The TrustQuay Board expects high standards of ethical behaviour and financial probity in all business dealings of TrustQuay and its subsidiary companies (the “Group”) and in the business dealings carried out on behalf of the Group. The Board acknowledges that the reputation of the Group with its employees, trading partners and in the wider community depends on achieving these high standards.
The Board has zero tolerance of bribery and requires that the management implements proportionate risk-based procedures that protect the reputation of the Group and ensure that the Group meets its obligations under the Bribery Act 2010.
The Group prohibits the offering, giving, solicitation or acceptance of any bribe, whether pecuniary or otherwise:
The Group prohibits any inducement resulting in a personal gain or advantage to the recipient (or any person or body associated with them) which is intended to influence them to take action that may not be solely in the interests of the Group or of the person or body employing them or whom they represent.
The following practices are not prohibited providing they are proper in all respects, customary in a particular market, proportionate and adequately recorded:
*These are only permitted if approved in advance by TrustQuay’s Chief Executive or Finance Director or if in full compliance with a written TrustQuay policy approved by the TrustQuay Board. All other facilitation payments are prohibited.
The Group’s anti‐bribery approach includes:
Approved by the TrustQuay Board 18 May 2020.