Last updated: 18 August 2025
1. Purpose & Scope
This policy affirms J3st Solutions’ commitment to integrity, fairness, and transparency. It prevents bribery, corruption, and improper influence in dealings with customers, partners, and Government Officials. It applies to all employees, contractors, directors, agents, and representatives globally.
2. Guiding Principles
- Zero tolerance for bribery, corruption, and unethical practices.
- Compliance with applicable anti‑corruption and trade laws (e.g., UK Bribery Act, U.S. FCPA where applicable).
- Integrity in business decisions; no improper personal gain.
3. Prohibited Practices
- No offering, promising, giving, or authorizing bribes, kickbacks, or improper payments to obtain or retain business.
- No requesting or accepting anything of value that could improperly influence duties.
- No use of third parties to circumvent this policy.
4. Gifts, Hospitality & Entertainment
- Permitted: Low‑value, customary business courtesies that are legal, infrequent, and transparent.
- Prohibited: Cash/cash equivalents, lavish entertainment, or anything creating a sense of obligation.
- Government Officials: Prior written approval required for any gift, meal, or hospitality, regardless of value.
- Transparency: All items must be recorded accurately in expense reports.
5. Commissions, Agents & Third Parties
- Due diligence and written agreements are mandatory before engagement.
- Compensation must be reasonable and tied to legitimate services.
- No facilitation ("grease") payments to expedite routine actions.
6. Conflicts of Interest
Employees must disclose any personal or financial interests that could influence, or appear to influence, their professional judgment.
7. Record‑Keeping & Transparency
- All transactions must be fully and accurately recorded in the company’s books and records.
- False, misleading, or off‑the‑books entries are prohibited.
8. Reporting & Accountability
- Duty to report suspected violations via the channels above.
- Strict non‑retaliation for good‑faith reporting.
- Violations may lead to disciplinary action and legal consequences.
9. Training & Awareness
Employees and relevant third parties receive periodic training on anti‑corruption compliance and business ethics.
10. Review & Oversight
This policy is reviewed annually by senior management and updated as required by law and best practice.