Forced Labour Policy
Jennings computer services ltd holds a zero-tolerance approach for human trafficking, slavery or Forced Labour, which the ILO has defined as, "all work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily," in the ILO Forced Labour Convention, 1930 (No. 29). All Business Partners are required to comply with local and international laws referring to human trafficking and modern slavery. Forced Labour risks are complex, often hidden and difficult to identify. Jennings Computer Services Ltd nevertheless strives to advance efforts to understand such risks and will uphold the UN Guiding Principles on Business and Human Rights by addressing adverse impacts and mitigating instances of Forced Labour throughout our Supply Chain tiers, requiring our Business Partners, direct or subcontractors, to uphold Jennings Computer Services Ltd's Forced Labour Policy.
Abuse of Vulnerability
Employers shall not take advantage of any vulnerable worker, to impose pressure to provide involuntary labour or economically compromise the worker, and shall acknowledge and grant protections of vulnerable people.
Vulnerable Workers - The U.K. Government defines vulnerable workers as those at risk of having their workplace entitlements denied, and who lack the capacity or means to secure them. These could include those unable to represent themselves, or without relevant language or communication skills, or in a compromised financial situation reducing resilience to represent themselves. Vulnerable Workers can include women, new and expectant mothers, Young Workers, older workers, workers with disabilities, migrant workers, agency and temporary workers, homeworkers, or those new to a job developing skills to maintain their income. Vulnerability increases if there are multiple dependencies on the employer, such as pay with provisions of housing and food, or whole family work dependence on a single employer.
Deception
Employers shall not use deceptive employment practices, and are required to adopt responsible recruitment protocols, including providing "return home" packages to migrant workers hired. Employers shall deliver on verbally agreed or written terms of employment, which shall be clearly communicated in the native language of workers at the first instance and throughout employment.
Restriction of Movement
Workers shall be free to enter employment and free to leave their job or employer, without menace of penalty. Employers shall not restrict workers' freedom of movement, nor confine in any way, workers within the workplace, including guaranteeing free access to toilets and drinking water stations, nor in provided accommodation, either during or outside working hours.
Isolation
Workers isolated at the time of recruitment, within the workplace or without easy access to fair employment advisory services are to be considered vulnerable workers, and shall be afforded additional support relevant to their remote situation or workplace, and monitored appropriately. Workers in informal or unorganised enterprises, at home, or in remote geographies shall be considered vulnerable to Forced Labour.
Physical, Sexual, and Psychological Coercion, Intimidation and Threats
Jennings Computer Services Ltd does not tolerate abuse, intimidation or threats to workers throughout our value chain. Employers shall arrange Right to Work papers for all employees in the employment destination country, where necessary. Threats to revoke Right to Work with intent to coerce workers are considered an instrument of Forced Labour.
Abusive Working
Fair working conditions are provided by the employer.
Pay
Employers shall pay wages directly to workers, in full and on time, according to local laws, including for all overtime hours, with documented wages. Wages shall not be systematically and deliberately withheld as a means to compel a worker to remain. There shall be no Deceptive Wage Practices employed, and all social insurances and taxes withheld from pay must be promptly paid to the local authorities to afford all workers equal rights to benefits. No excessive deductions, interest or false or inflated prices shall be charged for essential services or necessities for workers, and coercion into induced indebtedness shall be avoided.
Human Rights Policy
As a fundamental operating principle, we strive to respect human rights wherever we do business. We are committed to doing no harm, to avoiding infringing on the human rights of others, and to addressing adverse human rights impacts where they may be caused, contributed by, or linked to our activities.
We will:
• Seek to avoid causing or contributing to adverse human rights impacts through our own activities, and address such impacts if they do occur in a timely and appropriate manner;
• Seek to prevent or mitigate adverse human rights impacts that are directly related to our operations, products and services through our business relationships;
• If we identify that we have caused or contributed to adverse human rights impacts, provide for or cooperate in their remediation through legitimate processes; and,
• Continue to look for ways to support the promotion of human rights within our operations and our sphere of influence.
