Please find below a summary of the key topics in the Group's Anti-Bribery Corruption policy.
Bribes can take many forms, e.g.
- Direct or indirect promise, offering or authorisation of anything of value
- Under-pricing or over-payment
- A kickback disguised as third party commission
- Giving donations or aid in order to exert improper influence
- Benefits provided to others such as training funds, employment for relatives, or travel
- Providing, soliciting, authorising or offering a bribe; or
- Engaging in any other inappropriate practice intended to improperly influence a person’s conduct in executing a personal or public duty
Employees are prohibited from engaging in any activity, with any party, that might be construed as corrupt. This is not limited to situations involving personal gain but extends to improperly securing or retaining business for the JLT Group.
Employees must not:
- Offer, suggest or authorise a payment, service or any other benefit that may be seen as a bribe
- Accept or solicit a bribe
- Use or permit another party to conduct any of the above
- Process funds suspected of being the proceeds of bribery and corruption
- Assist in the concealment of any corrupt activity
- Knowingly establish or maintain any process, procedure or mechanism for the purpose of making illegal payments
- Make facilitation payments
- Understand and adhere to procedures that minimise bribery and corruption risk including: Know Your Customer (‘KYC’), Third Party Payments and the Group Gifts and Entertainment Policy.
- Be aware there are policy requirements around Charity & Sponsorship e.g.
- Appropriate checks on the organisation seeking sponsorship must be conducted to ensure that it is legitimate
- Where a public official or politically exposed person (PEP) is involved, consent should be sought from Group Risk and Compliance / Financial Crime Prevention Team
- Keep accurate records in terms of Gifts & Entertainment, donations and sponsorships etc.
- Complete Anti-Bribery & Corruption training when they join JLT, and as required thereafter.
- Seek clarification from their Risk & Compliance representative if they are unclear on any aspect of the Anti-bribery and Corruption Policy.
- Where they suspect that an act of bribery and corruption has occurred, report the matter to their local nominated person or to the Group Head of Financial Crime.
Senior Management must ensure there are appropriate Anti-Bribery & Corruption controls operating effectively, as set out in the Policy requirements, that relate to:
- Employment e.g. vetting
- Third Parties e.g. Third Party Payment Procedures
- Entities where JLT has a shareholding and management control e.g. systems and controls to ensure they meet the requirements of the Anti-bribery & Corruption Policy
- Entities where JLT has a shareholding but does not have management control e.g. attestation that the entity has not been subject to allegation, investigation, charges or conviction relating to bribery and corruption offences and Anti-Bribery & Corruption clauses are included in contracts
- Key Suppliers e.g. inclusion of Anti-bribery & Corruption clauses in contracts relating to the Group’s key suppliers
- Anti-Bribery and Corruption Contract Terms e.g. inclusion of Anti-bribery & Corruption clause with business counterparties
- Acquisitions - Bribery and Corruption Due Diligence e.g. appropriate bribery and corruption research and analysis as part of the due diligence process prior to acquisition