1. Purpose
This policy sets out the Group's anti-bribery, gifts and hospitality controls for Turks and Caicos Islands operations, with particular focus on licensing, suppliers, contractors, customs, property and interactions with public officials.
The purpose is to prevent bribery, corruption, improper influence, facilitation payments, kickbacks, disguised commissions, conflicts of interest and misuse of gifts or hospitality in any TCI-related activity.
This policy is deliberately strict. A payment, gift, favour or hospitality arrangement may be prohibited even if local custom, commercial pressure or a third party suggests it is normal.
2. Scope
This policy applies to Murzo Group Ltd and all subsidiaries, controlled entities, divisions, brands, branches, projects, premises, assets and operations conducting business in or from the Turks and Caicos Islands.
It applies to directors, officers, employees, temporary personnel, contractors, consultants, agents, brokers, customs brokers, property managers, suppliers, distributors, local representatives, introducers, advisers and any other person acting for or on behalf of the Group in connection with TCI activity.
It applies to direct and indirect conduct. A prohibited payment, benefit or promise cannot be made through a relative, company, agent, consultant, contractor, political contact, charitable body, community group, intermediary, platform, broker or other third party.
3. TCI Legal and Integrity Context
TCI has a dedicated Integrity Commission and local integrity framework for public life. The Integrity Commission describes corrupt acts as including direct or indirect benefits offered to or accepted by public officials for doing or omitting to do acts in the performance of public functions, conflicts between private interests and public duties, misuse of confidential information, misuse of public property and interference with official duties to obtain a benefit.
TCI rules around gifts for persons in public life include declaration duties and thresholds. Those thresholds are not approval for the Group to give gifts. The Group must avoid conduct that could place a public official, public officer, minister, regulator, inspector, customs officer, licensing officer or other public-sector person in breach of their own duties.
UK anti-bribery, tax evasion facilitation, sanctions, AML and corporate governance duties may also apply to TCI-linked activity where they have lawful cross-border effect.
4. Zero-Tolerance Position
The Group prohibits bribery, corruption, facilitation payments, kickbacks, improper gifts, improper hospitality, hidden commissions, false invoices, secret rebates, political influence payments, personal favours, employment favours, family benefits and any advantage intended to influence a decision improperly.
No person may offer, promise, give, request, receive, authorise or conceal anything of value to obtain or retain business, speed up an official act, secure a licence, influence a customs decision, win a contract, obtain property advantage, avoid inspection, reduce duty, influence enforcement, obtain confidential information or gain an improper commercial advantage.
5. Public Officials and Public-Sector Interactions
For this policy, public officials include elected officials, ministers, public servants, civil servants, police, customs, immigration, tax, licensing, planning, environmental health, agriculture, port, airport, land, court, regulator, statutory body, government-controlled company and public procurement personnel, as well as candidates, political party officials and people acting for public bodies.
Interactions with public officials must be transparent, lawful, respectful, properly authorised and connected to a legitimate business purpose. Public officials must not be offered gifts, cash, personal discounts, loans, travel, hotel stays, meals, entertainment, employment opportunities, internships, family benefits, political support, donations, sponsorships or other advantages to influence their decision or conduct.
Where modest working hospitality for a public official is genuinely necessary, it must be pre-approved, lawful, proportionate, transparent, infrequent, not during a live decision where it could create pressure, and consistent with the recipient's rules.
6. Licensing, Permits and Inspections
Business licences, renewals, changes in particulars, sector approvals, inspections, clearances, permits, environmental health approvals, immigration matters, work permits, agriculture permissions, tourism permissions, property permissions and other official processes must be handled through lawful channels.
No person may offer or provide anything of value to influence the issue, renewal, amendment, reinstatement, inspection, approval, refusal, delay, suspension, cancellation or enforcement of a TCI licence or permit.
Payments to authorities must be official fees, paid through official routes, supported by official receipts or platform confirmations and never paid personally to an officer unless the official process lawfully requires it.
7. Customs, Border and Import/Export Activity
Customs, border, port, airport, courier, shipping and import/export matters create high bribery risk because they involve declarations, valuation, classification, inspections, concessions, seizures, detention, release and time pressure.
The Group prohibits payments, gifts, commissions, tips, favours or hospitality intended to influence customs treatment, avoid inspection, reduce duty, release goods, change valuation, alter origin, overlook missing permits, misdescribe goods, conceal restricted items, protect cultural objects, release live insects or animals, or bypass lawful controls.
Customs brokers and freight forwarders must have clear written authority and must not make unofficial payments or commitments on behalf of the Group.
