1. Purpose
TRST Advisory Ltd (“TRST”) is committed to conducting all business honestly, fairly, and transparently.
This policy sets out TRST’s standards and expectations to prevent bribery and corruption in line with the UK Bribery Act 2010. It applies to all employees, directors, contractors, temporary staff, and any third-party acting on TRST’s behalf, including introducers, advisers, and consultants.
2. Scope
This policy covers all TRST activities, including real estate finance and investment consultancy, project advisory work, client engagement, and interactions with suppliers, professional partners, and public officials. It applies to conduct in the UK and overseas.
3. TRST’s Commitment
TRST prohibits:
- Offering, promising, giving, requesting, agreeing to receive, or accepting any bribe.
- Authorising or permitting any third-party to engage in such conduct on TRST’s behalf.
- Facilitation payments of any kind, regardless of local custom.
- Any act that could be perceived as improper influence in securing business or a commercial advantage.
All business decisions must be made on objective criteria such as competence, service quality, and value.
4. Gifts, Hospitality, and Entertainment
Reasonable and proportionate hospitality may be acceptable when directly connected to legitimate business relationships. However:
- No gift or hospitality may be offered or accepted if it could influence, or appear to influence, business judgement.
- Cash or cash-equivalent gifts are strictly prohibited.
- Any gift or hospitality offered or received that is more than nominal in value, unusual in nature, or could give rise to a conflict of interest must be declared promptly to line management and approval sought before acceptance where possible.
5. Third-Parties and Intermediaries
TRST may be legally responsible for the actions of third-parties acting on its behalf. Therefore:
- Introducers, agents, consultants, and service providers must be engaged only after proportionate due diligence to assess integrity and business conduct.
- Contracts should include appropriate anti-bribery and corruption provisions where relevant.
- Any concerns about the conduct of a third-party must be reported immediately.
6. Conflicts of Interest
All staff and representatives must avoid situations where personal interests could conflict with TRST’s interests or influence decision-making.
Any potential conflict must be disclosed to senior management as soon as identified so that appropriate steps can be taken to manage or remove the conflict.
7. Record-Keeping and Transparency
Accurate and complete records must be kept for all business transactions, expenses, third-party payments, and consultancy arrangements. No unrecorded or unexplained accounts, payments, or funds may be created.
Expenses must reflect genuine business activities and comply with TRST’s expense rules.
8. Raising Concerns
Anyone working for or with TRST is encouraged to report concerns about potential bribery or corruption. Concerns may be raised confidentially by emailing enquiries@trst-advisory.com.
TRST does not tolerate retaliation against anyone who raises a concern in good faith.
9. Responsibilities
All staff and representatives must read, understand, and comply with this policy.
Managers are responsible for promoting awareness and ensuring their teams understand how the policy applies to their work.
Third-parties acting for or representing TRST are expected to comply with this policy as a contractual condition where appropriate.
10. Breaches of this Policy
Any breach of this policy may result in disciplinary action, termination of contract, reporting to relevant authorities, and potential civil or criminal liability.
TRST will investigate all suspected breaches promptly and fairly.
11. Review of the Policy
This policy will be reviewed periodically and updated as required to ensure continuing compliance with the UK Bribery Act 2010 and best practice for UK professional services firms.
All Rights Reserved – TRST Advisory Ltd
Nov 2025