1. Purpose
1.1 This Policy establishes TrustCome’s institutional framework for controlling gifts, hospitality, travel, accommodation, entertainment and other benefits that are offered, promised, given, received or arranged in connection with TrustCome activity.
1.2 Its purpose is to protect independent judgement, prevent bribery and conflicts of interest, preserve professional boundaries, maintain accurate records and strengthen confidence in TrustCome relationships.
2. Policy Statement
2.1 TrustCome permits reasonable and proportionate courtesy only where it serves a legitimate institutional purpose, is lawful in every relevant jurisdiction, is consistent with the recipient’s rules, is transparently approved and recorded where required, and cannot reasonably be understood as an attempt to influence or reward a decision.
2.2 TrustCome prohibits every benefit that is cash-like, concealed, excessive, personal, coercive, reciprocal, linked to an active decision, routed through another person, or otherwise capable of compromising actual or perceived independence.
6. Institutional Standard
6.1 TrustCome shall judge a benefit by substance rather than label. A “courtesy”, “token”, “sponsorship”, “speaker invitation”, “familiarisation visit”, “cultural gift” or “relationship expense” remains subject to this Policy.
6.2 The fact that a benefit is common in a market, permitted by an expense budget or offered to others does not establish that it is proper.
7. Presumption of Caution
7.1 Where uncertainty is material, the benefit shall be declined, deferred, returned, surrendered or held pending written advice.
7.2 No person shall be criticised for refusing or delaying a benefit in good faith to protect TrustCome or the other party.
8. No Commercial Exception
8.1 Revenue opportunity, strategic importance, competitive pressure, personal relationship, urgency or senior instruction shall not authorise departure from this Policy.
8.2 TrustCome would rather lose an opportunity than secure it through obligation, concealed influence or compromised judgement.
10. Legitimate Institutional Purpose
10.1 A legitimate institutional purpose is a specific, proportionate and documented purpose connected to genuine business, professional, diplomatic, educational, ceremonial or stakeholder activity.
10.2 General relationship-building is not by itself sufficient where value, timing, frequency or sensitivity is elevated.
11. Independence and Appearance
11.1 Benefits shall not compromise actual judgement or create a reasonable appearance that judgement, access, information, advocacy or institutional treatment may be influenced.
11.2 The appearance test shall be applied from the perspective of an informed, impartial observer who knows the relevant facts.
12. Cash and Cash Equivalents
12.1 Cash and cash equivalents are prohibited. This includes currency, digital value readily convertible to cash, gift cards, vouchers, prepaid cards, loans, securities, cryptocurrency, personal debt relief and negotiable instruments.
12.2 A narrowly defined reimbursement of verified institutional expense is not a cash equivalent where it is lawful, contractually authorised, paid through an approved route and accurately recorded.
13. Solicitation
13.1 No person shall request, hint at, pressure for or create an expectation of a gift, invitation, upgrade, discount, travel arrangement or personal benefit.
13.2 TrustCome shall not condition access, favourable treatment or continued relationship upon a benefit.
14. Concealment and Indirect Benefits
14.1 A benefit shall not be concealed through a family member, friend, nominee, charity, private office, adviser, third party, personal account, false invoice, split expense or misleading description.
14.2 The true provider, recipient, beneficiary, purpose and value shall be identifiable.
15. Quid Pro Quo and Reciprocity
15.1 A benefit shall not be offered or accepted in exchange for a decision, introduction, confidential information, recommendation, access, waiver, acceleration, silence or other institutional act.
15.2 An expectation of future reciprocity may be improper even where no express agreement exists.
16. Personal and Family Benefits
16.1 Benefits for a spouse, partner, family member, friend, guest, private office or connected person are treated as benefits to the relevant TrustCome person or counterparty.
16.2 Companion attendance, family travel and personal extensions are prohibited unless wholly personal, separately contracted, personally funded, independently arranged and incapable of creating institutional obligation.
17. Timing
17.1 Heightened caution applies during tenders, appointments, licensing, regulatory review, disputes, investigations, audits, funding decisions, negotiations, recruitment, renewals, selection exercises and other active decisions.
17.2 A benefit connected in time or context to a sensitive decision shall normally be declined regardless of value.
18. Frequency and Aggregation
18.1 Repeated low-value benefits may create cumulative influence and shall be assessed in aggregate by provider, recipient, relationship and rolling twelve-month period.
18.2 Deliberate division of a benefit or event to remain below a threshold is prohibited.
19. General Rule for Gifts
19.1 Gifts shall be exceptional rather than routine. They may be given or accepted only where modest, appropriate to the occasion, culturally respectful, lawful and unrelated to a pending decision.
19.2 A gift that cannot be comfortably disclosed to TrustCome Legal & Governance and the recipient’s institution shall not be offered or accepted.
31. General Rule for Hospitality
31.1 Hospitality shall be modest, purposeful, proportionate to the relationship and attended by appropriate representatives of the host and guest organisations.
31.2 Hospitality that is predominantly recreational, luxurious, personal or unrelated to genuine institutional engagement shall be declined or personally funded where appropriate and lawful.
41. General Travel Rule
41.1 TrustCome should ordinarily pay the necessary travel and accommodation costs of its personnel. External funding is exceptional and requires written pre-approval.
41.2 Travel shall have a defined institutional purpose, reasonable itinerary, proportionate standard, transparent payer and no personal extension or hidden beneficiary.
51. Public Officials
51.1 Any gift, hospitality, travel or benefit involving a public official, public body, state-owned or state-controlled entity, political person, royal or protocol office, regulator or public international organisation requires heightened caution.
51.2 Prior written approval is required regardless of value, except ordinary low-value refreshments made generally available during a legitimate working meeting where local rules permit and no sensitive decision is active.
61. Approval Before Commitment
61.1 Approval shall be obtained before TrustCome is committed, an invitation is accepted, travel is booked, a gift is purchased or a benefit is communicated as agreed.
61.2 Retrospective approval is exceptional and does not regularise a prohibited benefit.
71. Third-Party Compliance
71.1 Agents, consultants, event organisers, travel providers, introducers, sponsors and other third parties shall not provide a benefit that TrustCome could not provide directly.
71.2 Contracts shall require compliance, accurate records, disclosure of beneficiaries and cooperation with review where risk is material.
81. Advice Before Action
81.1 Questions shall be referred to TrustCome Legal & Governance before action where value, law, recipient rule, public-sector status, timing, purpose or appearance is uncertain.
81.2 Advice shall be based on complete and accurate facts. Material changes require renewed review.
82. Duty to Report
82.1 A person shall report a suspected prohibited benefit, inaccurate register entry, concealed hospitality, improper request, retaliation or circumvention promptly through an authorised route.
82.2 A person who receives an unexpected benefit shall report it before use or disposal where reasonably possible.
95. Breach and Consequence
95.1 Breach may result in refusal, repayment, disciplinary action, removal of authority, contract action, termination, recovery, disclosure or referral as permitted by law.
95.2 Seniority, commercial performance or relationship importance shall not prevent proportionate accountability.