Bribery is a criminal offence. JPL 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 our employees or by third parties acting for or on behalf of JPL.

POLICY

It is prohibited, directly or indirectly, for any employee or person working on our behalf to offer, give, request or accept 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.

SUSPICION

If we suspect that an act of bribery or attempted bribery has been committed, an investigation will be carried out and, in line with our disciplinary procedure where appropriate, action may be taken against the employee which may result in dismissal or the cessation of our business arrangement with any contractor found in breach of our policy.

REPORTING

If any employee or person working on our behalf, suspect that an act of bribery or attempted bribery has taken place, even if they are not personally involved, they are expected to report this to a Director. They may then be asked to give a written account of events.

Staff are reminded of the Company’s Whistle-Blowers Policy which is available in JPL’s Employee Handbook.

GIFTS AND HOSPITALITY

We realise that the giving and receiving of gifts and hospitality as a reflection of friendship or appreciation where nothing is expected in return may occur, or even be commonplace, in our industry. This does not constitute bribery where it is proportionate and recorded properly.

No gift should be given nor hospitality offered by an employee or anyone working on our behalf to any party in connection with our business without receiving prior written approval from a Director.

Similarly, no gift or offer of hospitality should be accepted by an employee or anyone working on our behalf without receiving prior written approval from a Director.

RECORD KEEPING

A record will be made by a Director 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 JPL reserves the right to amend this policy without prior notice.

This policy will be reviewed annually or if we think it might no longer be valid, e.g. if circumstances change.