Code of Ethical Conduct

Introduction

The JLT Group is committed to ensuring the prevention of bribery in all parts of its business and to conducting all of its activities in an honest manner.

We expect all of the business counterparties who we work with to share this commitment and to promote the same high standards with their own suppliers and partners. This code of conduct (the "Code") sets out in detail how we expect our business counterparties who work with us to behave and what to do if confronted with issues of bribery or corruption. The Code is based on statutory requirements including the Bribery Act 2010.

The Code

  • The Code covers commitments against corrupt practices and commitments to ethical standards.
  • We expect that each counterparty shall:
  • work to the highest standards of professional competence and integrity;
  • refuse to accept or give gifts, hospitality or entertainment which might affect, or which are intended to affect, business judgement;
  • accept hospitality offered in a business context only, and only if offered on a reciprocal basis;
  • commit to complying with all applicable anti-bribery and anti-corruption laws, including the Bribery Act 2010;
  • keep confidential all aspects of its relationship with the JLT Group;
  • ensure that its staff do not offer or make any bribe, unorthodox or unauthorised payment or inducement of any kind to anyone;
  • maintain a working environment where staff can make reports of breaches of the Code in confidence and without fear of reprisals;
  • act with integrity and without thought or actions involving bribery and corruption and will, where appropriate, include clauses to this effect in contracts offered to any suppliers and partners;
  • ensure that every employee may report allegations of bribery or corruption without fear of retaliation;
  • not make direct or indirect contributions to political parties, organisations or individuals engaged in politics, as a way of obtaining advantage in business transactions;
  • ensure that charitable contributions and sponsorships are not used as a subterfuge for bribery;
  • ensure that no employee will suffer demotion, penalty, or other adverse consequences for refusing to pay bribes, even if such refusal may result in loss of business;
  • establish and maintain an effective system of internal controls to counter bribery, comprising financial and organisational checks and balances over accounting and record keeping practices and other business processes related to the Code; and
  • establish feedback mechanisms and other internal processes supporting the continuous improvement of the Code.

Monitoring and Compliance

This Code is a mandatory requirement for working with the JLT Group. From time to time the JLT Group may conduct assessments to ensure the Code is being upheld.

Group Compliance

Jardine Lloyd Thompson Group plc

June 2011