Scope
This policy applies to the company, its officers, and anyone acting for it, including agents and subcontractors. It covers valuation work, procurement and brokerage of goods, and export control files. A counterparty that will not accept these terms is not taken on.
Anti-Bribery and Corruption
The company complies with the Bribery Act 2010. It does not offer, pay, request or accept bribes or facilitation payments, directly or through a third party. It does not pay success fees to officials or to persons connected with a procurement decision. Agents and introducers are appointed in writing, and their fees are disclosed to the client where the contract requires it. Gifts and hospitality to public officials are declined.
Sanctions
Every counterparty, beneficial owner, end user, vessel and destination is screened before work starts and again before goods move. Screening covers the UK sanctions list maintained by OFSI and the FCDO. Where US persons, US-origin goods or US dollars are involved, the OFAC lists are screened as well, and where EU persons or goods are involved, the EU consolidated list. A match stops the work until it is cleared or the work is declined.
Export Controls and End Use
Goods are classified before an offer is made. Controlled goods move only under a valid export licence from the country they leave. Goods leaving the UK are classified against the UK Strategic Export Control Lists and move only under the appropriate licence issued by the Export Control Joint Unit. The company obtains end-user undertakings where the licence requires them, and it keeps licence records for the retention period the licence sets. Brokering of controlled goods between third countries is done only under the trade control rules. Explosives, firearms and ammunition are handled only where every required licence and permit is in place.
Licence numbers and end-user details are given to an identified counterparty on request. They are not published on this website.
Counterparty Due Diligence
Before work starts, the company asks each counterparty for:
- the registered legal name, company number and registered address;
- beneficial owners holding 25 per cent or more, and the directors;
- the end user and end use of the goods, with an end-user statement where a licence requires one;
- evidence of the counterparty's own licences, registrations or permits for the goods;
- the bank that will pay or receive, and the route the goods will take.
The company does not hold client money. Payment for goods is made through a bank or a trade finance provider. The company is not authorised by the Financial Conduct Authority and does not give regulated financial advice.
Modern Slavery
The company does not accept forced, compulsory or child labour in its own operations or in its supply chains. Suppliers are asked to confirm the same in writing. The company's turnover is below the threshold that requires a published statement under section 54 of the Modern Slavery Act 2015. This paragraph is published voluntarily.
Conflicts of Interest
The company will not value a business or contract in which it has a financial interest, and it will not act for both sides of a trade without the written consent of both. Any conflict found after work has started is disclosed to the client in writing.
Information Handling
The company does not accept classified material through this website, its email address or its form. Material marked OFFICIAL-SENSITIVE or above is received only through a channel agreed with the originating organisation.
Records
Due diligence, screening results, licences and transaction records are kept for at least six years from the end of the relevant work, or longer where a licence or a contract requires it.
Reporting a Concern
Report a suspected breach of this policy to contact@onyxadvisory.co.uk with the subject line "Compliance". Reports are read by an officer of the company, and nobody who reports in good faith is penalised.
Security issues with this website can be reported through the contact listed in security.txt.