REAL ESTATE CODE OF ETHICS & COMPLIANCE
BEST OF HAITI REAL ESTATE
Best of Haiti Real Estate is committed to conducting all business activities with integrity, professionalism, and respect for our clients, colleagues, and the communities we serve. Our real estate professionals are dedicated to upholding the highest ethical standards, ensuring that every transaction is conducted transparently and fairly. This Code of Ethics serves as a guide for the professional conduct of all agents, brokers, and employees within our organization.
1. COMMITMENT TO CLIENTS
Real estate professionals at Best of Haiti Real Estate shall prioritize their clients’ best interests in all transactions. We are committed to providing honest, professional, and knowledgeable advice, ensuring that our clients are fully informed throughout the buying, selling, or leasing process.
2. HONESTY AND INTEGRITY
All real estate transactions must be conducted with honesty and integrity. Real estate professionals must provide accurate information, avoid misrepresentation, and disclose all known material facts that could affect the value or desirability of a property.
3. CONFIDENTIALITY
Real estate professionals must protect the confidentiality of their clients’ information, including financial details and personal data. This information should only be disclosed with the client’s consent or when legally required. Confidentiality is key to maintaining trust and ensuring that clients feel secure in their transactions.
4. TRANSPARENCY AND DISCLOSURE
Real estate professionals are required to disclose any conflicts of interest, including personal or financial interests in a transaction, and must always act in the best interest of their clients. Transparency in all dealings is essential to maintaining the trust and confidence of clients.
5. FAIRNESS AND NON-DISCRIMINATION
Real estate professionals at Best of Haiti Real Estate must treat all clients, colleagues, and other parties in a transaction with fairness and respect. Discrimination based on race, color, religion, sex, disability, familial status, national origin, or any other protected characteristic is strictly prohibited.
6. COMPETENCE AND PROFESSIONAL DEVELOPMENT
Real estate professionals are responsible for maintaining their professional competence through ongoing education and staying current with changes in laws, regulations, and market conditions. They must provide services that reflect the latest industry knowledge and best practices.
7. COMPLIANCE WITH LAWS AND REGULATIONS
Real estate professionals must comply with all relevant laws, regulations, and ethical standards governing real estate practice. This includes understanding and adhering to local, state, and federal laws, as well as the rules and guidelines of any professional organizations to which they belong.
8. CONFLICT OF INTEREST
Real estate professionals must avoid situations in which their personal interests conflict with their clients’ interests. Any potential conflict of interest must be disclosed to the client immediately, and the real estate professional must take steps to ensure that their actions remain impartial and fair.
9. ACCOUNTABILITY
Real estate professionals are accountable for their actions and decisions in all transactions. They must be willing to report and address any unethical behavior or violations of this Code of Ethics, and take responsibility for any mistakes or oversights in their practice.
10. PROFESSIONAL CONDUCT
Real estate professionals must conduct themselves professionally at all times, ensuring their behavior reflects positively on Best of Haiti Real Estate and the real estate industry as a whole. This includes respectful interactions with clients, colleagues, and competitors.
11. COMMUNITY RESPONSIBILITY
Real estate professionals at Best of Haiti Real Estate are encouraged to contribute positively to the communities they serve. This includes promoting sustainable practices, supporting local initiatives, and engaging in activities that enhance quality of life in the areas where they operate.
12. ANTI-CORRUPTION & BRIBERY
Introduction
Corruption and bribery are illegal and unethical. They destabilize communities, undermine the rule of law, and pose serious threats to sustained economic progress and the healthy operation of markets. Failure to address the
risk of corruption and bribery may undermine our reputation and lead to investigations, fines and/or other penalties for the company and/ or individuals.
We do not engage in corruption, and we never pay bribes, regardless of local custom or practice. Glencore’s position on corruption is clear: the offer, payment, authorization, solicitation or acceptance of bribes or other improper advantages is unacceptable.
Who does this apply to?
This Anti-Corruption and Bribery Policy sets out Best of Haiti Real Estate’s approach to preventing bribery and other forms of corruption.
This policy applies to all employees, directors, and officers, as well as contractors under Best of Haiti Real Estate’s direct supervision, who work for a Best of Haiti Real Estate office or industrial asset that is directly or indirectly controlled or operated by Best of Haiti Real Estate plc worldwide.
We assert our influence over joint ventures we don’t control or operate to encourage them to act in a manner consistent with this policy.
What is our commitment?
We do not tolerate bribery of any kind, whether to a public official or a private individual.
We never offer, provide, or authorize bribes of any kind, including facilitation payments, either
directly or indirectly, to a public official or a private individual.
We never request or accept bribes of any kind, either directly or indirectly. A bribe may be monetary or non-monetary, tangible or intangible. A bribe may take the form of, or be facilitated through:
- payments of money;
- travel, gifts or entertainment;
- discounts, loans and/or financing given on
non-commercial terms; - rebates or kickbacks in relation to
services provided; - overpayments to business partners;
- use of assets at a discount or free of charge;
- sponsorships, charitable contributions and
community investments;political contributions; - employment or internships; or
information or assistance.
