The Trade & Customs Standards Association (TCSA) is committed to conducting all activities with honesty, integrity, transparency and accountability. We maintain a zero-tolerance approach to bribery, corruption and unethical business practices in any form.

1. Policy Statement

The Trade & Customs Standards Association (TCSA) is committed to conducting all activities with honesty, integrity, transparency and accountability. We maintain a zero-tolerance approach to bribery, corruption and unethical business practices in any form.

As a standards-led professional association, TCSA recognises that trust is fundamental to effective governance, professional recognition, commercial engagement and industry confidence. We therefore expect the highest standards of ethical conduct from all individuals and organisations acting on behalf of, associated with, or engaging with TCSA.

TCSA is committed to complying with all applicable anti-bribery and anti-corruption legislation, including the UK Bribery Act 2010 and any equivalent legislation applicable in jurisdictions in which activities are undertaken.

We will implement and maintain proportionate procedures designed to prevent bribery, corruption, conflicts of interest and improper influence within our operations, procurement activities, membership processes, verification programmes and commercial relationships.

Any form of bribery or corruption is incompatible with TCSA's values and will not be tolerated under any circumstances.

2. Purpose

The purpose of this policy is to:

  • Promote a culture of integrity and ethical conduct.
  • Prevent bribery and corruption throughout TCSA's activities.
  • Protect the reputation and credibility of TCSA.
  • Ensure compliance with applicable legal and regulatory obligations.
  • Provide guidance to employees, contractors, consultants, members and stakeholders regarding acceptable conduct.
  • Establish procedures for identifying, reporting and managing bribery risks.

3. Scope

This policy applies to:

  • All directors, officers and representatives of TCSA.
  • Employees and temporary workers.
  • Consultants, contractors and advisers.
  • Agents and intermediaries acting on behalf of TCSA.
  • Volunteers and committee members.
  • Suppliers and service providers engaged by TCSA.
  • Member organisations when participating in TCSA activities, programmes, procurement exercises, verification processes or commercial engagements.
  • Any third party acting for or representing TCSA in any capacity.

Compliance with this policy is a condition of engagement with TCSA.

4. What Constitutes Bribery?

Bribery occurs when a financial or other advantage is offered, promised, given, requested or accepted with the intention of inducing or rewarding improper performance of a function or activity.

A bribe may take many forms, including but not limited to:

  • Cash payments.
  • Gifts or hospitality.
  • Travel or accommodation.
  • Discounts or preferential treatment.
  • Employment opportunities.
  • Commissions or referral fees.
  • Political or charitable contributions used improperly.
  • Personal favours.
  • Sponsorship arrangements intended to influence decisions.

Bribery can occur within both public and private sectors and may involve direct or indirect arrangements through third parties.

The appearance of improper influence can be as damaging as actual misconduct and should therefore be avoided.

5. Prohibited Conduct

The following activities are strictly prohibited:

No individual acting on behalf of TCSA may offer, promise or provide any financial or other advantage intended to influence a decision, secure a commercial benefit or obtain an improper advantage.

No individual may request, agree to receive or accept any financial or other advantage that could influence, or appear to influence, their professional judgement or decision-making.

TCSA prohibits facilitation payments of any kind. Facilitation payments are unofficial payments made to secure or expedite routine government or administrative actions and remain prohibited regardless of local custom or practice.

No person may seek to influence — through gifts, incentives, payments or other advantages — any of the following:

Bribery carried out through agents, consultants, intermediaries, partners, suppliers or other third parties is prohibited to the same extent as direct bribery. Individuals cannot avoid responsibility by acting through another party.

6. Gifts, Hospitality and Business Courtesies

TCSA recognises that reasonable and proportionate hospitality can form part of legitimate business relationships. However, gifts, hospitality and entertainment must:

  • Be lawful.
  • Be proportionate and reasonable.
  • Be transparent and openly declared where appropriate.
  • Have a legitimate business purpose.
  • Not influence, or appear to influence, decision-making.
  • Not create a conflict of interest.