Our commitment is guided by the principles set forth in laws of the United Kingdom governing human rights, as well as in the following international standards:
• Universal Declaration of Human Rights;
• International Covenant on Civil and Political Rights;
• International Covenant on Economic, Social and Cultural Rights;
• International Labour Organization’s (ILO’s) Declaration on Fundamental Principles and Rights at Work;
• Guidelines for Multinational Enterprises of the Organization for Economic Cooperation and Development (OECD);
• United Nations (UN) Guiding Principles on Business and Human Rights;
• Voluntary Principles on Security and Human Rights (VPSHR) (relevant for mining companies).
Where national law and international human rights standards differ, we will follow the higher standard; where they are in conflict, we will adhere to national law, while seeking ways to respect international human rights to the greatest extent possible.
Assessing human rights risks and impacts
We recognise that we must take steps to identify and address any actual or potential adverse impacts with which we may be involved whether directly or indirectly through our own activities or our business relationships. We manage these risks by integrating the responses to our due diligence into our policies and internal systems, acting on the findings, tracking our actions, and communicating with our partners about how we address impacts.
Due diligence process to identify, prevent, mitigate, account and remediate human rights impacts
We understand that human rights due diligence is an ongoing process that requires particular attention at certain stages in our business activities, such as when we form new partnerships or our operating conditions change, as these changes may create new potential or actual impacts on human rights. We understand that this means that we must put in place additional due diligence measures to assess these risks and address them effectively, where appropriate, using our leverage to work either in one-to-one relationships or in broad-based partnerships. We recognise the importance of dialogue with our employees, workers and external stakeholders who are or could potentially be impacted by our actions. We pay particular attention to individuals or groups who may be at greater risk of negative human rights impacts due to their vulnerability or marginalisation and recognise that women and men may face different risks.
Remedy
We place importance on the provision of effective remedy wherever human rights impacts occur through company-based grievance mechanisms. We continue to build the awareness and knowledge of our employees and workers on human rights, including labour rights, by encouraging them to speak up, without retribution, about any concerns they may have, including through our grievance channels. We are committed to increasing the capacity of our management to effectively identify and respond to concerns.
Monitoring human rights impacts
We seek to establish relationships with entities that share the same principles and values. We promote human rights awareness and respect along our value chain, including the adoption of legal contractual clauses. We will seek to monitor our human rights performance and the performance of our suppliers through audits.
Environmental Policy
Jennings Computer Services Ltd is committed to leading the industry in minimising the impact of its activities on the environment.
The key points of its strategy to achieve this are:
• Minimise waste by evaluating operations and ensuring they are as efficient as possible.
• Minimise toxic emissions through the selection and use of its fleet and the source of its power requirement.
• Actively promote recycling both internally and amongst its customers, suppliers and vendors.
• Source and promote a product range to minimise the environmental impact of both production and distribution.
• Meet or exceed all the environmental legislation that relates to the Company.
• Minimise greenhouse gas emissions generated by our activities.
Environmental Improvement Plan
Jennings Computer Services Ltd is committed minimising the impact of its activities on the environment.
The key points of its strategy to achieve this are:
• Reduce energy consumption by replacing normal light bulbs with LED where possible.
• Reduce energy consumption by ensuring unnecessary computer equipment is switched off or put in sleep mode when not in use.
• Actively promote recycling both internally and amongst our customers, suppliers and vendors.
• Ensure all electrical equipment implemented is at least A+ rated
• Reduce gas usage through better insulation, responsible usage of modern efficient digital thermostat and regular servicing of gas boiler.
• Meet or exceed all the environmental legislation that relates to the Company.
• Minimise greenhouse gas emissions by encouraging staff to car share or cycle to and from work where possible.
