Governance

Code of Conduct Rules & Procedures

1. Purpose

The purpose of this procedure is to establish guidelines and protocols for preventing bribery, ensuring compliance with trade regulations, and managing gifts and entertainment within TMX Consulting Ltd.  Adherence to this procedure is essential to maintain ethical standards, legal compliance, and preserve the reputation of the company.

2.  Scope

This procedure applies to all employees and Business Partners associated with our supply chain consulting company. Business Partner means any person who provides services to TMX

3. Sanctions and Trade Control Compliance:

  • TMX is committed to conducting its business transparently and in accordance with applicable Sanctions and Trade Controls-related laws, rules, and regulations to avoid violating laws and damaging our reputation.
  • Sanctions limit trade or the provision of money, goods, or services to certain countries, organizations, companies, and people. Sanctionscan also restrict the trade in goods and the provision of money, goods, or services to Sanctioned Persons and Sanctioned Countries
  • TMX Consulting complies with all applicable international trade laws and regulations, including but not limited to export controls, sanctions, and anti-money laundering laws.
  • Employees involved in international transactions must ensure compliance with export control regulations and obtain any necessary licenses or permits before exporting goods or services.
  • The company conducts due diligence on suppliers, partners, customers, and competition to ensure they comply with trade regulations.
  • Any Employee who becomes or became aware of breach of this Policy or any other event or circumstance that gives rise to an actual or suspected breach to any Sanctions or Trade Controls-related laws by any of TMX’s Employees or Business Partners, is obliged to escalate the issue.

TMX’s top management will provide comprehensive support to any of its Employees who report any issues.

4. Gifts and Entertainment:

  • TMX values its reputation for conducting business in an ethical and transparent manner. TMX has designed the Gifts and Entertainment policy to ensure compliance with our ethical values and to. 1. Comply with international Bribery and Corruption legislation and 2. Help employees, vendors and business partners take the right decisions when providing or accepting Gifts and Entertainment while conducting business on behalf of TMX.
  • Any breach of this policy will be treated seriously by TMX and is likely to result in disciplinary action, which may even include the termination of employment of employees and the immediate termination of any vendor or business partner arrangements.
  • Employees must exercise caution when giving or receiving gifts, entertainment, or hospitality to or from clients, suppliers, or any other business associates.
  • Gifts and entertainment should be of modest value, appropriate, and given or received transparently.
  • Any gifts or entertainment received by employees must be reported to their immediate supervisor or the compliance officer.
  • Employees must avoid situations where gifts or entertainment could be perceived as influencing business decisions or creating conflicts of interest.

5. Anti-Bribery Policy:

  • The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that TMX’s business is conducted in a socially responsible manner.
  • Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
  • It is our policy to conduct all of our business in an honest and ethical We take a zero- tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.
  • We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we
  • TMX strictly prohibits offering, soliciting, or accepting bribes, kickbacks, political or charitable contributions or any form of corrupt payments.
  • Employees must not engage in any activity that may constitute bribery, including but not limited to offering gifts, favors, or entertainment with the intention to influence business decisions.
  • This policy applies to any individual or organisation employees come into contact with during the course of working for TMX, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
  • Employees must report any suspected instances of bribery promptly to the compliance officer or designated authority.

6. Procedure

  • Training: All employees will receive training on anti-bribery laws, trade compliance regulations, and the company’s gifts and entertainment policy upon joining the company and periodically thereafter.
  • Reporting: Employees must report any violations or suspected violations of this procedure to the compliance officer or through the company’s anonymous reporting mechanism.
  • Investigation: Upon receiving a report of a potential violation, the compliance officer will investigate the matter promptly and take appropriate disciplinary action if necessary.
  • Record-keeping: The company will maintain records of training sessions, reported incidents, investigations, and actions taken to ensure compliance with this procedure.

7. Enforcement

Violations of this procedure may result in disciplinary action, including termination of employment or termination of contracts with suppliers or vendors found to be in breach. Additionally, individuals found to have engaged in bribery or other illegal activities may be subject to legal action.

8. Review

This procedure will be reviewed periodically to ensure its effectiveness and compliance with changing laws and regulations. Amendments or updates will be made as necessary.

9. Approval

This procedure is approved by the CEO and becomes effective immediately upon publication.

Contact Information

For questions regarding this Legal Disclaimer, please contact:

TMX Consulting Ltd

Email: info@tmxconsulting.co.uk

Website: http://www.tmxconsulting.co.uk

Registered Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

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Contact Information

Registered in ENGLAND, Number 08809648. VAT Registration Number 182 8371 85.
71-75 Shelton Street, Covent Garden, London, WC2H 9JQ