OUR ANT-CORRUPTION & BRIBERY POLICY is designed to help Johnston Cave Associates, clients and contractors comply with the provisions of the Bribery Act 2010.
JCA take a zero-tolerance approach to bribery and corruption. We are committed to acting fairly, professionally, and with integrity in all our business dealings and relationships wherever we operate.
All individuals are expected to comply with the obligations of the Bribery Act 2010. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for or associated with Johnston Cave or under our control.
All individuals are required to avoid any activity that might lead to, or suggest, a breach of this policy.
• JCA require that staff must notify their Manager or HR Team as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future.
• A bribe is an inducement, financial or other advantage or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage or to induce a person to perform a function or activity improperly or to reward them for doing so.
• This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.
• Staff are not permitted to accept or offer any gifts, expenses or hospitality which might influence or be seen to influence a contractual or material matter. As a consequence of our business activities employees may well be offered gifts and/or offers of hospitality. These may not be accepted if the value exceds £20 as such gifts could be perceived as influencing judgment in dealings with any contractor, supplier, customer or other third-party doing business with Johnston Cave Associates or any associated company. No JCA team member must ever accept any gift of cash, cash equivalent, and shares of stock, options or an opportunity to participate in an initial public offering of security. Any such offers should be brought to the attention of JCA senior management.
• The JCA Directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations and that all those under our control or associated with Johnston Cave Associates complies with it. A breach of this policy is treated very seriously and may lead to disciplinary action being taken against up to and including summary dismissal.