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For the purposes of this Code, "corruption" includes bribery, extortion, fraud, deception, collusion, cartels, abuse of power, embezzlement, trading in influence and similar criminal activity.
Corruption inhibits economic growth, is damaging to business, and may result in criminal and civil liability and penalties for organisations and individuals.
Johnson Tiles prohibits its directors, officers and employees, and those of its branch offices which it controls, from engaging in any form of corruption in relation to Johnson Tiles business and affairs.
Specifically such directors, officers and employees should:
a) Act at all times honestly and without deception
b) Not knowingly or recklessly do any of the following, or participate in any activity which involves any of the following:
Offer, give, demand or accept any bribe or other improper advantage.
Participate in any dishonest or deceptive activity, including in relation to any selection, certification, approval or management process.
Provide, conceal, or approve work, materials, equipment or services which are not of the quality and quantity required under contract.
Provide false, inaccurate or misleading information.
Dishonestly withhold information.
Make or submit false, inaccurate, misleading or exaggerated records, invoices, claims, applications for variations or extensions of time, or requests for payment.
Dishonestly refuse or fail to approve, or delay in approving, work, materials, equipment, services, invoices, claims, applications for variations or extensions of time, or requests for payment.
Dishonestly refuse or fail to pay, or delay in paying, sums due. |
c) Any director or officer or others having management responsibility within Johnson Tiles should in addition to the above:
Not instruct, authorise or condone, expressly or impliedly any corrupt activity;
Make proper enquiries regarding any suspicion of corruption which becomes apparent;
Take reasonable preventative measures to stop corruption for which Johnson Tiles may be liable;
Report any suspicion of corruption to the Board of Directors and to the officer responsible for compliance with Johnson Tiles anti corruption programme
Johnson Tiles will use all reasonable endeavours to conduct its business and affairs so as to ensure that it does not engage in or facilitate any form of corruption.
In order to minimise the opportunity for corruption a policy has been adopted for political and charitable donations and the provision of gifts or hospitality to any person or organisation a copy of which is attached.
A facilitation payment is a payment made to encourage a person to carry out his duty. Even though facilitation payments are in many cases obtained by way of extortion, they are nevertheless a form of corruption and the making or receiving of a facilitation payment is a criminal offence in many jurisdictions. Johnson Tiles prohibits the making of any facilitation payment unless permitted under local law, save in circumstances where the personal safety of any person is endangered.
Johnson Tiles will adopt a corporate anti-corruption programme to enable it to comply with this Code. Johnson Tiles will properly implement this programme within the next three months and ensure that it is reviewed on an annual basis to warrant that it is operating effectively.
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