Legal
Anti-corruption Policy
How we handle bribery, gifts, customs facilitation and third parties — and what we expect from anyone acting for us.
- Last updated
- 2026-09-04
- Review status
- Internal review
- Questions to
- hello@trivoxagroup.com
Position
Trivoxa Group does not pay bribes, does not accept them, and does not use agents, forwarders or customs house agents to do what we would not do ourselves. This applies to every market we ship into and every market we buy from.
Where a buyer’s own anti-bribery regime applies to the transaction — the UK Bribery Act 2010, the US Foreign Corrupt Practices Act, or an equivalent — we will cooperate with their due diligence and sign their supplier code of conduct.
What is prohibited
The following are prohibited absolutely, in every jurisdiction and whatever the local practice is said to be:
- Payments, gifts or hospitality offered to a public official to obtain or expedite a licence, clearance, inspection result or shipment release — including so-called facilitation or "speed" payments at a port.
- Kickbacks, commissions or undisclosed referral fees to a buyer’s employees or agents.
- False or understated invoicing, split invoicing, mis-declared HS codes, mis-declared values or mis-declared country of origin — a documentation falsification is treated as a corruption offence, not an administrative shortcut.
- Charitable or political donations made as a way of routing a benefit to a decision-maker.
Gifts and hospitality
Modest business hospitality is normal and permitted: a working lunch during a factory visit, product samples, branded items of nominal value. Anything that could influence a decision — cash or cash equivalents, travel unrelated to a factory visit, personal gifts above nominal value, or hospitality for a family member — requires the Managing Director’s written approval before it is offered or accepted.
Every gift or hospitality item offered to or received from a public official is recorded, whatever its value.
Third parties acting for us
Freight forwarders, customs house agents, inspection bodies, sourcing agents and distributors act on our behalf and their conduct is our exposure. They are engaged in writing, with an anti-bribery clause, a right to audit, and payment against a documented service — never in cash, never to a third country unrelated to the service, and never as a percentage of a customs valuation.
We will not appoint an intermediary because they claim to be able to "fix" a clearance. If a third party cannot explain how a problem was solved, we treat it as a red flag and stop.
Documentation integrity
Commercial invoices, packing lists, certificates of origin, inspection reports and declarations must match the goods and the transaction. A document we would not show to a customs authority is a document we do not issue. Where a buyer asks for documentation that misstates value, origin or description, we decline the request and record that we declined it.
Raising a concern
Anyone — employee, supplier, agent, forwarder or buyer — can raise a concern with the Managing Director at hello@trivoxagroup.com, marked confidential. We will acknowledge within two working days and investigate.
There is no retaliation for raising a concern in good faith, including where the concern turns out to be mistaken. Raising a false allegation deliberately is a different matter and is handled as misconduct.
Consequences and review status
Breaching this policy is grounds for termination of employment or of a third-party engagement, and where the conduct is criminal we will report it to the relevant authority.
Last updated 4 September 2026. This policy is under internal review and requires founder sign-off and review by counsel before launch; it is published now because a supplier-code question from a buyer should not have to wait for our paperwork.
Questions about this document go to hello@trivoxagroup.com, marked for the attention of the Managing Director.
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