Policy · Conduct
Anti-bribery and corruption policy.
Our approach to improper payments, inducements, gifts, hospitality, conflicts and third-party conduct in investment, property and estate activities.
Policy information · reviewed September 2026
Bribery and corruption are incompatible with how we do business.
Grupo Gosen does not accept bribery, kickbacks, secret commissions or other improper inducements in connection with acquisitions, sales, planning, estate management, procurement, contracting, tenancy matters or any other business activity.
No person acting for or on behalf of Grupo Gosen should offer, promise, give, request or accept a financial or other advantage where the purpose is to induce improper performance, reward improper conduct or create an undisclosed obligation.
The same principle applies when an intermediary, adviser, agent, contractor, introducer or other third party is involved. A payment or benefit does not become acceptable merely because it passes through another person.
Conduct
Areas requiring particular care.
Introducers & advisers
Fees and commissions should relate to legitimate services, be documented appropriately and not conceal an improper payment or conflict.
Contractors & suppliers
Procurement decisions should be made for legitimate business reasons and not in exchange for personal benefits.
Land & planning matters
No improper advantage should be offered to influence a public, planning, regulatory or property decision.
Gifts & hospitality
Modest and legitimate hospitality may be acceptable where lawful, proportionate and transparent, but it must never be used to influence a decision improperly.
Conflicts of interest
Personal, family or financial interests that could affect impartial decision-making should be disclosed and managed.
Records
Payments, fees, gifts and material business expenses should be recorded accurately and not disguised through false descriptions or off-book arrangements.
Facilitation & pressure
No unofficial shortcut payments.
Unofficial payments intended to secure or accelerate a routine official action are not an acceptable method of doing business. Genuine, published and lawfully charged fees for an official expedited service are different and should be supported by proper documentation.
Where a person believes a payment or benefit has been requested improperly, they should not conceal the issue. A concern can be raised through the central contact form with enough context for it to be directed appropriately.
If an immediate threat to personal safety is involved, personal safety takes priority. The circumstances should be recorded and reported as soon as reasonably possible afterwards.
Third parties
Proportionate due diligence supports clean transactions.
Land and estate transactions can involve agents, sellers, advisers, public bodies, contractors and specialist consultants. The level of due diligence should reflect the value, role, jurisdiction, payment structure and risks of the relationship.
Warning signs can include unexplained cash requests, unusual payment routes, vague services, pressure for secrecy, excessive commissions, undisclosed relationships or requests to pay a party with no clear role in the transaction.
Where a material concern cannot be resolved satisfactorily, Grupo Gosen may decline, pause or terminate the relevant relationship or transaction, subject to applicable contractual and legal obligations.
Concern about bribery, corruption or a conflict?
Use the contact form, identify the subject as a conduct or anti-bribery concern and provide enough context for it to be reviewed.
Raise a concernRisk areas
Property transactions require particular attention to conflicts, introductions and payments.
Land acquisition and estate management can involve agents, brokers, planning consultants, contractors, local suppliers, professional advisers and public authorities. These relationships create legitimate commercial interactions but can also create bribery and corruption risk if payments, gifts, hospitality, introductions or conflicts are not transparent.
Grupo Gosen expects fees and commissions to reflect genuine services, be properly documented and be paid through appropriate channels. No person acting for the group may offer or accept an improper advantage to influence a decision, accelerate a public process, obtain confidential information or secure preferential treatment.
Facilitation payments are not treated as an acceptable shortcut. Political or charitable contributions must not be used to disguise a benefit intended to influence a transaction or public decision.
Controls
Proportionate anti-bribery controls are applied to relevant relationships.
Counterparty diligence
Identity, ownership, reputation, role and reason for appointment may be reviewed before higher-risk intermediaries or suppliers are engaged.
Written scope and fees
Material appointments should state the service, commercial basis, authority and payment terms clearly enough to be audited.
Conflicts
Actual or potential conflicts of interest should be disclosed and managed rather than concealed.
Gifts and hospitality
Hospitality must be reasonable, proportionate and connected with legitimate business rather than intended to induce improper conduct.
Payment controls
Unusual payment destinations, unexplained cash requests, excessive commissions or payments unrelated to contractual milestones require scrutiny.
Reporting concerns
Employees, suppliers and counterparties are encouraged to raise suspected bribery, fraud or conflicts through the contact form or the relevant internal route.
Third parties
People acting on behalf of Grupo Gosen are expected to meet equivalent standards.
A company can face risk through agents, consultants, introducers and other associated persons. Grupo Gosen therefore expects third parties acting for it to comply with applicable anti-bribery law and to avoid conduct that the group itself would not undertake.
Contracts may include anti-bribery obligations, audit or information rights, termination rights and requirements to notify suspected misconduct where proportionate to the relationship.
Suspected wrongdoing can result in investigation, suspension of payment, termination, referral to advisers or authorities and other action depending on the circumstances.