Anti-bribery Policy

MESSAGE FROM THE CHIEF EXECUTIVE:

“At John Hogg we are committed to running our business legally and ethically. Our Code of Ethics outlines the behaviour we uphold as a company to ensure that we maintain the highest standards of honesty and integrity. It underpins everything we do.
We are proud of the way we do business and do not tolerate, permit, or engage in bribery, corruption, improper payments, or unethical practices of any kind, anywhere in the world.

We have introduced our anti-bribery policy to reinforce this stance and to give clear guidance to our employees and business partners, so that, when they carry out our business, their behaviour is beyond reproach.”

William Webb
Chief Executive

1. ABOUT THIS POLICY

This policy sets out what we must do to help prevent bribery in all its forms. A bribe may include any payment, gift or benefit that is offered with the purpose of influencing a decision in order to gain a commercial or personal advantage.

Bribes usually take the form of improper payments or personal ‘commissions’.  They can, however, take on many different shapes and forms, such as tickets for major sporting events or political donations.

2. WHO MUST COMPLY WITH THIS POLICY

This policy is mandatory for all of our employees and should act as a clear guide to all the agents, distributors, suppliers, contractors and consultants working on our behalf anywhere in the world, collectively known in this policy as business partners.

It is important that you take time to familiarise yourself with this policy and comply with it. 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. Any failure to comply with this policy will be treated seriously and may result in disciplinary action.

3. HOW TO COMPLY

You must read and abide by the terms of this policy together with our Code of Ethics. Training will also be provided for all employees, relevant to their role in the company.

4. WHAT HAPPENS IF YOU DON’T COMPLY

For employees:
Any bribery, in whatever form is unacceptable and we will consider taking 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 can result in a fine and/or up to a maximum of 10 years imprisonment.

For John Hogg:
A breach of this policy by an employee or business partner could result in criminal liability for the company under the Bribery Act. An offence under the Act can result in the business being fined, leading to negative publicity and damage to the company’s reputation.

5. WHAT YOU CANNOT DO

Prohibited Behaviour
The following conduct is absolutely prohibited under this policy:

  • Making unofficial payments to government officials to facilitate a routine procedure.
  • Making improper or undisclosed payments to any third party to open doors or make connections for us.
  • Appointing any third party to act on John Hogg’s behalf when you know, or have reason to believe, they have engaged or are likely to engage in corrupt or unlawful conduct including any breach of the Bribery Act or the equivalent laws of another country.

Facilitation Payments and Kickbacks
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 action by a 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.

6. GIFTS AND HOSPITALITY

This policy does not prohibit the giving and receiving of hospitality, subject to the following key points:

  • Gifts are given and received in the company’s and not the employee’s name.
  • The total value of the gift does not exceed £30.
  • The gift does not include cash, gift certificates or vouchers.
  • Any gift to or from government officials or political parties is approved in advance by a Director.
  • Any gifts or hospitality received or given should be recorded as an attachment to your business expenses claim.
  • Gifts or hospitality received as a reward, inducement or encouragement for preferential treatment are strictly prohibited.
  • John Hogg employees’ actions must be able to withstand scrutiny and must not cause embarrassment to the company, the individual or any third party.

7. POLITICAL AND CHARITABLE DONATIONS

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 Managing Director.

8. SPEAKING UP

Any employee who is concerned about any form of improper action or malpractice must raise their concerns as soon as possible with their line manager. We believe that it is essential that all employees feel able to raise genuine matters of concern. In the event they feel they are unable to discuss issues with their line manager, or that their line manager is unable to resolve the issues raised, then individuals are encouraged to discuss the matter in strictest confidence with either a director or the company secretary. A list of potential areas of concern, or ‘red flags’, is contained in the appendix to this policy, this is provided by way of example and is not an exhaustive list.

9. POLICY COMPLIANCE, MONITORING AND REVIEW

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 the employee’s contract of employment and can be amended at any time.

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