Anti-Bribery and Corruption Policy

TD & Partners Global does not tolerate bribery or corruption in any form, whether direct or indirect. We are committed to conducting business honestly and in compliance with applicable anti-bribery laws in Zimbabwe, the United Kingdom and elsewhere.

This policy applies to everyone acting on our behalf, including partners, employees, contractors and third parties representing us. It covers all business activities and all jurisdictions in which we operate.

We prohibit offering, giving, promising, soliciting, accepting or authorising anything of value — directly or indirectly — to obtain or retain business or an improper advantage. This includes payments to public officials, commercial bribery, and facilitation payments except where refusal would create an immediate threat to safety.

We apply judgement and transparency to gifts and hospitality. Gifts and hospitality must be modest, proportionate, made in good faith, and properly recorded. We do not offer or accept gifts or hospitality that could improperly influence judgement or create an appearance of impropriety.

We do not make donations or sponsorships as a means of securing improper advantage. Any donations or sponsorships are made transparently and for genuine purposes, and are properly approved and recorded.

We take reasonable steps to ensure those acting on our behalf understand and follow this policy. We assess third parties for bribery risk where appropriate and include anti-bribery commitments in relevant arrangements.

Everyone is responsible for preventing bribery. Leaders are responsible for ensuring controls operate in their areas. Concerns must be raised through our Speak Up and Whistleblowing Policy.

We investigate suspected breaches promptly and confidentially. We act on findings, including disciplinary and legal action where appropriate, and we protect those who raise concerns in good faith from retaliation.

We keep accurate books and records that fairly reflect our transactions. We do not maintain off-book accounts or use false documents to conceal improper payments.

We review this policy regularly. The effective date and version are shown on the policy page.