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.