DRAFT FOR LEGAL REVIEW. A policy statement for publication. It must be adopted by the directors and supported by internal procedures proportionate to the company’s risks before it is published.
Axsia Howmar does not offer, give, ask for or accept bribes, in any country, directly or through anyone acting for us. We comply with the UK Bribery Act 2010 and with the anti-corruption laws of the countries where we work. This policy applies to our directors, employees, agents, consultants, fabricators and suppliers.
What we prohibit
- Offering, promising or giving any payment, gift, hospitality or other advantage to influence a business or official decision improperly.
- Asking for or accepting any such advantage.
- Facilitation payments: small unofficial payments to speed up routine official actions.
- Making a payment through an agent, consultant or other third party that we could not properly make ourselves.
- Political donations made on the company’s behalf.
Gifts and hospitality
Modest, occasional and transparent hospitality that has a genuine business purpose is permitted. Anything given or received must be proportionate, recorded, and never offered during a tender or when a decision affecting us is pending. Gifts of cash or cash equivalents are never permitted.
Agents, fabricators and suppliers
We carry out risk-based checks before appointing agents and other intermediaries, pay them only for genuine services at a rate that reflects those services, and require them by contract to comply with this policy. Fabricators in our approved network are expected to apply equivalent standards.
Records
All payments are recorded accurately. No account is kept off the books.
Raising a concern
Anyone who suspects a breach of this policy should report it to a director of the company at enquiries@axsiahowmar.com, marked for the attention of the board. Reports made in good faith will not lead to retaliation. Breaches by staff are a disciplinary matter, and breaches by third parties may lead to termination of their contract.
Approved by the board in September 2026. Reviewed annually.