Bribery Act policy
Anglo-Suisse Capital Limited (the firm) is authorised and regulated by the Financial Conduct Authority. The Bribery Act 2010 makes it an offence to offer, give, request or accept a bribe and to bribe a foreign public official. Section 7 of the Act also makes a company liable if a person associated with it bribes another person to obtain or retain business or an advantage for the company, unless the company had adequate procedures designed to prevent such conduct. This policy forms part of the firm's procedures. Everyone who works for or on behalf of the firm, including consultants, introducers and agents, accepts it on joining and each year thereafter.
ANTI-BRIBERY AND ANTI-CORRUPTION POLICY
Contents
1. What does the policy cover?
2. Policy statement
3. Who is covered by the policy?
4. Definition of bribery
5. What is and what is not acceptable
a. Gifts and hospitality
b. Facilitation payments and kickbacks
c. Political contributions
d. Charitable contributions
6. Responsibilities
7. Raising a concern
a. How to raise a concern
b. What to do if you are offered or asked for a bribe
c. Protection
8. Training and communication
9. Record keeping
10. Monitoring and review
1. What does the policy cover?
1.1. This policy sets out the responsibilities of the firm and of those who work for it in observing and upholding a zero-tolerance position on bribery and corruption.
1.2. It explains how to recognise and deal with bribery and corruption and whom to consult.
2. Policy statement
2.1. The firm conducts its business ethically and honestly and has zero tolerance for bribery and corruption. It acts professionally, fairly and with integrity in all business dealings and relationships wherever it operates.
2.2. The firm complies with the laws against bribery and corruption in every jurisdiction in which it operates. It is bound by the laws of the United Kingdom, including the Bribery Act 2010, for its conduct both in the United Kingdom and abroad.
2.3. An individual convicted of bribery may be imprisoned for up to ten years and fined without limit. A company convicted of bribery or of failing to prevent it may be fined without limit, excluded from public contracts and seriously damaged in its reputation. A company is also liable for a bribery offence committed by one of its senior managers acting within the actual or apparent scope of their authority (Economic Crime and Corporate Transparency Act 2023, section 196).
2.4. The Financial Conduct Authority requires the firm to maintain systems and controls that counter the risk of financial crime, which includes bribery and corruption.
3. Who is covered by the policy?
3.1. This policy applies to the firm's director, employees, consultants, contractors, introducers, agents and any other person who performs services for or on behalf of the firm, whether temporary or permanent and wherever located.
3.2. Third party means any individual or organisation with which the firm deals. It includes actual and potential clients, investors, suppliers, business contacts, introducers, agents, advisers, public officials, politicians and political parties.
3.3. Introducers, consultants and agents are checked before they are engaged, in proportion to the risk they present. They are bound by written terms that require them to comply with this policy and with the law on bribery. Fees paid to or received from introducers are agreed in writing and disclosed to the client in the engagement letter.
4. Definition of bribery
4.1. Bribery is offering, promising, giving, requesting, agreeing to receive or accepting a financial or other advantage intended to induce or reward the improper performance of a function or activity.
4.2. A bribe is any inducement, reward or item of value offered to another person to gain a commercial, contractual, regulatory or personal advantage.
4.3. Accepting a bribe is as much an offence as offering one.
4.4. No one covered by this policy may engage in bribery, whether directly or through a third party such as an agent or introducer. No one may bribe a foreign public official anywhere in the world. Anyone unsure whether something is a bribe, a gift or hospitality asks the Compliance Officer before acting.
5. What is and what is not acceptable
5.1. This section covers gifts and hospitality, facilitation payments and kickbacks, political contributions and charitable contributions.
a. Gifts and hospitality
5.2. The firm accepts normal and proportionate hospitality and gestures of goodwill, given or received, provided that the gift or hospitality:
(a) is not intended to influence the recipient, to obtain or retain business or an advantage or to reward such conduct and is not given in exchange for favours or benefits;
(b) carries no suggestion that a favour is expected in return;
(c) complies with local law;
(d) is given in the name of the firm, not of an individual;
(e) does not include cash or a cash equivalent, such as a voucher or gift card;
(f) is appropriate to the circumstances, such as a small gift at Christmas or a modest thank-you on completion of a transaction;
(g) is of a type and value appropriate to the reason for it and is given at an appropriate time;
(h) is given or received openly, not secretly;
(i) is not directed at a key decision maker with the intention of influencing them; and
(j) is not offered to or accepted from a public official, politician or political party without the prior approval of the Compliance Officer.