• Staff awareness that printing of documents only when deemed necessary
• Ensure WEEE directive compliance at all times
• Recycle all paper and waste where possible
• Be mindful of the environment at all times and minimise waste wherever possible
Slavery Prevention Statement
This modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015. Jennings Computer Services Ltd are committed to preventing slavery and human trafficking violations in its own operations, its supply chain and its products. We have zero tolerance towards slavery and require our supply to comply with our values.
Due Diligence
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:
Our due diligence procedures aim to:
Identify and action potential risks in our business and supply chains
Monitor potential risks in our business and supply chains
Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
Risk and Compliance
Due to the nature of our business and our suppliers, we consider that we operate in a low-risk environment.
Where there is evidence of failure to comply with our policies within our supply chain we will instigate further discussion with that suppliers management to discuss a resolution or ultimately a change of supplier.
Business Continuity Plan
Scope and objectives
The purpose of this Business Continuity Plan is to have an executable plan in case of an emergency situation to maintain delivery of critical activities and services during an incident.
Recovery plan
Response Personnel
The recovery team is responsible for maintaining business continuity and acting upon this plan to ensure minimal business disruption.
Team Leader.
Karl Jennings
Plan Activation
This plan will be activated in response to an incident causing significant disruption to normal service delivery/business and/or the delivery of key/critical activities.
Eg:
Loss of key staff or skills above normal levels of absenteeism due to illness
Loss of critical systems eg ICT failure
Denial of access, or damage to facilities eg loss of premises through fire
Process for Activation
Incident occurs.
Assess the nature, scale & impact of the disruption.
Does incident have significant impact on critical activities?
If YES, activate plan and continuity arrangements, notify relevant people & take action to manage the incident.
If NO, do not activate continuity arrangements.
Incident Management
Protect the safety of staff, visitors and wider community
Protect vital assets eg equipment, data, reputation etc
Ensure necessary communication takes place
The following actions will be taken to protect the immediate safety to staff, visitors and the public:-
Evacuate the building if necessary
Ensure all staff report to the assembly point
Call emergency services as appropriate
Check that all staff or visitors have been evacuated from the building. Consider safety of all staff and visitors as a priority.
Record details of any injuries
Assess impact of the impact
If issue is due to reduced staffing levels, hold emergency meeting to discuss
Communication Actions
In the event of an incident and this plan being activated, the following people should be contacted.
Karl Jennings
Mike Jennings
Susie Martin
Margaret Moorhouse
Actions to support Business Continuity
Recover vital assets / equipment to enable delivery of critical activities
Assess the key priorities for the remainder of the working day and take relevant action
Inform staff what is required of them
Publicise the interim arrangements for delivery of critical activites
Actions to support Recovery and Resumption
Take any salvage/asset recovery actions that are appropriate
Eg remove any equipment, furniture, records etc that are at risk of damage.
Continue to log all expenditure incurred as a result of the incident.
Seek advice from insurance company
Critical Activities
Ascertain immediate priorities, dependant of the scale of the issue.
Arrange temporary business accommodation if necessary
Restore business critical systems & communications
Seek further advice from insurance company
Ensure and maintain staff safety and well being
Assign staff to key tasks as required
Additional Activities & Resumption
Agree and plan the actions required to enable recovery and resumption of normal working practises
Continue to log all expenditure incurred as a result of the incident
Respond to any support needs of staff
Carry out a debrief of the incident and complete an incident report
Child labour policy
Jennings Computer Services Ltd is committed to respecting human and subsequently children‘s rights. We strongly believe children should grow up loved, cherished, and able to enjoy their childhood in a strong caring community. Jennings Computer Services Ltd will not knowingly tolerate child labour activities in any areas of its operations, including its supply chain.
Terms & Definitions
Minimum working age
According to the ILO, no person shall work at an age younger than 15, unless exceptions recognised by the ILO apply, or national laws apply, whichever is most stringent.
Juvenile worker
According to the ILO, a ‘juvenile worker’ is defined as a worker who has reached the minimum working age but is not yet 18 years old.
