Anti-bribery Policy 2023

The Company has a zero-tolerance position in relation to corruption, wherever and in whatever form that may be encountered. Under UK law the payment, or offer to pay bribes, or provision of or offer to provide gifts or anything of value for improper purposes to obtain or retain business or any other benefit, (whether for Texecom or any other party) is prohibited. Such payments or gifts are also forbidden under the terms of this policy and may result in immediate dismissal for those involved in their payment or receipt.

This policy applies to individual employees, agents, sponsors, intermediaries, consultants or any other people or bodies associated with the Company or any of its subsidiaries and employees. Bribery is committed when an inducement or reward is provided in order to gain any commercial, contractual, regulatory or personal advantage for the Company or another party. No bribes of any sort may be paid to or accepted from customers, suppliers, politicians, government advisors or representatives, private person or company. It is not permitted to establish accounts or internal budgets for the purpose of facilitating bribes or influencing transactions (slush funds).

This policy does not prohibit the following practices providing they are customary in a particular market, or are proportionate and are properly recorded:

  • Normal and appropriate hospitality (given or received)
  • The giving of a ceremonial gift on a festival or at another special time

The Company recognises that market practice varies across the international arena in which it does business, and what is normal and acceptable in one place may not be in another. The Company also appreciates that to refuse a gift in certain circumstances and/or countries would cause offence to our trading partners. The test to be applied in all circumstances is whether the gift or entertainment is reasonable and justifiable. What is the intention of the gift? Special care must be taken in accepting or giving gifts/entertainment, and these are not permitted if it would create a real or perceived conflict of interest.

The prevention, detection and reporting of bribery and corruption is the responsibility of all employees throughout the Company. Suitable channels of communication by which employees or others can report confidentially any suspicion of bribery will be maintained, and employees should contact the Managing Director directly to raise a concern.

A summary can be found below:

  1. Gifts should never be cash or cash equivalents.
  2. Gifts should be small tokens, ideally incorporating some form of marketing message, and should not normally exceed GBP 100 or local currency equivalent in value.
  3. Entertaining and hospitality should not normally exceed GBP 250 or local currency equivalent per head and the events should not normally last more than a day.
  4. No-one should receive frequent or multiple gifts or hospitality as a way of exceeding limits.

Any requirement to pay or accept travel or accommodation expenses must have prior approval from the Managing Director.
Exceeding the above limits for gifts and hospitality, whether giving or receiving, needs the prior approval of your Managing Director. Your Managing Director will also be required to sign any expenses claim you make which includes such substantial spend before the claim is settled.

You should account for the cost of all gifts and entertainment you provide using your company’s standard expenses reporting and approval process. You need to make certain the spend is properly analysed and include adequate detail, explanation and justification of the claim.

Our Anti-Bribery Policy can be downloaded HERE

If you require any further information about our Anti-Bribery Policy, please email