In This Article

Our position in one sentence: FlatFee Sourcing will never pay, offer, accept, or facilitate a bribe — to any person, in any form, in any country — and our transparent flat-fee model exists precisely to make this promise auditable.

Our Commitment

FlatFee Sourcing was built on a single principle: you should always know exactly what you are paying and who is receiving it. Traditional sourcing agents profit from hidden markups, kickbacks from factories, and opaque pricing. We reject this model entirely.

Our business model is anti-corruption by design. We earn revenue exclusively from fixed, published service fees. We have zero financial incentive to steer clients toward higher-priced factories, accept kickbacks from suppliers, or hide any part of the transaction from you.

This Anti-Bribery Policy formalizes that commitment. It applies to every aspect of how we operate, from how we select factories on 1688 to how we interact with logistics partners and regulatory authorities.

Who This Policy Applies To

This policy applies to:

  • FlatFee Sourcing staff: All full-time and part-time employees, contractors, and consultants acting on our behalf.

  • Our clients: When engaging FlatFee Sourcing's services, clients agree not to offer, request, or encourage any form of bribe, kickback, or improper payment through or to FlatFee Sourcing or any party we introduce.

  • Third parties we work with: Freight forwarders, inspection labs, customs brokers, and other partners are expected to adhere to equivalent anti-bribery standards as a condition of working with us.

Engaging our services constitutes acceptance of this policy as part of our Terms of Service.

What Is Bribery

Bribery is the offering, giving, receiving, or soliciting of any item of value — money, gifts, services, favors, or anything else — in order to improperly influence a decision or action.

In the context of China sourcing, bribery and corruption can take many forms, including:

  • A sourcing agent accepting a "rebate" or kickback from a factory in exchange for directing client business to that factory.

  • A factory offering gifts, entertainment, or cash to an agent to secure repeat orders.

  • An agent inflating invoices or adding hidden margins and sharing a portion with a factory as a kickback.

  • Payments made to expedite customs clearance or government inspections outside of official fee channels.

  • A client incentivizing an agent to falsify QC reports or inspection results.

All of the above are strictly prohibited under this policy and under applicable law.

Prohibited Conduct

FlatFee Sourcing and anyone acting on our behalf must never:

  • Offer, promise, or give a bribe to any person or entity — private or public — to obtain or retain business, or to secure an improper advantage.

  • Accept or solicit a bribe, kickback, hidden rebate, or secret commission from any factory, supplier, freight forwarder, lab, or other third party.

  • Mark up factory invoices or product costs and conceal the markup from clients.

  • Falsify, alter, or omit material information in sourcing reports, QC reports, factory invoices, or any other deliverable.

  • Facilitate a bribe by a third party, even if FlatFee Sourcing does not directly participate in or benefit from the payment.

  • Use a third party (subcontractor, intermediary, or partner) as a conduit for improper payments.

  • Threaten or retaliate against anyone who refuses to participate in bribery or who reports a concern.

Gifts & Hospitality

We recognize that exchanging small gifts and reasonable hospitality is a normal part of business relationships in China and other markets. This policy does not prohibit all gift-giving. The key test is: could this gift or hospitality reasonably influence — or appear to influence — a business decision?

Acceptable

  1. Modest seasonal gifts (e.g., mooncakes, tea) of low value

  2. Standard factory-provided meals during site visits

  3. Branded promotional items of nominal value

  4. Gifts given openly and transparently to all parties

Prohibited

  1. Cash or cash-equivalent gifts in any amount

  2. Gifts valued above USD $50 from any single source

  3. Hospitality that is lavish, frequent, or tied to a pending decision

  4. Gifts given secretly or routed through a third party

When in doubt, decline. Any gift received above the acceptable threshold must be disclosed to management and either returned or donated to a charitable cause.

Facilitation Payments

Facilitation payments — small, unofficial payments to government officials or customs personnel to speed up routine processes — are prohibited regardless of their size or local custom.

If a government official, customs officer, or any other person requests an unofficial payment in connection with our services:

  • Politely decline the request.

  • Document the incident in writing, including the date, person involved, and amount requested.

  • Report the incident to us immediately at [email protected].

FlatFee Sourcing will never penalize a client or team member for a delay caused by refusing to make a facilitation payment.

Our Open-Book Model as an Anti-Corruption Control

Structural transparency: Because we forward unmodified 1688 factory invoices directly to clients and charge only fixed published fees, there is no gap in which a hidden kickback or margin could exist undetected. The open-book model is our primary anti-corruption control.

