Anti-Bribery Policy and Statement

Anti-Bribery Policy and Statement, October 2022 

Policy statement 

It is the policy of Hitbox (HK) Limited and all it’s subsidiaries including Thronmax LLC, to conduct business  in an honest and ethical manner. Referred to in this policy as the “Company”, Hitbox Hong Kong Limited takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally,  fairly and with integrity in all its business dealings and relationships, wherever it operates, and  implementing and enforcing systems to counter bribery. 


The company will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in  which it conducts business, including, in the UK, the Bribery Act 2010 (the Act), which applies to conduct  both in the UK and abroad. 

Scope and applicability 

This Anti-Corruption and bribery Policy (the Policy) applies to all individuals working for or on behalf of  the company at all levels and grades, whether permanent, fixed-term or temporary, and wherever  located, including consultants, contractors, seconded staff, casual staff, agency staff, volunteers, agents,  sponsors and any other person who performs services for or on behalf of the company (collectively  referred to as Workers in this policy). 

In this policy, Third Party means any individual or organisation that Workers come into contact with  during the course of work and the running of the Company’s business, and includes actual and potential  clients, intermediaries, referrers of work, suppliers, distributors, business contacts, agents, advisers,  government and public bodies (including their advisers, representatives and officials), politicians and  political parties. 

What is bribery? 

A bribe is an inducement or reward offered, promised or provided in order to improperly gain any  commercial, contractual, regulatory or personal advantage, which may constitute an offence under the  Act, namely:

  • giving or offering a bribe; 
  • receiving or requesting a bribe; or 
  • bribing a foreign public official. 

The Company may also be liable under the Act if it fails to prevent bribery by an associated person  (including but not limited to Workers) for the Company’s benefit. 

Gifts and hospitality 

This Policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from  Third Parties unless otherwise specifically stated. However, we have specific internal policies and  procedures which provide guidance to Workers as to what is to be regarded as normal and appropriate  gifts and hospitality in terms of financial limits, subject to the principles set out below (the Overriding  Principles), namely that any gift or hospitality: 

  • must not be made with the intention of improperly influencing a Third Party or Worker to obtain  or retain business or a business advantage, or to reward the provision or retention of business or  a business advantage, or in explicit or implicit exchange for favours or benefits; 
  • must comply with local law in all relevant countries; 
  • must be given in the name of the organisation, not in an individual’s name; 
  • must not include cash or a cash equivalent; 
  • must be appropriate in the circumstances; 
  • must be of an appropriate type and value and given at an appropriate time taking into account  the reason for the gift; 
  • must be given openly, not secretly; 

The Company appreciates that the practice of giving business gifts varies between countries and regions  and what may be normal and acceptable in one region may not be in another. The test to be applied is  whether in all the circumstances the gift or hospitality is reasonable and justifiable both in the UK and  any other relevant country. The intention behind the gift should always be considered. 

What is not acceptable? 

It is not acceptable for any Worker (or someone on their behalf) to: 

  • give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that  they or the Company will improperly be given a business advantage, or as a reward for a  business advantage already improperly given; 
  • give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or  representative to facilitate or expedite a routine procedure; 
  • accept payment from a Third Party where it is known or suspected that it is offered or given with  the expectation that the Third Party will improperly obtain a business advantage; accept a gift or hospitality from a Third Party where it is known or suspected that it is offered or  provided with an expectation that a business advantage will be improperly provided by the  Company in return;
  • threaten or retaliate against another Worker who has refused to commit a bribery offence or  who has raised concerns under this Policy; or 
  • engage in any activity that might lead to a breach of this Policy. 

Facilitation payments and kickbacks 

We do not make, and will not accept, facilitation payments or “kickbacks” of any kind, such as small,  unofficial payments made in return for a business favour or advantage. 

Charitable donations and sponsorship 

The Company only makes charitable donations and provides sponsorship that are legal and ethical under  local laws and practices and which are in accordance with the Company’s internal policies and  procedures. 

Record keeping 

We keep appropriate financial records and have appropriate internal controls in place which evidence the  business reason for gifts, hospitality and payments made and received. 

Responsibilities and raising concerns 

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of  all those working for us or under our control. All Workers are required to avoid any activity that might  lead to, or suggest, a breach of this Policy. 

Workers are required to notify the Company as soon as possible if it is believed or suspected that a  conflict with this Policy has occurred, or may occur in the future, or if they are offered a bribe, are asked  to make one, suspect that this may happen in the future, or believe that they are a victim of another  form of unlawful activity. 

Any employee who breaches this Policy may face disciplinary action, which could result in dismissal for  gross misconduct. We reserve our right to terminate our contractual relationship with non-employee  Workers if they breach this Policy. 

If any Third Party is aware of any activity by any Worker which might lead to, or suggest, a breach of this  Policy, they should raise their concerns with the Company’s Founder – Hasan Turgut, in the first instance – 

Training and communication

Training on this Policy is provided for all Workers and our zero-tolerance approach to bribery and  corruption will, where appropriate, be communicated to clients, suppliers, contractors and business  partners. 

Monitoring and review 

The Company monitors the effectiveness and reviews the implementation of this Policy at appropriate  intervals, considering its suitability, adequacy and effectiveness. Any improvements identified are made  as soon as possible. Internal control systems and procedures are also subject to regular review to provide  assurance that they are effective in countering any risks of bribery and corruption. All Workers are aware that they are responsible for the success of this Policy and should ensure they use  it to disclose any suspected danger or wrongdoing.