At John Hogg we are committed to running our business both legally and ethically. Our Code of Conduct outlines the behaviours that John Hogg upholds as a Company, to ensure that the highest standards of honesty and integrity are maintained. We are proud of the way we do business and want to ensure that integrity underpins everything we do.
We specifically do not tolerate, permit, or engage in bribery, corruption, improper payments, or unethical practices of any kind in our business dealings, anywhere in the world.
We have introduced this policy to reinforce our stance on bribery and corruption and to give clear guidance to our employees and business partners in order that they may do the right thing when they are carrying out our business.
William Webb, CEO & Chair of the Board
This policy sets out what we all must do to help prevent all forms of bribery and corruption.
Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
Bribery includes offering, promising, giving, accepting or seeking a bribe.
All forms of bribery and corruption are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with your manager or a Director.
This policy is mandatory for all of our employees and acts as a clear guide to all of the agents, distributors, suppliers, contractors, consultants and others working with us or on our behalf anywhere in the world, collectively referred to in this policy as “business partners”.
It is important that you take time to familiarise yourself with this policy and comply with its provisions.
The prevention, detection and reporting of bribery in any form is the responsibility of all John Hogg employees.
The channels for reporting any suspicion of bribery are detailed later in this policy.
We take a zero-tolerance approach to bribery and corruption and any failure to comply with this policy will be treated seriously and will result in disciplinary action and/or the termination of your contract with us.
You must read and abide by the terms of this policy together with our Code of Conduct. Training will also be provided for all employees where this subject is relevant to their role in the Company.
Bribery and corruption, in whatever form is unacceptable and we will take disciplinary action against anyone who fails to comply with this policy up to and including dismissal. Failure to comply with the policy may also leave you open to a criminal prosecution. An offence under the Bribery Act 2010 can result in a fine and/or up to a maximum of 10 years imprisonment.
A breach of this policy by an employee or business partner could result in criminal liability for the Company under the Bribery Act 2010. An offence under the Act can result in the business being fined, which would lead to negative publicity and reputational damage as well as impacting the Company financially.
We do not make and will not accept facilitation payments or kickbacks of any kind.
Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government official. Kickbacks are typically payments made in return for a business favour or advantage.
If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided and ensure that you obtain a receipt that details the reason for the payment.
Where gifts are accepted we encourage employees to submit them to the Company Christmas Raffle or share within the department. Where this is not possible and the gift is consumed by the employee then it should be marked as such on the Register.
Gifts or hospitality received as a reward, inducement or encouragement for preferential treatment are strictly prohibited and all John Hogg employees’ actions must be able to withstand scrutiny and not cause embarrassment to the Company, the individual or any third party. If the employee is in any doubt they should contact their Line Manager before accepting the gift or hospitality.
We do not make contributions to political parties and we only make charitable donations that are legal and ethical under local laws and practices and which have been approved in advance by the CEO.
Any employee who is concerned about any form of improper action or malpractice must raise their concerns as soon as possible with their manager.
There will be no retaliation from any concern raised in good faith – we believe that it is essential that all employees feel able to raise genuine matters of concern. In the event that they feel they are unable to resolve issues raised with their manager, then the individual is encouraged to discuss the matter in strictest confidence with either one of the Directors or the Company Secretary.
A list of potential areas of concern – ‘red flags’ is contained in the appendix to this policy, these are provided by way of example and this is not an exhaustive list.
The Board has overall responsibility for ensuring that the Company maintains adequate procedures to prevent bribery and will monitor and review the effectiveness of this policy on an ongoing basis.
This policy does not form part of any employee’s Contract of Employment and can be amended at any time.
Further information on the Anti-Bribery Act can be found by following the links below:
The following is a list of possible red flags that may arise during the course of you working for us and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.