Total Asset Silk Road is committed to conducting business lawfully, honestly, independently, and transparently. These principles apply to directors, employees, consultants, and other persons acting for the Company and are considered when selecting business partners.
1. Compliance with law
We comply with the laws of the Republic of Uzbekistan and mandatory requirements of other jurisdictions relevant to a particular engagement. Commercial objectives, deadlines, or client expectations never justify a breach of law, contract, or these principles.
2. Zero tolerance for corruption
- bribes, kickbacks, unofficial benefits, and facilitation payments are prohibited;
- no person may directly or through an intermediary offer, promise, give, request, or accept an improper advantage;
- improper payments may not be disguised as consulting fees, hospitality, gifts, charitable contributions, or other expenses;
- where doubt exists, the transaction must be paused pending compliance review and written approval by an authorised manager.
3. Public-sector engagement
Engagement with public authorities is conducted only through lawful and officially permitted means. The Company may support regulatory analysis, meeting and document preparation, official submissions, and procedural monitoring, but does not promise informal influence, guaranteed access, or a favourable public decision.
Material communications, instructions, and expenses involving public officials must be documented and have a lawful business purpose.
4. Gifts and hospitality
Gifts, invitations, and hospitality are permitted only when lawful, reasonable, infrequent, transparent, business-related, and incapable of being viewed as an attempt to influence a decision. Cash and cash equivalents are prohibited. Heightened caution and prior approval apply to public officials.
5. Conflicts of interest
Employees and consultants must promptly disclose actual, potential, or perceived conflicts between personal and professional interests. The Company applies proportionate safeguards, ranging from documented conflict management and information barriers to declining an engagement.
6. Third-party due diligence
Before appointing an agent, intermediary, subcontractor, customs declarant, certification body, or other partner, the Company assesses reputation, competence, authority, remuneration, conflicts, and applicable sanctions or restrictions. Agreements must clearly define scope, remuneration, confidentiality, and compliance obligations.
7. AML, sanctions, and payment integrity
The Company does not participate in money laundering, terrorist financing, sanctions evasion, concealment of beneficial ownership, or payments lacking a genuine economic purpose. Unusual, opaque, or disproportionate payments require enhanced review.
8. Confidentiality and personal data
Confidential information and personal data are used only for a lawful, stated purpose, accessed on a need-to-know basis, and protected in accordance with contractual and legal requirements. Client information must not be used for personal benefit or disclosed without authority.
9. Fair competition and accurate claims
The Company prohibits collusion, unlawful exchange of competitively sensitive information, misleading statements, unsupported comparisons, and exaggeration of qualifications, client relationships, or results. Public metrics, case studies, and testimonials must be supported by evidence and disclosure permission.
10. Professional independence
Analysis and recommendations are based on facts, agreed methodology, and professional judgement. The Company discloses material limitations, assumptions, and conflicts, does not alter conclusions to produce a predetermined answer, and does not guarantee decisions outside its control.
11. Respect and non-discrimination
The Company supports a safe professional environment, respects human dignity, and prohibits discrimination, harassment, forced labour, and other abuse in its own activities. It expects comparable conduct from business partners.
12. Reporting concerns
Suspected violations may be reported to info@total-asset.uz with the subject line “Compliance Report”. Reports should include sufficient facts for a good-faith review. The Company handles reports confidentially to the extent permitted by law and prohibits retaliation against a person who raises a concern in good faith.
13. Response
A substantiated breach may result in corrective action, removal from an engagement, termination of employment or contract, return or blocking of an improper benefit, notification of a client or competent authority, and other actions required by law.
14. Governance
Total Asset Silk Road management is responsible for implementing these principles. The document is reviewed at least annually and whenever there is a material change in law, business activities, or risk profile.