Definition
Bribery is, in the conduct of AJAC Supplies (UK) Limited (the Company) business, the offering or accepting of any gift, loan, payment, reward or advantage for personal gain as an encouragement to do something which is dishonest, illegal or a breach of trust. Bribery is a criminal offence. The Company prohibits any form of bribery. We require compliance, from everyone connected with our business, with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us and we have a zero tolerance attitude towards corrupt activities of any kind, whether committed by AJAC Supplies (UK) Limited employees or by third parties acting for or on behalf of AJAC Supplies (UK) Limited.
Purpose
The purpose of this policy is to convey to all employees, customers, suppliers and interested parties of AJAC Supplies (UK) Limited the rules of the Company in relation to our unequivocal stance towards the eradication of bribery and our commitment to ensuring that AJAC Supplies (UK) Limited conducts its business in a fair, professional and legal manner.
Scope
This policy applies to all employees of AJAC Supplies (UK) Limited, regardless of seniority or site. It also extends to anyone working for or on our behalf e.g. those engaged by us on a self-employed basis or an agency arrangement. We will encourage the application of this policy where our business involves the use of third parties e.g. suppliers; contractors.
Policy
AJAC Supplies (UK) Limited prohibits, directly or indirectly, to offering, giving, requesting or accepting any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or company in order to gain commercial, contractual or regulatory advantage for the Company, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.
The Company prohibits acting in the above manner to influence an individual in his capacity as a foreign public official. We will not make a payment to a third party on behalf of a foreign public official.
Appropriate checks will be made before engaging with suppliers or other third parties of any kind to reduce the risk of our business partners breaching our antibribery rules.
The Company will ensure that all of its transactions, including any sponsorship or donations given to charity, are made transparently and legitimately.
The Company takes any actual or suspected breach of this policy extremely seriously and will carry out a thorough investigation should any instances arise.
We will uphold UK and laws of the countries in which we operate relating to bribery and will take disciplinary action against any employee, or other relevant action against persons working on our behalf or in connection with us, should we find that an act of bribery, or attempted bribery, has taken place. This action may result in an employee’s dismissal, or the cessation of our arrangement with a self-employed individual, an agency worker, contractor etc.
Gifts and hospitality
We realise that the giving and receiving of gifts and hospitality where nothing is expected in return helps form positive relationships with third parties where it is proportionate and properly recorded. This does not constitute bribery and consequently such actions are not considered a breach of this policy.
Gifts include money; goods (flowers, vouchers, food, drink, event tickets when not used in a hosted business context); services or loans given or received as a mark of friendship or appreciation.
Hospitality includes entertaining; meals or event tickets (when used in a hosted business context) given or received to initiate or develop relations. Hospitality will become a gift if the host is not present.
A record will be made of every instance in which gifts or hospitality are given or received. As the law is constantly changing, this policy is subject to review and the Company reserves the right to amend this policy without prior notice.