Policies & Procedures
Bribery and corruption risks are addressed through a number of other Oxon Limited policies and procedures, including our Anti-Money Laundering and Counter-Terrorism Financing Policy, incorporating Client Identification. This document is a summary of Oxon Limited' Anti-Bribery and Corruption Policy and framework. It is not intended to create third party rights or duties or to form part of any contractual agreement between Oxon Limited and any other party.
Procedures
Oxon Limited staff must take reasonable steps to avoid, giving or accepting gifts and entertainment that are intended to, or may, improperly influence them or others. We also maintains a Whistle-blower Policy and framework which promotes the escalation and reporting of matters including bribery and corruption. Staff are encouraged to raise matters through line management or to compliance, and can also approach the Integrity Office or anonymously through an externally-hosted staff hotline.
Due Diligence
In dealing with third parties, the Policy requires sufficient due diligence to be undertaken to ensure that they are suitable to be associated with Oxon Limited, and that appropriate controls are implemented, designed to prevent and detect bribery and corruption. Third parties associated with Oxon Limited are in turn expected to have appropriate due diligence arrangements and controls in place in relation to the other parties they engage with, on behalf of Oxon Limited.
Monitoring & Review
Oxon Limited performs payment monitoring, including monitoring for bribery ‘red flags’ and Oxon Limited' independent compliance function conducts periodic risk-based monitoring of gifts and entertainment.
Training & Communication
Oxon Limited promotes staff awareness in compliance with the Anti-Bribery & Corruption framework through the appropriate dissemination of the Policy and procedures (including disciplinary procedures) and training on induction and periodically thereafter