Specifically:

  • Zero commission on product cost. We earn nothing from your product purchase price. A factory cannot bribe us by offering a higher price — we pass 100% of the factory price to you.

  • Published, fixed service fees. Our fees are publicly listed on our website. There is no variable component tied to order size, product margin, or factory choice.

  • Direct invoice transparency. You receive the original 1688 factory invoice. Any discrepancy between the invoice we show you and the amount we pay the factory would be immediately visible — and is explicitly prohibited by this policy.

  • No exclusive factory relationships. We do not hold commercial agreements with specific factories that would create a financial incentive to favor one over another. We recommend factories based solely on your specifications and our quality assessment.

Due Diligence on Third Parties

We conduct basic due diligence on the third parties we regularly work with — including freight forwarders, inspection labs, and customs brokers — to assess their integrity and compliance standards.

Our due diligence process includes:

  • Verifying business registration and licensing of key partners.

  • Reviewing their reputation and any known compliance issues.

  • Requiring partners to confirm, as a condition of working with us, that they do not engage in bribery or corrupt practices.

  • Terminating relationships with any partner found to be engaging in bribery, even if FlatFee Sourcing was not directly involved.

We acknowledge that due diligence cannot eliminate all risk in complex international supply chains. If a client becomes aware of potential misconduct by a third party we introduced, we ask that you inform us immediately.

Record Keeping

Accurate record keeping is essential to demonstrating compliance with this policy and with applicable anti-bribery laws.

FlatFee Sourcing maintains:

  • Unmodified copies of all 1688 factory invoices shared with clients.

  • Records of all service fees charged and received.

  • Documentation of any gifts received or given, including description, value, and business context.

  • Records of any reported concerns or investigations conducted under this policy.

We do not create false, misleading, or off-the-books records. All financial transactions are recorded accurately and in a timely manner.

Reporting Concerns

If you — as a client, team member, or third party — become aware of or suspect a violation of this policy, we encourage and expect you to report it promptly.

You can report a concern by:

Reports may be made anonymously where local law permits. All reports will be treated with strict confidentiality and investigated promptly and impartially.

Concerns raised in good faith will never be used against the person raising them, even if the investigation does not substantiate the concern.

Non-Retaliation

FlatFee Sourcing has a strict non-retaliation policy. Anyone who reports a genuine concern about bribery or corruption — or who refuses to participate in conduct that would violate this policy — is protected from:

  • Termination or suspension of services.

  • Reduction in service quality or scope.

  • Threats, intimidation, or harassment.

  • Any other adverse action as a consequence of their report or refusal.

If you believe you have experienced retaliation for reporting a concern, please contact us immediately. Retaliation against a reporter is itself a serious violation of this policy.

Consequences of Violations

Violations of this policy are treated seriously regardless of seniority, business pressure, or local custom.

For FlatFee Sourcing team members

Violations may result in immediate termination of the working relationship, recovery of any improper payments, and referral to appropriate law enforcement authorities where required.

For clients

If a client offers a bribe to FlatFee Sourcing staff or to a factory or third party in connection with our services, we reserve the right to immediately terminate all services, retain fees already paid, and report the conduct to relevant authorities. Please refer to Section 12 of our Terms of Service (Prohibited Uses).

For third-party partners

Partners found to have engaged in bribery or corrupt practices will have their working relationship with FlatFee Sourcing terminated immediately.

Applicable Laws

This policy is designed to comply with, and is informed by, the following laws and frameworks:

  • People's Republic of China: Anti-Unfair Competition Law; Criminal Law provisions on commercial bribery (Articles 163–164); Regulations on Prohibiting Commercial Bribery.

  • United Kingdom: Bribery Act 2010, which applies to any business with UK operations or UK-based clients and which prohibits both the giving and receiving of bribes, including facilitation payments.

  • United States: Foreign Corrupt Practices Act (FCPA), which prohibits US persons and companies from bribing foreign government officials. Clients who are US persons should ensure their own FCPA compliance.

  • OECD Anti-Bribery Convention: We align with the principles of the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.

This policy does not constitute legal advice. Clients are responsible for understanding and complying with anti-bribery laws applicable in their own jurisdiction.

Review & Contact

This policy is reviewed annually or when there are material changes to applicable law or our business model. The current version is always published at FlatFeeSourcing.com/anti-bribery-policy.

For any questions about this policy or to report a concern:

FlatFee Sourcing

Email: [email protected]

Telegram: @Julian_Dong

WhatsApp: +852 5709 3280

Anti-bribery concerns are treated as priority matters. We aim to acknowledge all reports within 1 business day.