Child labour
According to the ILO, ‘child labour’ is defined as work that ‘deprives children of their childhood, their potential and their dignity, and that is harmful to physical and mental development’.
This includes:
• Any child below the minimum working age engaged in non-light work, and
• Juvenile workers engaged in hazardous work.
Light work
In compliance with the ILO conventions, UNCRC, national laws and regulations, Jennings Computer Services Ltd may allow the work of children aged 16 years (unless exceptions by the ILO or national laws apply, whichever is most stringent). The work is only permitted if it happens outside of school hours, falls into the category of light work and fulfils the following criteria or as part of a work experience scheme.
It must be age-appropriate and must not threaten the child’s health or development.
It must be in line with children‘s rights. The work should not negatively impact the development and education of the child. It should not compromise their attendance at school or time dedicated to homework, playtime and sleeping time, their participation in vocational orientation or training programmes.
It must not take place on a continuous basis (e.g. it should only take place after school or during holidays) and must take place under none exploitive conditions.
Equality, diversity and inclusion policy
Jennings Computer Services Ltd is committed to encouraging equality, diversity and inclusion among our workforce, and eliminating unlawful discrimination.
The aim is for our workforce to be truly representative of all sections of society and our customers, and for each employee to feel respected and able to give their best.
The organisation - in providing goods and/or services and/or facilities - is also committed against unlawful discrimination of customers or the public.
Our policy’s purpose
This policy’s purpose is to:
1. Provide equality, fairness and respect for all in our employment, whether temporary, part-time or full-time
2. Not unlawfully discriminate because of the Equality Act 2010 protected characteristics of:
• age
• disability
• gender reassignment
• marriage and civil partnership
• pregnancy and maternity
• race (including colour, nationality, and ethnic or national origin)
• religion or belief
• sex
• sexual orientation
3. Oppose and avoid all forms of unlawful discrimination. This includes in:
• pay and benefits
• terms and conditions of employment
• dealing with grievances and discipline
• dismissal
• redundancy
• leave for parents
• requests for flexible working
• selection for employment, promotion, training or other developmental opportunities
Our commitments
The organisation commits to:
1. Encourage equality, diversity and inclusion in the workplace as they are good practice and make business sense
2. Create a working environment free of bullying, harassment, victimisation and unlawful discrimination, promoting dignity and respect for all, and where individual differences and the contributions of all staff are recognised and valued.
This commitment includes training managers and all other employees about their rights and responsibilities under the equality, diversity and inclusion policy. Responsibilities include staff conducting themselves to help the organisation provide equal opportunities in employment, and prevent bullying, harassment, victimisation and unlawful discrimination.
All staff should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their employment, against fellow employees, customers, suppliers and the public
3. Take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, customers, suppliers, visitors, the public and any others in the course of the organisation’s work activities.
Such acts will be dealt with as misconduct under the organisation’s grievance and/or disciplinary procedures, and appropriate action will be taken. Particularly serious complaints could amount to gross misconduct and lead to dismissal without notice.
Further, sexual harassment may amount to both an employment rights matter and a criminal matter, such as in sexual assault allegations. In addition, harassment under the Protection from Harassment Act 1997 – which is not limited to circumstances where harassment relates to a protected characteristic – is a criminal offence.
4. Make opportunities for training, development and progress available to all staff, who will be helped and encouraged to develop their full potential, so their talents and resources can be fully utilised to maximise the efficiency of the organisation.
5. Make decisions concerning staff being based on merit (apart from in any necessary and limited exemptions and exceptions allowed under the Equality Act).
6. Review employment practices and procedures when necessary to ensure fairness, and also update them and the policy to take account of changes in the law.
7. Monitor the make-up of the workforce regarding information such as age, sex, ethnic background, sexual orientation, religion or belief, and disability in encouraging equality, diversity and inclusion, and in meeting the aims and commitments set out in the equality, diversity and inclusion policy.
