Legal · Anti-Bribery and Corruption
Anti-Bribery and Corruption Policy
Taurex has zero tolerance for bribery — including 'facilitation payments' to customs and port officials, which are illegal in the UK with no exception. This policy is our Bribery Act 2010 'adequate procedures' defence to the strict-liability s.7 offence.
Why this policy exists
The Bribery Act 2010 creates four offences: bribing another person (s.1), being bribed (s.2), bribing a foreign public official (s.6), and failure of a commercial organisation to prevent bribery by an associated person (s.7 — strict liability). The only defence to s.7 is showing we had 'adequate procedures' in place. This policy and its implementation are those procedures. Penalty: unlimited fine + up to 10 years' prison for individuals + debarment from public contracts.
Scope — who and where
Every Taurex employee, director, contractor, and 'associated person' (agents, customs brokers, port agents, sub-contracted carriers). Every business activity in every country we operate in. NO exceptions for local custom, market pressure, or business urgency.
What counts as a bribe
Offer, promise, gift, or receipt of any financial or other advantage with intent to induce improper performance. Includes cash, vouchers, gift cards, goods, services, hospitality beyond reasonable norms, facilitation payments, jobs / favours to relatives of counterparties, charitable or political donations made to win business. It is bribery whether or not the bribe is actually paid — the offer is enough.
Facilitation payments — zero tolerance
Facilitation payments ('grease', 'tea money', 'expediting fees') to public officials are bribery under UK law with NO exception (unlike US FCPA). Staff refuse politely, pay only legitimate published fees against an official receipt, escalate to Director within 24 hours, and document. Personal safety exception: under physical duress (e.g. armed border guard), pay the minimum, document immediately, report on return. Safety first.
Gifts and hospitality
Allowed: reasonable, occasional, openly given hospitality — coffee, lunches, modest branded merchandise, sector events. NOT allowed: anything over £100/person without prior Director approval; anything appearing intended to influence a decision; cash or cash equivalents; ANY gifts to public officials, civil servants, regulators or judiciary; lavish entertainment. Gifts and hospitality register maintained — every item above £25 logged.
Due diligence on third parties
Before engaging an associated person (especially overseas brokers, port agents, sub-contracted carriers in high-corruption jurisdictions per Transparency International CPI), we verify legal status, screen entity and beneficial owners against sanctions and PEP lists, check adverse media. CPI below 50 → require written acceptance of this policy, commitment to no facilitation payments, audit rights. Renewed annually.
Training, reporting, consequences
Day-1 briefing for every new employee or contractor + annual e-learning refresher + role-specific training for operations, sales, customs. Training records kept 6 years. Required reporting: any bribe offered, paid, requested, or suspected → [email protected] (Director-only access) or anonymous post marked 'Private and Confidential — Ethics'. Retaliation against reporters is a disciplinary offence (Public Interest Disclosure Act 1998 protection). Consequences for breach: dismissal, recovery of losses, police referral, Director disqualification under Company Directors Disqualification Act 1986.
Last reviewed 2026-06-06.