1. Statement from the Board of Directors:
1.1 At John Alison we care about the future of UK business and believe that anti-bribery legislation is directly beneficial for business, because it creates clarity, the principle of free and fair competition and a level playing field, all of which can be diminished by a bribe offered or accepted. The legislation is tough as the Bribery Act 2010 creates offences of offering or receiving bribes and of failure to prevent a bribe being paid on an organisation’s behalf and this Policy sets out the steps that our team must take to prevent bribery and corruption in our business and to comply with the legislation.
1.2 We run our business with integrity and this Policy is a source of information and guidance for our clients, consultants and staff. For our staff, it helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.
2. The Policy
2.1 John Alison Land & Research Ltd is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.
2.2 John Alison Land & Research Ltd will consistently 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, in regards to our conduct both at home and abroad.
2.3 John Alison Land & Research Ltd recognizes, that any person guilty of bribery is subject to fines or up to ten years of imprisonment. If our company is discovered to have taken part in corrupt activities, or fails to have adequate procedures in place, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. Notwithstanding this, there is a moral issue here about engaging in good and fair business and it is with this in mind that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously.
3. Who is covered by the policy?
3.1 This anti-bribery policy applies to all employees including members of the Board (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), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK).
3.2 In the context of this policy third-party refers to any individual or organization, that our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.
3.3 Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with this policy.
4. Definition of Bribery
4.1 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.
4.2 A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage. There are many names given to such payments which seek to divert the attention of the unwary from the fact that they are actually Bribes, such terms as ‘Facilitation Payment’, ‘Kickback’, ‘Grease Payment’ and for the avoidance of doubt all constitute Bribes and fall within the scope of this Policy.
4.3 Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.
4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). You must not bribe a public official. You must not accept any payment for your services from a client or consultant employed by John Alison, or make any payment to a client or consultant employed by John Alison, if it is offered outside of our normal terms and conditions of engagement. If you are uncertain about whether something is a bribe, or a gift, or act of hospitality, you must immediately seek further advice from the Managing Director.
5. What is and what is not acceptable
5.1 Gifts and hospitality
5.1.1 John Alison Land & Research Ltd 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:
a. It is not made with the intention of influencing the party to whom it is being given, to obtain a business advantage or reward the retention of a business or, as an explicit or implicit exchange for favours or benefits.
b. It is not made with the suggestion that a return favour is expected.
c. It is in compliance with local law.
d. It is given in the name of the company, not in an individual’s name.
e. It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
f. 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).
g. It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
h. It is given/received openly, not secretly.
i. It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
j. It is not above a certain excessive value, as pre-determined by the company’s compliance manager (usually in excess of £100).
k. It is not offered to, or accepted from, a government official, or representative, or politician, or political party.
5.1.2 Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances.
5.1.3 As good practice, gifts given and received must always be disclosed to the compliance manager.
5.1.4 The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the compliance manager should be sought.
5.2 Facilitation Payments and Kickbacks
5.2.1 John Alison Land & Research Ltd does not accept and will not make any form of facilitation payments, kickbacks or grease payments of any nature. We recognize them as a form of bribery to induce officials to perform routine functions they are otherwise obligated to perform or offered/received for securing unfair business advantage.
5.2.3 John Alison Land & Research Ltd, recognizes, that despite our strict policy on facilitation payments and kickbacks, employees may, even in the UK, face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken:
a. Keep any amount to the minimum.
b. Ask for a receipt, detailing the amount and reason for the payment.
c. Create a record concerning the payment.
d. Report this incident to the Managing Director.
5.3 Political Contributions
5.3.1 John Alison Land & Research Ltd will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognize, this may be perceived as an attempt to gain an improper business advantage.
5.4 Charitable Contributions
5.4.1 John Alison Land & Research Ltd supports the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.
5.4.2 Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.
5.4.3 We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the Managing Director.
6. Employee Responsibilities
6.1 As an employee of John Alison Land & Research Ltd, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.
6.2 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.
6.3 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 Managing Director.
6.4 If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. John Alison Land & Research Ltd has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.
7. What happens if I need to raise a concern?
7.1 How to raise a concern
7.1.1 If you suspect that there is an instance of bribery or corrupt activities occurring in relation to John Alison Land & Research Ltd, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behavior can be considered bribery or corruption, you should speak to the Managing Director.
7.1.2 John Alison Land & Research Ltd will familiarize all employees, with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially.
7.2 What to do if you are a victim of bribery or corruption
7.2.1 You must tell the Managing Director as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity. Failure to do so could be considered as gross misconduct and could result in termination of your employment.
7.3.1 If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, John Alison Land & Research Ltd understands that you may feel worried about potential repercussions. John Alison Land & Research Ltd will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.
7.3.2 John Alison Land & Research Ltd will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.
7.3.3 Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.
7.3.4 If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform the Managing Director immediately.
8. Training and communication
8.1 John Alison Land & Research Ltd will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy.
8.2 John Alison Land & Research Ltd, anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.
9. Record keeping
9.1 John Alison Land & Research Ltd keeps 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.
10. Monitoring and reviewing
10.1 John Alison Land & Research Ltd, Board of Directors 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.
10.3 Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the Managing Director.
10.4 This policy does not form part of an employee’s contract of employment and John Alison Land & Research Ltd may amend it at any time so to improve its effectiveness at combatting bribery and corruption.