Monitoring will also include assessing how the equality, diversity and inclusion policy, and any supporting action plan, are working in practice, reviewing them annually, and considering and taking action to address any issues.
Agreement to follow this policy
The equality, diversity and inclusion policy is fully supported by senior management and has been agreed with trade unions and/or employee representatives.
Our disciplinary and grievance procedures
Details of the organisation’s grievance and disciplinary policies and procedures can be found in the employee handbook This includes with whom an employee should raise a grievance – usually their line manager.
Use of the organisation’s grievance or disciplinary procedures does not affect an employee’s right to make a claim to an employment tribunal within three months of the alleged discrimination.
Information Security Policy
Purpose
Information that’s collected, analysed, stored, communicated and reported upon may be subject to theft, misuse, loss and corruption. Information may be put at risk by poor education and training, and the breach of security controls.
Information security incidents can give rise to embarrassment, financial loss, non-compliance with standards and legislation, as well as possible judgements being made against Jennings Computer Services Ltd.
This high level Information Security Policy sits alongside the ‘Information Risk Management Policy’ and ‘Data Protection Policy’. This is to provide the high-level outline of, and justification for, Jennings Computer Services Ltd’s risk-based information security controls.
Objectives
Jennings Computer Services Ltd’s security objectives are that:
• our information risks are identified, managed and treated according to an agreed risk tolerance
• our authorised users can securely access and share information in order to perform their roles
• our physical, procedural and technical controls balance user experience and security
• our contractual and legal obligations relating to information security are met
• our teaching, research and administrative activity considers information security
• individuals accessing our information are aware of their information security responsibilities
• incidents affecting our information assets are resolved and learnt from to improve our controls
Scope
The Information Security Policy and its supporting controls, processes and procedures apply to all information used at Jennings Computer Services Ltd in all formats. This includes information processed by other organisations in their dealings with Jennings Computer Services Ltd.
The Information Security Policy and its supporting controls, processes and procedures apply to all individuals who have access to Jennings Computer Services Ltd’s information and technologies. This includes external parties that provide information processing services to Jennings Computer Services Ltd.
Compliance monitoring
Compliance with the controls in this policy will be monitored by the Information Security Team, and reported to the Information Governance Board.
Review
A review of this policy will be undertaken by the Jennings Computer Services Ltd This will be annually or as required, and will be approved by Jennings Computer Services Ltd.
Policy Statement
It is Jennings Computer Services Ltd.’s policy to ensure that information is protected from a loss of:
• confidentiality – information will be accessible only to authorised individuals
• integrity – the accuracy and completeness of information will be maintained
• availability – information will be accessible to authorised users and processes when required
Jennings Computer Services Ltd will implement an Information Security Management System based on certified standards as required.
Jennings Computer Services Ltd will adopt a risk-based approach to the application of the following controls:
1. Information security policies
A set of lower-level controls, processes and procedures for information security will be defined, in support of the high-level Information Security Policy and its stated objectives. This suite of supporting documentation will be approved by the office manager, published and communicated to Jennings Computer Services Ltd users and relevant external parties.
2. Organisation of information security
Jennings Computer Services Ltd will define and implement suitable governance arrangements for the management of information security. This will include identification and allocation of security responsibilities, to initiate and control the implementation and operation of information security within Jennings Computer Services Ltd.
3. Human resources security
Jennings Computer Services Ltd’s security policies and expectations for acceptable use will be communicated to all users to ensure that they understand their responsibilities. Information security education and training will be made available to all staff. Poor or inappropriate behaviour will be addressed.
Where practical, security responsibilities will be included in role descriptions, person specifications and personal development plans.
4. Asset management
All assets will be documented and accounted for. This includes:
• information
• software
• electronic information processing equipment
• service utilities
• people
Owners will be identified for all assets and they will be responsible for the maintenance and protection of their assets.
