1. Purpose
1.1 This Policy establishes TrustCome’s institutional framework for preventing, identifying, resisting, reporting, investigating and remediating bribery, corruption and improper influence.
1.2 It protects the independence of decisions, the integrity of relationships, the lawful use of resources and the confidence placed in TrustCome by governments, institutions, private principals, families, advisers, businesses and strategic counterparties.
2. Policy Statement
2.1 TrustCome prohibits bribery, corruption, kickbacks, facilitation payments, secret commissions, influence-peddling, concealed benefits and every other arrangement intended to secure or reward improper performance.
2.2 No objective, relationship, urgency, local custom, instruction, competitive pressure, revenue opportunity, political consideration or perceived strategic importance authorises departure from this Policy.
6. Zero-Tolerance Standard
6.1 Zero tolerance means TrustCome will not authorise, ignore, conceal or rationalise bribery or corruption. It does not remove the need for fair investigation, evidence-based findings, proportional response and respect for lawful rights.
6.2 A transaction or relationship may be declined, suspended or terminated where risk cannot be reduced to an acceptable and documented level, even where misconduct is not proven.
8. Speak Before Acting
8.1 A person who is uncertain shall pause the affected action where reasonably possible, protect relevant information and seek advice from TrustCome Legal & Governance or another designated authority.
8.2 No person shall be disadvantaged for delaying a transaction in good faith to obtain required review.
9. Offering or Giving a Bribe
9.1 No person shall offer, promise, authorise, give or arrange any financial or other advantage intending to induce, reward or conceal improper performance.
9.2 The prohibition applies whether the advantage is received by the decision-maker, another person, an organisation, a political body, a charity, a family member or any nominated beneficiary.
10. Requesting or Receiving a Bribe
10.1 No person shall request, agree to receive, accept or retain an advantage where it is intended, expected or reasonably capable of appearing to influence institutional judgement or reward improper performance.
10.2 A benefit may be improper even where no explicit request is made and no decision has yet occurred.
11. Facilitation Payments
11.1 Facilitation payments are prohibited. No person shall make a small or unofficial payment to secure, accelerate or avoid a routine governmental or administrative action.
11.2 A payment made under an immediate and credible threat to life, liberty or physical safety shall be reported as soon as safely possible, recorded accurately and reviewed independently.
12. Kickbacks, Secret Commissions and Referral Arrangements
12.1 Kickbacks, rebates, commissions, referral fees and success payments are prohibited where concealed, disproportionate, unsupported by legitimate service or intended to influence an award, approval or decision.
12.2 All remuneration arrangements shall identify the genuine service, contracting party, beneficial recipient, calculation method, approval and payment route.
14. Improper Influence
14.1 Improper influence includes use of personal, political, familial, financial, social, institutional or reputational leverage to obtain a decision that should be made independently and on proper criteria.
14.2 Legitimate advocacy, negotiation and relationship management are permitted when transparent, lawful, authorised and free from concealed benefit or coercion.
17. Circumvention and Deliberate Ignorance
17.1 No person shall structure a transaction, divide payments, use aliases, route funds through unrelated entities or deliberately avoid inquiry in order to evade a control.
17.2 Warning signs shall be investigated. Deliberate ignorance, unreasonable reliance and conscious avoidance may constitute misconduct.
18. The Integrity Decision Rule
18.1 Before approving a material benefit, payment, intermediary or sensitive engagement, the decision-maker shall be satisfied that the purpose is legitimate, the recipient is proper, the value is proportionate, the route is transparent, the authority is documented and the record could withstand independent scrutiny.
18.2 Where any element cannot be established, the matter shall not proceed without additional review and written approval from a competent authority.
19. Heightened Public-Sector Standard
19.1 Engagement involving public officials, candidates, political parties, state-owned or state-controlled entities, sovereign bodies, regulators, courts, public procurement, licensing or public funds requires heightened care.
19.2 The absence of a requested favour does not remove risk where timing, value, recipient, relationship or surrounding circumstances could create an appearance of influence.
28. Third-Party Principle
28.1 TrustCome shall not engage or retain a third party to perform conduct that TrustCome could not perform lawfully and ethically itself.
28.2 Responsibility for third-party risk begins before appointment and continues through payment, monitoring, renewal and termination.
29. Risk Assessment and Due Diligence
29.1 Due diligence shall be proportionate to the third party’s role, location, ownership, public-sector contact, compensation, access, subcontracting, reputation and ability to influence decisions.
29.2 Appointment shall not proceed until material ownership, competence, integrity, sanctions, conflicts and corruption-risk questions are resolved or formally accepted by authorised governance.
32. Contracting Requirements
32.1 Contracts shall describe the legitimate service, territory, deliverables, compensation, payment route, records, audit rights, compliance obligations, reporting duties, subcontracting limits and termination rights.
32.2 Side letters, oral modifications and undisclosed understandings affecting compensation, beneficiary, scope or influence are prohibited.
34. Payment Controls
34.1 Payments shall be made to the contracted party in the jurisdiction and account reasonably connected to the service, supported by accurate invoices and required approvals.
34.2 Cash, bearer instruments, crypto-assets, unrelated accounts, personal accounts, split payments and advance payments require prohibition or exceptional documented review according to risk.
49. Advice Before Action
49.1 Persons are expected to seek advice before acting where a proposed benefit, payment, intermediary, public-sector contact or transaction presents material uncertainty.
49.2 Advice shall be sought early enough to permit genuine review and shall include complete facts rather than a preferred conclusion.
50. Duty to Report
50.1 Known or suspected bribery, corruption, improper influence, concealment, retaliation or material control failure shall be reported promptly through an authorised channel.
50.2 A person is not required to prove misconduct before reporting. Good-faith information and reasonable concern are sufficient.
52. Non-Retaliation
52.1 Retaliation, intimidation, threat, career disadvantage, exclusion, loss of opportunity, reputational attack or adverse treatment for protected activity is prohibited.
52.2 Protection applies to good-faith questions, refusal to participate, reporting, evidence preservation, witness cooperation and support of another reporting person.
69. Breach and Consequences
69.1 A breach may result in corrective, disciplinary, contractual, financial, civil, regulatory or criminal consequences according to law, evidence, seriousness and authority.
69.2 Failure to supervise, disclose, preserve evidence, complete diligence, use required approvals or act upon warning signs may itself constitute a breach.