1. Purpose
This policy sets out Murzo Group's approach to foreign agents, distributors, local partners, introducers, consultants, brokers, commission payments, referral fees, and third-party representatives.
The purpose is to reduce bribery, corruption, sanctions, tax, conflict of interest, money laundering, hidden agency, unauthorised representation, and reputational risks in overseas work.
2. Scope
This policy applies to any person or organisation acting for, representing, introducing business to, distributing for, selling for, negotiating for, advising, or receiving commission from Murzo Group in relation to foreign markets.
It applies whether the partner is described as an agent, distributor, consultant, sponsor, local partner, fixer, introducer, broker, reseller, sourcing contact, joint venture party, or strategic adviser.
3. Partner Approval
Murzo Group should not appoint a foreign agent, distributor, or local partner without proportionate checks on identity, ownership, role, reputation, sanctions exposure, government connections, conflicts, capability, and payment route.
Higher-risk markets, government interactions, licences, customs matters, security-sensitive work, cultural property, high-value goods, public contracts, and commission-heavy arrangements require stronger review.
4. Commission and Payment Controls
Commission, referral fees, success fees, retainers, facilitation fees, gifts, hospitality, expense reimbursements, and local service charges must be transparent, proportionate, contractually agreed, and paid through legitimate routes.
Murzo Group will not make payments that are intended to improperly influence public officials, private customers, customs officers, licensing bodies, suppliers, auditors, lenders, inspectors, or decision makers.
- No cash or off-book payments
- No payment to unrelated third parties without approval
- No vague invoices for services not actually provided
- No success fee designed to disguise a bribe, kickback, or improper influence
- No commission arrangement that conflicts with sanctions, tax, AML, or procurement rules
5. Authority and Representation
Foreign agents, distributors, and local partners must not claim to bind Murzo Group, make legal commitments, change product claims, alter pricing terms, approve customs declarations, promise regulatory approval, or represent Murzo Group to authorities unless expressly authorised.
They must not use Murzo Group branding, confidential information, product claims, certificates, or websites beyond the approved scope.
6. Red Flags
- Undisclosed government, military, customs, police, royal, political, or public-sector connections
- Requests for cash, offshore payment, unrelated payee, inflated invoices, or vague consultancy fees
- Pressure to bypass checks, contracts, licences, sanctions screening, or procurement rules
- No clear business capability except access to officials or decision makers
- Refusal to disclose beneficial ownership, conflicts, sub-agents, or commission sharing
- Requests to hide Murzo Group involvement or misstate the partner's role
7. Contracts
Partner contracts should define role, territory, authority limits, payment basis, compliance duties, anti-bribery expectations, sanctions obligations, confidentiality, data protection, termination rights, audit support where justified, and restrictions on sub-agents.
Murzo Group may suspend or terminate a partner relationship if legal, ethical, sanctions, bribery, tax, AML, security, or reputational concerns arise.
8. Required Evidence Only
Partner, contract, payment, compliance, and approval evidence should be limited to what is required by law, tax, contract, authority request, banking, insurer, or legitimate business need.
9. Review
This policy will be reviewed when Murzo Group enters a new market, appoints higher-risk partners, uses commission-based structures, or handles government-facing work.
