Anti-Bribery Statement

As a Company Jennings maintains relationships with many organisations and individuals who could be in a position to exert influence over decisions that affect the interests of the Jennings Group. We operate a zero tolerance approach to the making or receiving of bribes or corrupt payments, in any form. This type of conduct is absolutely prohibited whether committed by employees or anyone else acting on the Company’s behalf.

What is a Bribe?

A bribe is a financial or other advantage offered or given:

  • To anyone to persuade them to or reward them for performing their duties improperly or;
  • To any public official with the intention of influencing the official in the performance of their duties.

It is unacceptable to:

  • Give or offer a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
  • Give or offer a payment, gift or hospitality to a government official/agent to facilitate or expedite a routine procedure;
  • Accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;
  • Accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided in return;
  • Retaliate against or threaten a person who has refused to commit a bribery offence or who has raised concerns under this policy.

Any employee who fails to comply with this policy may be subject to disciplinary action and may also leave themselves open to a criminal prosecution under the Bribery Act 2010.

Gifts and Hospitality

This policy does not prohibit giving and receiving promotional gifts of low value and normal and appropriate hospitality. However, in certain circumstances gifts and hospitality may amount to bribery and all employees must comply strictly with Jennings policy. You must tell us about any gifts or hospitality you receive. You will not provide gifts or hospitality with the intention of persuading anyone to act improperly or to influence a public official in the performance of their duties.

Charitable Donations

Each year Jennings chooses a registered charity that it will support as well as the Emaan Foundation. At no time would charitable donations be made with the purpose of gaining any commercial advantage. Raising Concerns

Jennings aims to conduct business with the highest standards of ethics, honesty and integrity. Any employee concerned about any improper action or wrongdoing by either another employee or stakeholder should report the matter to the HR Department.