Joint Inspection Group (“JIG”)
Anti-Bribery & Anti-Corruption Policy
(“The Policy”)
1. Purpose
The purpose of this policy is to establish controls to ensure that all of JIG’s activities are carried out in compliance with anti-bribery and anti-corruption laws of the United Kingdom and any other country where JIG activities are undertaken and which are applicable to JIG’s business.
2. Policy Statement
Each of the JIG participant companies recognizes that it may be held liable for bribery or corruption undertaken by any of the JIG directors, officers, employees, members or associated members, or anyone acting on JIG’s behalf. The JIG participants have therefore moved to adopt this Policy in order to ensure that all of JIG’s activities are undertaken in full compliance with the applicable anti-corruption laws. It is JIG’s policy to conduct all its business activities in an honest, transparent and ethical manner. JIG takes a zero tolerance approach to all forms of bribery and corruption. JIG is committed to acting professionally, fairly and with integrity in all its business dealings and relationships wherever it operates.
3. Scope – Who is covered by this Policy?
This Policy will apply to all of JIG’s directors, officers, employees, members and associated members and will also apply to all third parties when acting for or on behalf of JIG.
4. Prohibited Conduct
Any conduct which would constitute a breach of the anti-bribery and anti-corruption laws of the United Kingdom or the laws of any other country where JIG activities are undertaken. In particular, directly or indirectly, offering, promising, giving, accepting or soliciting any advantage (e.g. money, goods, services or anything of value), to/from any third party, as an inducement for action, or omission, for a corrupt purpose. Prohibited conduct also includes any inducement or reward directly or indirectly offered, promised or provided in order to gain any commercial, contractual, regulatory, personal or other advantage.
5. Facilitation Payments
Facilitation payments are a form of bribery made for the purposes of expediting or facilitating the performance of a public official for a routine governmental action, and not to obtain or retain business or any improper business advantage. Facilitation payments tend to be demanded by low level officials to obtain a level of service which one would normally be entitled to. JIG strictly prohibit the making of facilitation payments. It is not acceptable for anyone, acting for or on JIG’s behalf, to make these sorts of payments in any circumstances.
6. Gifts & Hospitality
The giving or receiving of gifts or any other financial or other benefit or advantage can be made for or on behalf of JIG, by JIG’s directors, officers, employees, members or associated members, where it is in the context of a commercial courtesy and it does not, on an objective assessment, compromise the integrity and/or reputation of either party, and cannot be construed, by an impartial observer as being aimed at creating an indebtedness or obtaining undue advantage.
Gifts and other financial advantages or other benefits made or received must therefore be reasonable and bona fide in all of the circumstances and in line with what is considered normal market practice (i.e. not lavish or excessive).
Further, any gift or financial advantage, or the benefit must have all of the following characteristics:
(a) Not be a cash payment,
(b) Be provided in connection with a bona fide and legitimate business purpose,
(c) Not be motivated by a desire to exert improper influence, or with the expectation or reciprocity,
(d) Be reasonable under the circumstances,
(e) Be tasteful and commensurate with the generally accepted standards for professional courtesy, and
(f) Comply with the local laws and regulations that apply Public Officials and private parties.
Further, any gifts or hospitality made or received by those acting for or on behalf of JIG must notify the JIG Council as soon as reasonably practicable and preferably in advance, where circumstances allow.
7. Political Contributions
JIG does not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage.
8. Sponsorships and Charitable Contributions
Sponsorship initiatives and the making of charitable donations are acceptable, however, care must be taken that these initiatives are not used as schemes to conceal bribery. Such initiatives will only be undertaken with well known and reputable third parties. All such initiatives must be approved by the JIG Council.
9. Other Agreements involving third parties
The JIG Participants recognize that other agreements with third parties, such as: consultancy agreements, contractor agreements, sales/acquisition of land and lease agreements, intermediary agreements and agreements with third parties who will act on behalf of JIG may pose bribery and corruption risks. All agreements such with third parties will therefore be assessed by the JIG Council which will, where necessary, undertake due diligence on any proposed counterparty and include suitable contractual provisions in any contract with such third parties, designed to mitigate the risk of corruption.
10. Record Keeping
JIG and the JIG directors, officers, employees, members or associated members will maintain full, accurate and detailed financial accounts in the relevant books and records relating to all and any activities undertaken for or on behalf of JIG and notify the JIG Council or the appropriate Committee of all relevant expenses incurred.
11. Monitoring and Review
The JIG Council will keep under review and monitor this Policy and will make whatever amendments are necessary to ensure its continued effectiveness.
Anti-Trust Policy
It is JIG’s policy that its directors, officers, employees, members and associated members comply with the antitrust laws of the United Kingdom and any other country where JIG’s activities are undertaken and applicable to JIG’s business.
August 2014