5.3. Any gift offered by anyone working for the firm is approved by the director in advance. Any gift or hospitality above £100, whether given, received or declined, is entered in the firm's gifts and hospitality register. Anything received above that value is approved in advance by the Compliance Officer where possible and otherwise reported to the Compliance Officer at once.
5.4. Where declining a gift would cause offence, for example for cultural or religious reasons, it may be accepted provided that it is declared to the Compliance Officer, who decides what is done with it.
5.5. Practice on business gifts differs between countries and cultures. The intention behind any gift or hospitality must always be considered. In case of doubt the Compliance Officer is consulted.
b. Facilitation payments and kickbacks
5.6. The firm does not make or accept facilitation payments of any kind. A facilitation payment is a small payment to a public official to secure or speed up a routine governmental action. It is a bribe under the law of the United Kingdom.
5.7. The firm does not make or accept kickbacks, which are payments made in return for a business favour or advantage.
5.8. If a person faces a demand for payment under threat to their own safety or that of their family, they may pay in order to protect themselves. They must then:
(a) keep the amount to a minimum;
(b) ask for a receipt showing the amount and the reason;
(c) make a note of the payment; and
(d) report it to the Compliance Officer as soon as possible.
c. Political contributions
5.9. The firm makes no donations in cash, in kind or by any other means to political parties or candidates.
d. Charitable contributions
5.10. The firm may donate to charity in money, services, knowledge or time. Every charitable contribution is approved in advance by the Compliance Officer, is lawful where it is made and is recorded. Care is taken that no contribution is used to conceal a bribe.
6. Responsibilities
6.1. Everyone covered by this policy reads, understands and complies with it and with any training or guidance the firm provides on bribery and corruption.
6.2. Everyone is responsible for preventing, detecting and reporting bribery and other corruption. Everyone must avoid any activity that could lead to or suggest a breach of this policy.
6.3. Anyone who knows or suspects that bribery or corruption has occurred or may occur in connection with the firm tells the Compliance Officer at once.
6.4. A breach of this policy by an employee leads to disciplinary action and may amount to gross misconduct justifying dismissal. A breach by a consultant, introducer or agent entitles the firm to end its relationship with them.
7. Raising a concern
a. How to raise a concern
7.1. Concerns should be raised as early as possible. Anyone unsure whether something amounts to bribery or corruption speaks to the Compliance Officer, to the Money Laundering Reporting Officer or to the director.
7.2. Concerns may also be raised under the firm's whistleblowing arrangements, which allow a report to be made directly to the Financial Conduct Authority.
b. What to do if you are offered or asked for a bribe
7.3. Tell the Compliance Officer as soon as possible if you are offered a bribe, are asked to make one or suspect that either may happen. Do the same if you believe you are the victim of any other corrupt activity.
c. Protection
7.4. The firm supports anyone who refuses a bribe or raises a concern in good faith under this policy, even if the concern proves to be mistaken.
7.5. No one suffers detrimental treatment for refusing to take part in bribery or corruption or for reporting a concern about it. Detrimental treatment includes dismissal, disciplinary action, threats and any other unfavourable treatment.
7.6. Anyone who believes they have been treated unfairly for these reasons tells the Compliance Officer or the director at once. They may also report it under the whistleblowing arrangements.
8. Training and communication
8.1. This policy is explained to everyone who joins the firm as part of their induction. Each person confirms in writing on joining and each year thereafter that they accept it.
8.2. Further training on bribery and corruption is given where a person's role makes it appropriate and whenever this policy changes materially.
8.3. The firm's zero-tolerance approach is communicated to introducers, consultants, agents and business partners at the start of the relationship and as appropriate afterwards.
9. Record keeping
9.1. The firm keeps accurate financial records and internal controls that evidence every payment it makes or receives.
9.2. The gifts and hospitality register records the date, the giver and the recipient, the description and value and the reason for each entry. Where nothing is recorded in a year, a nil confirmation is entered at the annual review. The Compliance Officer reviews the register.
9.3. Records kept under this policy are retained for at least six years.
10. Monitoring and review
10.1. The Compliance Officer is responsible for this policy, monitors its effectiveness and reviews it at least once a year as part of the firm's compliance monitoring.
10.2. Improvements are made as soon as practicable. Suggestions for improving the policy are welcome and should be sent to the Compliance Officer.
10.3. This policy does not form part of any contract of employment and the firm may amend it at any time.
This policy was last updated on 18 October 2026.
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