All information assets will be classified according to their legal requirements, business value, criticality and sensitivity. Classification will indicate appropriate handling requirements. All information assets will have a defined retention and disposal schedule.
5. Access control
Access to all information will be controlled and will be driven by business requirements. Access will be granted or arrangements made for users according to their role and the classification of information, only to a level that will allow them to carry out their duties.
A formal user registration and de-registration procedure will be maintained for access to all information systems and services. This will include mandatory authentication methods based on the sensitivity of the information being accessed, and will include consideration of multiple factors as appropriate.
Specific controls will be implemented for users with elevated privileges, to reduce the risk of negligent or deliberate system misuse. The separation of duties will be implemented, where practical.
6. Cryptography
Jennings Computer Services Ltd will provide guidance and tools to ensure proper and effective use of cryptography to protect the confidentiality, authenticity and integrity of information and systems.
7. Physical and environmental security
Information processing facilities are housed in secure areas, physically protected from unauthorised access, damage and interference by defined security perimeters. Layered internal and external security controls will be in place to deter or prevent unauthorised access and protect assets. This includes those that are critical or sensitive, against forcible or hidden attacks.
8. Operations security
Jennings Computer Services Ltd will ensure the correct and secure operations of information processing systems. This will include:
• documented operating procedures
• the use of formal change and capacity management
• controls against malware
• defined use of logging
• vulnerability management
9. Communications security
Jennings Computer Services Ltd will maintain network security controls to ensure the protection of information within its networks. Jennings Computer Services Ltd will also provide the tools and guidance to ensure the secure transfer of information both within its networks and with external entities. This is in line with the classification and handling requirements associated with that information.
10. System acquisition, development and maintenance
Information security requirements will be defined during the development of business requirements for new information systems or changes to existing information systems.
Controls to reduce any risks identified will be implemented where appropriate.
Systems development will be subject to change control and separation of test, development and operational environments.
11. Supplier relationships
Jennings Computer Services Ltd’s information security requirements will be considered when establishing relationships with suppliers, to ensure that assets accessible to suppliers are protected.
Supplier activity will be monitored and audited according to the value of the assets and the associated risks.
12. Information security incident management
Guidance will be available on what constitutes an information security incident and how this should be reported. Actual or suspected breaches of information security must be reported and will be investigated. The appropriate action to correct the breach will be taken, and any learning built into controls.
13. Information security aspects of business continuity management
Jennings Computer Services Ltd will have in place arrangements to protect critical business processes from the effects of major failures of information systems or disasters. This is to ensure their timely recovery in line with documented business needs. This will include appropriate backup routines and built-in resilience.
Business continuity plans must be maintained and tested in support of this policy. Business impact analysis will be undertaken, detailing the consequences of:
• disasters
• security failures
• loss of service
• lack of service availability
14. Compliance
The design, operation, use and management of information systems must comply with all statutory, regulatory and contractual security requirements.
Currently this includes:
• data protection legislation
• the payment card industry standard (PCI-DSS)
• the government’s Prevent strategy
• Jennings Computer Services Ltd’s contractual commitments
Jennings Computer Services Ltd will use a combination of internal and external audits to demonstrate compliance against chosen standards and best practice, including against internal policies and procedures. This will include:
• IT health checks
• gap analyses against documented standards
• internal checks on staff compliance
• returns from Information Asset Owners
Anti Bribery and Anti Corruption Policy
1. What does this policy cover?
1.1 This anti-bribery policy exists to set out the responsibilities of Jennings Computer Services Ltd and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption.
1.2 It also exists to act as a source of information and guidance for those working for Jennings Computer Services Ltd It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.
2. Policy statement
2.1 Jennings Computer Services Ltd is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. Jennings Computer Services Ltd has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.
2.2 Jennings Computer Services Ltd will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regards to our conduct both at home and abroad.
2.3 Jennings Computer Services Ltd recognises that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously.
3. Who is covered by the policy?
3.1 This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.
3.2 In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.
3.3 Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum.