8. Suppliers, Contractors and Procurement
Supplier and contractor selection must be based on lawful business criteria such as competence, price, quality, availability, safety, compliance, insurance, reliability, conflict position and value for money.
No supplier, contractor, agent or broker may offer or receive a secret commission, kickback, rebate, personal benefit, inflated invoice, side payment, employment favour, entertainment benefit or family benefit in return for selection, approval, payment, renewal, inspection pass, scope change or favourable treatment.
Procurement must not be split, disguised, misdescribed or routed through a related party to avoid approvals, licensing rules, public procurement rules, AML checks, sanctions checks, conflict review or financial controls.
9. Property, Land, Planning and Real Estate
TCI property activity, including acquisition, leasing, land holding, planning, construction, development, facilities management, property management, valuations, agent instructions, landlord negotiations and government or Crown-related land matters, must be handled with enhanced integrity controls.
No person may offer or accept anything of value to influence land allocation, lease terms, planning consent, inspection, zoning, development approval, valuation, rent, facilities contract, utilities connection, enforcement decision, title issue, beneficial ownership review or property-related public decision.
Introducers, property agents, developers, landlords, contractors and consultants must not use political connections, public-official relationships, hidden commissions or undisclosed side agreements to obtain advantage for the Group.
10. Gifts and Hospitality Principles
Gifts and hospitality may only be offered or accepted where they are lawful, modest, infrequent, transparent, appropriate to the relationship, approved where required, connected to a genuine business purpose and not capable of being understood as a reward, inducement or pressure.
Cash, cash equivalents, vouchers, gift cards, cryptoassets, precious metals, jewellery, personal loans, personal travel, lavish entertainment, adult entertainment, gambling, political tickets, family benefits and secret benefits are prohibited.
A gift or hospitality item must never be offered or accepted during a live tender, licence application, customs issue, inspection, enforcement matter, contract negotiation, property approval, dispute, refund issue, recruitment process or payment dispute where it could influence judgement or appear improper.
11. Gifts and Hospitality to Public Officials
Gifts to public officials are generally prohibited unless a specific authorised exception applies, such as low-value branded material at a public event, protocol items approved in advance, or modest refreshments at an official meeting where refusal would be impractical and the arrangement is lawful and transparent.
Hospitality involving public officials must be pre-approved, proportionate, business-related, not lavish, not frequent, not extended to family members or personal guests, and not connected with obtaining a specific public decision.
The fact that a public official may be permitted to declare or retain a gift under TCI rules does not mean the Group may provide it. The Group's own controls may be stricter than the recipient's rules.
12. Gifts and Hospitality From Suppliers or Contractors
Employees and representatives must not accept gifts, hospitality, discounts, trips, meals, samples, accommodation, favours or entertainment from suppliers, contractors, brokers, agents, landlords or customers where this could influence judgement or create an obligation.
Modest business hospitality may be acceptable where it supports a genuine business relationship and is not connected to a live decision. Anything unusual, valuable, frequent, secret, personal, travel-related or involving family members must be refused or escalated.
13. Facilitation Payments and Expediting Fees
Facilitation payments are prohibited. This includes unofficial payments or benefits to speed up, secure or smooth routine actions such as licence processing, customs release, inspections, utility connections, police assistance, immigration processing, permit collection, tax clearance, port access, courier release or certificate printing.
Official fast-track, priority, courier, filing, inspection or service fees may be paid only where they are lawful, published or formally confirmed, paid to the proper authority or service provider and supported by official evidence.
14. Political Activity, Donations and Sponsorship
The Group remains politically neutral. No TCI political donation, campaign contribution, fundraising ticket, party sponsorship, candidate support, political advertising, election-related service, political hospitality or in-kind benefit may be given without senior approval and legal review.
Charitable donations, community support, disaster relief, sports sponsorship, cultural support or local partnership funding must not be used to influence a public official, obtain a licence, win a contract, gain planning or property advantage, avoid enforcement or disguise a political contribution.
15. Conflicts of Interest
Conflicts of interest must be disclosed before decisions are made. This includes family relationships, friendships, romantic relationships, business interests, political links, landlord interests, contractor interests, public-official relationships, property interests, gifts, hospitality, side work and referral commissions.
A conflicted person must not approve, influence, manage or conceal the relevant decision unless a higher authorised person has assessed and controlled the conflict.
16. Agents, Brokers, Consultants and Introducers
Agents, brokers, customs brokers, property agents, lobbyists, consultants, local representatives, recruiters, marketing contacts, tender advisers and introducers create bribery risk because they may interact with public officials, suppliers, contractors, landlords or customers on the Group's behalf.
