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Anti-Bribery and Business Conduct

This page exists because corporate procurement questionnaires ask for it, and because the honest answer is short.

What we do not do

  • We do not pay bribes or facilitation payments to obtain business, expedite customs, or influence an inspection outcome.
  • We do not accept commissions, rebates or kickbacks from suppliers. Our income is the fee you agree with us. If a supplier offered us a share of the order value, accepting it would put us on the wrong side of the table.
  • We do not mark up the goods. We never take ownership, so there is no invoice of ours for a hidden margin to live inside.

The commercial structure is what makes the policy credible. An agent whose real income is a supplier rebate has a reason to recommend the wrong factory, whatever its code of conduct says.

Gifts and hospitality

Modest business hospitality is normal in Chinese commercial life and we participate in it. What we do not do is accept anything of a value that could reasonably influence a recommendation, and we do not offer anything of that kind to your staff. If a supplier attempts it, we tell you.

Conflicts of interest

We disclose any ownership interest or family relationship in a supplier we recommend. If two of our clients compete directly in the same category, we tell both, and we keep specifications and supplier lists strictly separate — one client's work is never used to serve another.

Reporting a concern

If you believe someone acting for us has solicited or accepted an improper payment, raise it with us directly. We would rather hear it from you than not hear it. Reports are investigated and the outcome is communicated to whoever raised it.

Questions

Ask before you commit

If anything here is unclear, or you need it in a different form for a procurement review, ask.

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