4. Definition of bribery
4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.
4.2 A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.
4.3 Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.
4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager.
5. What is and what is NOT acceptable
5.1 This section of the policy refers to 4 areas:
• Gifts and hospitality.
• Facilitation payments.
• Political contributions.
• Charitable contributions.
5.2 Gifts and hospitality
Jennings Computer Services Ltd accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:
a. It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.
b. It is not made with the suggestion that a return favour is expected.
c. It is in compliance with local law.
d. It is given in the name of the company, not in an individual’s name.
e. It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
f. It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
g. It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
h. It is given/received openly, not secretly.
i. It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
j. It is not above a certain excessive value, as pre-determined by the company’s compliance manager (usually in excess of £100).
k. It is not offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance manager.
5.3 Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances.
5.4 Jennings Computer Services Ltd recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.
5.5 As good practice, gifts given and received should always be disclosed to the compliance manager. Gifts from suppliers should always be disclosed.
5.6 The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the compliance manager should be sought.
5.7 Facilitation Payments and Kickbacks
Jennings Computer Services Ltd does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.
5.8 Jennings Computer Services Ltd does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.
5.9 Jennings Computer Services Ltd recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken:
a. Keep any amount to the minimum.
b. Ask for a receipt, detailing the amount and reason for the payment.
c. Create a record concerning the payment.
d. Report this incident to your line manager.
5.10 Political Contributions
Jennings Computer Services Ltd will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.
5.11 Charitable Contributions
Jennings Computer Services Ltd accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.
5.12 Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.
5.13 We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the compliance manager.
6. Employee Responsibilities
6.1 As an employee of Jennings Computer Services Ltd , you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.
6.2 All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.
6.3 If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the compliance manager.
6.4 If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. [A Managing Director has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.
7. What happens if I need to raise a concern?
7.1 This section of the policy covers 3 areas:
a. How to raise a concern.
b. What to do if you are a victim of bribery or corruption.
c. Protection.
7.2 How to raise a concern
If you suspect that there is an instance of bribery or corrupt activities occurring in relation to Jennings Computer Services Ltd, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager, the compliance manager, the director, or the Head of Governance and Legal.
7.3 Jennings Computer Services Ltd will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially.
7.4 What to do if you are a vicitim of bribery or corruption
You must tell your compliance manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.
7.5 Protection
If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, Jennings Computer Services Ltd understands that you may feel worried about potential repercussions. Jennings Computer Services Ltd will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.
7.6 Jennings Computer Services Ltd will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.
7.7 Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.
7.8 If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager or the compliance manager immediately.
8. Training and communication
8.1 Jennings Computer Services Ltd will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy.
8.2 Jennings Computer Services Ltd ’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third parties at the outset of business relations, and as appropriate thereafter.
8.3 Jennings Computer Services Ltd will provide relevant anti-bribery and corruption training to employees etc. where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice, all businesses should provide their employees with antibribery training where there is a potential risk of facing bribery or corruption during work activities.
9. Record keeping
9.1 Jennings Computer Services Ltd will keep detailed and accurate financial records, and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.
10. Monitoring and reviewing
10.1 Jennings Computer Services Ltd compliance manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.
10.2 Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.
10.3 Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager.
10.4 This policy does not form part of an employee’s contract of employment and Jennings Computer Services Ltd may amend it at any time so to improve its effectiveness at combatting bribery and corruption.
Supplier Assessment Policy
Jennings Computer Services Ltd is committed to ensuring suppliers and contractors are rated and verified prior to entering into a business relationship.
Prior to entering into a trading relationship with any supplier, please ensure the following steps of this internal document are carried out.
• Review the supplier's reputation online
• Analyse customer complaints
• Is the supplier outsourcing?
• Obtain references from a minimum of 1x existing client
• Establish suitable payment terms
• Review returns / complaints procedures
• Ensure supplier is easy to contact and responds promptly