To manage our bribery and corruption risk, we implement a range of procedures and controls relating to dealings with public officials, gifts and entertainment, our business partners, sponsorships and donations, political
contributions and record keeping.
We remain alert to red flags of corruption and bribery and report them to Compliance. If we are asked to pay a bribe, we must refuse to pay and immediately inform Compliance.
Public officials
Dealing with public officials carries a higher risk of corruption or of its perception. We are especially careful when communicating with public officials, providing travel, gifts and entertainment to public officials, or providing any other in-kind assistance to public officials.
Travel, gifts and entertainment
The proper management of the provision and acceptance of travel, gifts, and entertainment is key to mitigating the risk of actual or perceived bribery and corruption. We only provide or accept travel, gifts and entertainment that are:
- in good faith, occasional, reasonable
and appropriate; - a normal business courtesy; and
- transparent
We don’t provide or accept travel, gifts
and entertainment:
- with the intent or prospect of influencing the
recipient’s decision-making or other conduct; - with the intent of obtaining any improper or
undue advantage; - that could reasonably in any way be
perceived as a bribe; or - in the form of cash, including pre-paid cards
or gift cards redeemable for cash, precious
stones and metals, cryptocurrency (e.g.,
Bitcoin, Ethereum, Solana, Tether) and other
‘commodity money’ such as gold coins.
Facilitation payments
In certain jurisdictions, public officials may request small payments, known as facilitation payments, to expedite or secure the performance of a routine governmental action such as issuing permits, licenses, or other
official documents, processing government papers such as visas, providing customs clearances, providing police protection, providing utility services, or handling cargo.
Facilitation payments are a form of bribery, and we never pay, or authorize the payment of, facilitation payments. If we are asked to make a facilitation payment, we must refuse to pay and immediately inform Compliance.
Payments made under duress and extortion
Best of Haiti Real Estate prioritizes the physical safety and well-being of all its employees and contractors. If our welfare or safety is at risk, we take reasonable steps to remove ourselves from danger. In exceptional circumstances, this may include making a payment to a public official to ensure our safety. We must report any such incident to Compliance as soon as we are safely able to do so.
Sponsorships, charitable contributions and community investments
We never make a sponsorship, charitable contribution, or community investment to disguise a bribe or to gain an improper business advantage.
We ensure that before we enter into sponsorships, community investments, or make charitable contributions, we conduct risk-based due diligence. We monitor the appropriate use of our funds or resources when required.
Political contributions
We do not seek to influence the political process by improper or corrupt means. To mitigate this risk, we do not contribute any funds or resources towards any political campaign, political party, political candidate, or any politically affiliated organization.
Business partners
We work with a range of business partners and expect them to share our commitment to ethical and responsible business practices and conduct. We never authorize a business partner to engage in bribery or corruption on our behalf.
We take care to know who our business partners are by implementing our risk-basedKnow Your Counterparty Program.
To manage our bribery and corruption exposure associated with our business partners, we implement a range of controls and processes including screening, due diligence and monitoring, using a risk-based approach.
We implement additional controls for high-risk business partners, such as business developers, joint venture partners, lobbyists, or those who interact with public officials on our behalf. We conduct a detailed risk-based assessment prior to entering into these types of relationships to identify and mitigate the risk of corruption associated with these engagements. Where appropriate, we also conduct ongoing monitoring and regular review of our high-risk business partner relationships.
Speaking openly and raising concerns
We are each responsible for ensuring that we meet our commitments. We expect our employees and contractors to speak openly and require them to report any concerns regarding breaches of the Code of Conduct, our policies or the law, whether these relate to themselves or others. These concerns must be raised with managers or supervisors, or via other available reporting channels, including dedicated whistleblowing contacts at our offices and industrial assets. Our Corporate Raising Concerns Program channels are also available to employees, contractors and external parties. We also expect employees to report any breaches of requirements in our procedures.
Best of Haiti Real Estate takes concerns seriously and handles them promptly.
Best of Haiti Real Estate has zero tolerance for retaliation against anyone who speaks openly about conduct they believe is unethical, illegal, or not in line with our Code of Conduct, policies, and procedures, even if the concern isn’t substantiated. There will be no adverse consequences for anyone who raises a concern, as long as they have not knowingly made a false report.
13. CONSEQUENCES OF CODE VIOLATIONS
Violations of this Real Estate Code of Ethics can result in disciplinary action, including termination of employment or association with Best of Haiti Real Estate. The severity of the discipline will depend on the nature of the violation and the real estate professional’s willingness to disclose the issue and cooperate during any investigation.
At Best of Haiti Real Estate, we believe that ethical real estate practice is the foundation of trust and success in the industry.
CONTACT DETAILS
All questions, comments, concerns, reporting, or praise should be directed to Best of Haiti Real Estate’s compliance department via the email or physical address below:
Email: compliance@bestofhaitirealestate.com
Physical Address: Impasse Fleury, Rue Coutilien #4
Musseau, Petion-ville, Haiti, HT4410