Such parties must have a legitimate role, appropriate checks, written authority, transparent remuneration, defined scope, clear limits and contractual anti-bribery obligations. Success fees, commissions and retainers must be proportionate and must not reward unlawful influence.
The Group may refuse, suspend or terminate any third-party relationship where anti-bribery risk cannot be understood or controlled.
17. Discounts, Rebates, Commissions and Side Benefits
Discounts, rebates, credits, commissions, referral fees, marketing allowances, brokerage fees, agency fees and loyalty benefits must be transparent, commercially justified, authorised and correctly recorded in the relevant transaction.
They must not be paid personally to employees, public officials, relatives, secret companies, undisclosed agents or decision makers, and must not be used to hide bribery, tax evasion, customs fraud, inflated pricing or procurement abuse.
18. High-Risk Goods and Services
Enhanced review is required where TCI activity involves high-value goods, cultural objects, antiquities, property, construction, security services, firearms or controlled items, chemicals, food, farming, live insects or animals, cryptoassets, cash-heavy trading, import/export permissions, public tenders or politically connected counterparties.
No gift, hospitality or benefit may be used to overcome a missing licence, weak provenance, unclear source of funds, customs issue, safety concern, environmental issue, food safety issue, biosecurity issue or restricted goods concern.
19. Expenses, Approvals and Evidence
Any approved gift, hospitality, sponsorship, donation, travel, meeting expense, public-official interaction, agent commission, customs broker fee, property introducer fee or unusual third-party benefit must have a genuine business reason and proportionate evidence of approval, purpose, recipient, value and payment route.
False descriptions, generic invoice wording, missing receipts, personal reimbursements, cash claims, split expenses and vague descriptions such as "miscellaneous", "special help", "processing support" or "relationship fee" are not acceptable.
20. Red Flags
Red flags include requests for cash, secrecy, urgent unofficial fees, gifts before decisions, public-official family involvement, political introductions, unusually high commissions, vague consulting roles, success fees tied to official approvals, invoices with false descriptions, pressure to use a particular broker, refusal to disclose beneficial ownership, and claims that payment is the only way to get a licence, release goods or secure property.
Other red flags include free travel requests, family employment requests, requests to donate to a connected charity, requests to pay a relative, unexplained property discounts, unofficial customs charges, gifts from suppliers during tenders, repeated hospitality, lavish entertainment, and statements that "this is how business is done here".
21. Duress and Personal Safety
If a person is threatened with immediate harm, unlawful detention or serious danger unless a payment is made, personal safety comes first. Any payment made under duress must be reported as soon as safely possible and must not be concealed as an ordinary business expense.
Commercial pressure, delay, embarrassment, inconvenience, missed deadline, customs detention, licence delay or fear of losing business is not duress.
22. Reporting and Investigation
Suspected bribery, attempted bribery, improper gifts, facilitation payment requests, conflicts, kickbacks, public-official pressure, customs irregularities, property corruption concerns, agent misconduct or supplier misconduct must be reported promptly through the internal escalation route.
The Group may pause the transaction, suspend authority, restrict access, preserve evidence, seek legal advice, notify banks, notify insurers, report to TCI authorities, terminate third parties, discipline employees, recover funds, or take civil or criminal action where appropriate.
No person may retaliate against someone who raises a genuine concern in good faith.
23. Accountability
Failure to comply with this policy may result in refused reimbursement, withdrawal of authority, access restriction, contract remedies, disciplinary action, termination, regulator notification, law enforcement referral or other lawful action.
A third party remains responsible for its own misconduct, but misconduct by an agent, contractor, broker or representative may still create serious risk for the Group. That is why written authority, due diligence and escalation are required before higher-risk TCI activity proceeds.
24. Relationship With Other Policies
This policy should be read with the TCI Legal and Regulatory Compliance Policy, TCI Business Licensing and Corporate Compliance Procedure, TCI Financial Controls, Fraud and Cash-Handling Policy, TCI Records Retention and Legal Hold Schedule, TCI Employment and Workplace Policy, Anti-Bribery and Corruption Policy, Conflict of Interest Policy, Fraud Prevention and Economic Crime Policy, High-Value Goods, Anti-Money Laundering and Source of Funds Policy, Supplier Approval, Procurement and Due Diligence Policy, Contract Approval, Signing Authority and Delegations Policy, Customs Import/Export Policy, Foreign Agents, Distributors and Local Partners Policy, Real Estate Acquisition, Leasing and Facilities Management Policy, Tax Governance and Compliance Policy, Failure to Prevent Facilitation of Tax Evasion Policy, Whistleblowing and Speak Up Policy, and Insurance and Liability Disclosure Statement.
