Anti‐Bribery Policy

ANTI‐BRIBERY Policy

Policy:

Our Anti‐Bribery policy exists to set out the responsibilities of all employees with regard to upholding our zero‐tolerance positions to bribery and corruption.

Policy Statement

Just Print UK Limited t/a JP-UK committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented. We have a zero‐tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate. We will constantly uphold all laws relating to anti‐bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, about our conduct both at home and abroad.

Who is covered by the policy?

This anti‐bribery policy applies to all employees (whether temporary, fixed term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), no matter where they are located (within or outside of the UK). The policy also applies Board, and/or Committee members at any level.

Definition of bribery:

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.
A bribe refers to any inducement, reward, or object/item of value offered to another individual to gain commercial, contractual, regulatory, or personal advantage.

What is and what is NOT acceptable:

Our Company accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:

It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.
It is not made with the suggestion that a return favour is expected.
It complies with local law.
It is given in the name of the company, not in an individual’s name.
It does not include cash or a cash equivalent (e.g., a voucher or gift certificate).
It is appropriate for the circumstances (e.g., giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
It is of an appropriate type and value and given at an appropriate time, considering the reason for the gift.
It is given/received openly, not secretly.
It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
It is not above a certain excessive value, as pre‐determined by the company’s compliance manager (usually more than £100).
It is not offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance manager.

Employee responsibilities:

All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti‐bribery policy.
If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the compliance manager.

Training and communication:

Our Anti‐bribery and Corruption policy and zero‐tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and 7 any third‐parties at the outset of business relations, and as appropriate thereafter.
We will provide relevant anti‐bribery and corruption training to employees etc. where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice, all businesses should provide their employees with anti‐bribery training where there is a potential risk of facing bribery or corruption during work activities.

Record keeping:

We will keep detailed and accurate financial records and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given and understand that gifts and acts of hospitality are subject to managerial review.

Monitoring and reviewing:

Our Compliance Manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.
This policy does not form part of an employee’s contract of employment and Just Print UK Limited t/a JP-UK may amend it at any time so to improve its effectiveness at combatting bribery and corruption.