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Anti Bribery Act

Dear JFM Shipping Staff,

 

In the UK, the Bribery Act 2010 came into force in July 2011. This applies to the bribing of foreign public officials abroad as well as in UK waters. JFM Shipping has always been committed to a strict policy against bribery, whenever and wherever we do business. Bribery is a serious criminal offence in almost all jurisdictions in which we do business and is morally wrong. Conviction usually results in serious penalties for employees and their employers.

 

Given the importance of the issue to JFM Shipping, we hereby communicate our policy which must be absolutely clear to everyone who works for us or with us.

 

Our policy is:

  • Not to bribe, accept bribes or do business with anyone else who bribes;
  • To treat all dishonest, unethical or unfair behavior of any kind by anyone in our organization as a potentially serious disciplinary offence:
  • Only to do business with service suppliers and other business partners who have a similar policy of complying with anti-bribery laws and acting ethically.

 

This can be distilled into one simple rule:

JFM SHIPPING STAFF AND BUSINESS PARTNERS DO NOT OFFER OR ACCEPT BRIBES.

 

The law is quite complex and varies from country to country but we aim to comply with the highest current standards. In summary, we must not:

  • directly or indirectly offer, promise or give bribes to anyone to influence business decisions;
  • solicit, agree to receive or accept a bribe;
  • bribe public officials to obtain or retain business;
  • offer hospitality to government official or employees of private companies, except for genuine corporate hospitality that is reasonable and proportionate, and transparent;
  • make 'facilitation payments' to enable or speed up routine official processes; or
  • consent, or turn a blind eye, to any employee, temporary agency staff or business partner doing any of the above acts (or proposing to do so).

 

Ask if you are not sure
If you are not sure if a particular transaction is lawful or not, please do not hesitate to discuss it with the Management in advance. Similarly, if you suspect that bribery may have occurred please report it immediately so that appropriate remedial action may be taken.

 

Bribery – the only exceptions
Corporate Hospitality


Always be cautious when giving or receiving gifts to or from public officials or other business contacts or entertaining or being entertained by them.
The law is not meant to prohibit hospitality where it is an established and important part of doing business, is reasonable and proportionate and is done openly and transparently to seal or maintain good business relationships.

 

Our policy allows you to:

  • have drinks, take people out to lunch or dinner, invite them to sporting, musical or other such events, to home or offer similar hospitality with a corporate objective worth up to a maximum of EUR 100 per person.
  • give a token gift or present on a special occasion (such as at an inaugural call), on a festival or at another special time (e.g. a gift at Christmas or New Year)

 

Facilitation Payments
DO NOT MAKE "FACILITATION PAYMENTS". It is illegal.

These include money, cigarettes, bottles of whisky, etc unofficially paid to low-grade public official to get the job done or done quicker.

If asked for something 'under the table', you should always answer "NO".

The only exception is:

  • You can pay the official fee for an officially recognized "fast-track" process available to all

But you must:

  • Say you are making the payment under protest and record the incident as soon as possible

 

Duty to Report
If you know or suspect somebody is acting dishonestly or contrary to our policy or have other concerns about possible bribery or corruption within JFM Shipping Organization or third parties we deal with, you must report it immediately and in confidence to the Management.


We should all be proud of our reputation and I want our reputation to be that of an ethical company doing business in an ethical way. I strongly urge you to make the effort to understand and put into practice our policy for the benefit of the company and the shipping community as a whole.

 

Yours sincerely,

João Welsh
Managing Director

 

You can see the original document here: Anti_Bribery_Act.pdf