dedicated to maintaining the highest ethical standards and fostering a culture of transparency and accountability in all our business dealings.