Anti-Bribery & Fraud Policy

Purpose

Bullman Minerals Inc. (the "Company") is committed to the highest standards of business, personal and professional ethical behaviour. It is the purpose of this policy to ensure the Company remains free of corrupt practices or acts of bribery that provide an unfair financial or other advantage and to be recognized by our customers, employees, community and shareholders as a responsible Company committed to conducting business in an honest way.


Policy

  1. The Company is committed to compliance with all applicable laws, rules, and regulations in every jurisdiction in which it does business.
  2. Directors, Managers, Employees, Contractors and Suppliers are expected to adhere to the standards and restrictions imposed by those laws, rules and regulations and Company’s Code of Ethics and Conduct, Policies, Procedures and Rules. It is every employee’s responsibility to report any suspicion of Bribery or Fraud using the Whistleblowing Reporting Procedure.
  3. Neither the Company nor any of its Directors, Managers, Employees, Contractors and Suppliers are permitted to directly or indirectly influence (with money, gifts or promises) any government, official, political party or political candidate in order to assist the Company in obtaining or retaining business or in directing business to any other person.
  4. The Company will develop employee knowledge and understanding of Bribery and Fraud risks related to employment functions.
  5. Managers within the Business Units have the responsibly of identifying those who work in areas within the Company as being particularly high risk and providing them with additional knowledge and understanding.
  6. The Company will conduct in-house and third party reviews to ensure it remains fully compliant with relevant regulations.
  7. The Company maintains appropriate methods in its Whistleblowing Investigation Guideline to ensure that Concerns raised in accordance to paragraph 3 above have been satisfactorily resolved.
  8. The Company will not tolerate any incident of Bribery or Fraud, committed by the Company's Directors, Managers, Employees, Contractors and Suppliers, either from within or outside the Group, and will take swift action (including suspension, dismissal and legal action) against those persons committing Bribery or Fraud, irrespective of length of service or position. Noncompliance with the Company's Policy on Anti-Bribery and Fraud may include discipline up to and including discharge for Company Directors, Managers, and Employees and may result in Contractor and Supplier dismissal and contract termination.

The effect of this Policy on Anti-Bribery and Fraud extends to all the Company’s dealings and transactions wherever it conducts its business.