The following are generally unacceptable:

  • Cash gifts.
  • Gift cards or cash equivalents.
  • Luxury hospitality.
  • Excessive entertainment.
  • Personal benefits unrelated to legitimate business activity.
  • Gifts or hospitality offered during procurement, verification or assessment processes.

Where there is any doubt regarding the appropriateness of a gift or hospitality arrangement, guidance should be sought before acceptance.

7. Conflicts of Interest

Individuals associated with TCSA must avoid situations where personal interests could conflict, or appear to conflict, with the interests of TCSA. Potential conflicts must be disclosed promptly and managed appropriately.

Examples include:

  • Financial interests in suppliers or member organisations.
  • Family relationships with applicants or contractors.
  • Personal relationships affecting professional judgement.
  • External appointments that could influence decision-making.

Failure to disclose a material conflict of interest may constitute a breach of this policy.

8. Procurement and Third-Party Due Diligence

TCSA is committed to conducting procurement and supplier engagement activities fairly, transparently and objectively. Appropriate due diligence may be undertaken before entering into relationships with suppliers, consultants, contractors, commercial partners, agents, verification partners and service providers.

The level of due diligence undertaken will be proportionate to the nature and risk profile of the relationship.

Where appropriate, contractual arrangements may include provisions relating to:

  • Anti-bribery compliance.
  • Ethical conduct.
  • Audit rights.
  • Termination for misconduct.

9. Record Keeping and Financial Controls

TCSA will maintain accurate, complete and transparent records of:

  • Financial transactions.
  • Procurement activities.
  • Expenses.
  • Hospitality declarations.
  • Sponsorship arrangements.
  • Donations and contributions.
  • Commercial agreements.

False, misleading or incomplete records are strictly prohibited. Financial controls and approval procedures shall be maintained to reduce the risk of fraud, bribery and corruption.

10. Reporting Concerns

All individuals associated with TCSA have a responsibility to report concerns regarding suspected bribery, corruption, fraud or unethical conduct. Reports may relate to:

  • Actual misconduct.
  • Suspected misconduct.
  • Attempted bribery.
  • Requests for improper payments.
  • Concerns regarding third parties.
  • Weaknesses in existing controls.

Reports should be made as soon as reasonably practicable. TCSA will treat reports seriously, investigate concerns appropriately and take proportionate action where necessary.

11. Protection for Whistleblowers

TCSA will not tolerate retaliation against any person who raises a concern honestly and in good faith.

Individuals who report concerns shall not suffer:

  • Dismissal.
  • Discrimination.
  • Harassment.
  • Victimisation.
  • Detrimental treatment.

This protection applies regardless of whether subsequent investigations establish wrongdoing. Malicious or knowingly false allegations may however result in appropriate action.

12. Training and Awareness

TCSA is committed to maintaining awareness of ethical and compliance obligations throughout the organisation. Where appropriate, training, guidance and policy updates may be provided to ensure individuals understand:

  • Their responsibilities under this policy.
  • Applicable legislation.
  • Reporting procedures.
  • Ethical decision-making expectations.

13. Breaches of this Policy

Any breach of this policy will be treated seriously. Depending upon the circumstances, consequences may include:

  • Disciplinary action.
  • Removal from office or committee positions.
  • Suspension of membership privileges.
  • Termination of contracts or engagements.
  • Exclusion from procurement opportunities.
  • Reporting to regulatory or law enforcement authorities.

Where criminal conduct is suspected, TCSA reserves the right to cooperate fully with relevant authorities and enforcement agencies.

14. Monitoring and Review

TCSA will periodically review this policy and associated procedures to ensure continued effectiveness, legal compliance and alignment with recognised good practice. Reviews may consider:

  • Legislative developments.
  • Regulatory guidance.
  • Organisational changes.
  • Emerging risks.
  • Lessons learned from incidents or investigations.

The most current version of this policy supersedes all previous editions.

15. Commitment from TCSA Leadership

TCSA's leadership is fully committed to fostering a culture in which ethical conduct, professional integrity and responsible governance are embedded throughout all aspects of the organisation.

The reputation of TCSA depends upon the conduct of those who represent it. Every individual associated with the Association shares responsibility for protecting that reputation by acting honestly, transparently and in accordance with both the letter and spirit of this policy.