2024-2025 Disclosure:

A recent review found that two account managers committed a serious breach of the BDC Code of Ethics by exchanging sales acquisition credits. This enabled one of them to qualify for an incentive payment in Fiscal 2024. Their arrangement involved both a personal financial transaction and a future consideration of a sales credit. BDC senior leadership took immediate corrective action. Both individuals are no longer employed at BDC.

Furthermore, a review was conducted to determine whether similar trades of sales acquisition credits were occurring amongst employees and if employees had engaged in similar personal financial compensation exchanges. Although there was no indication that other employees engaged in personal financial compensation exchanges, the Senior Officer of Internal Disclosure recommended that BDC; (i) review and update the pertinent compensation program and provide further guidance on the acceptable allocation of sales acquisition credits, (ii) reinforce the BDC Code of Ethics and (iii) implement ongoing monitoring to identify cases of misallocated sales acquisition credits.