Anti-Bribery and Sanctions Compliance Policy


TRO Distribution Ltd (“the Company”) is committed to operating a corruption-free regime and conducting its business and any dealings with third parties professionally, with integrity and in compliance with all legal obligations.

The Company will not tolerate any form of bribery, corruption or related malpractice and expects its employees and any third parties acting on its behalf to adopt a similar approach. Third parties would include any individual or organisation which is engaged by the Company, or acts on behalf of an individual or organisation which is engaged by the Company and would cover freelancers, agents, talent, sub-contractors and fixers (each a “Third Party”).

This Anti-Bribery Policy explains what is required of any person or Third Party employed or engaged by the Company, and what action must be taken by such person or Third Party should it encounter or suspect corruption or bribery of any kind whilst working for or with the Company. The policy also affirms our commitment to full compliance with all sanctions policies operating within the domain of the established international legal framework, in particular TRO Distribution Ltd is not permitted to enter into a transaction if it would breach a sanction imposed by any of the following:

  • The UK Government
  • The US Government
  • The European Union
  • The United Nations



A bribe is an inducement offered or given in return for an improper advantage (commercial or personal gain). The Bribery Act 2010 sets our four specific criminal offences which constitute “bribery” which include: (i) to offer or give a bribe; (ii) to request, agree to receive or accept a bribe; (iii) to bribe a foreign public official; and, (iv) failure by a company to prevent bribery by an associated person acting for that company’s benefit.
The offence outlined at number (iv) above refers to “associated persons” of an organisation. This is intended to cover the entire range of persons that may perform services for or on behalf of an organisation. The Company expects all of its employees and Third Parties to comply with this policy and the law at all times.

Facilitation Payments

In the event that an employee of, or Third Party acting on behalf of the Company, is engaged as a fixer abroad on a television location shoot, it is illegal for that person to give to a foreign public official any payment to facilitate the shoot, as this will constitute a bribe.
All employees and Third Parties away on location out of the UK should be aware that they could be contravening English law if they offer a facilitation payment (possibly incurring individual liability as well as Company liability). The Company expects all employees and Third Parties who may find themselves abroad on shoots to seek local advice on disguised requests for such facilitation payments; question and confirm the authority of those demanding any payments, and to always require receipts for any payments made.

Hospitality and Gifts

Care must always be taken to ensure that any gift/hospitality that is given or received by/from the Company or Third Parties is reasonable and appropriate given the particular set of circumstances.
The Company expects that employees and Third Parties will, at all times, consider whether the giver of the gift/hospitality is hoping to persuade, induce or oblige the recipient to act improperly (as opposed to contributing to a legitimate business relationship) it could be deemed as bribery.

Code of Conduct

When working for, with or on behalf of The Company it is never acceptable for employees or Third Parties (or someone on behalf of the Third Party) to:

  • Offer or give a payment, gift or hospitality with the intention that a business advantage will be received solely because of the inducement (rather than because of a bona fide commercial reason for providing the advantage, such as a lower price, better service etc), or to reward a business advantage already given; AND/OR
  • Offer or give a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure both at home or abroad; AND/OR
  • Receive/accept a payment, gift or hospitality from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for that party; AND/OR
  • Receive/accept a payment, gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by The Company in return; AND/OR
  • Engage in any activity whatsoever that might lead to a breach of this policy or in contravention of English law against bribery.

The Company will regularly review this policy, assessing the efficacy of both the terms and implementation of its code of conduct.

If you have any questions about this policy or the code of conduct outlined above, or, suspect that any bribery may have taken place, please contact us at without delay.

Reviewed and Updated September 2023