Anti-Bribery and Corruption Policy

As a professional services firm, we’re committed to maintaining the highest standards of integrity and transparency, ensuring that all our activities are conducted in strict compliance with anti-bribery and corruption laws.

DEFINITION

Bribery, in the conduct of A Jolly Consulting Ltd’s business, refers to offering or accepting any gift, loan, payment, reward, or advantage for personal gain as encouragement to act dishonestly, illegally, or in breach of trust.

Bribery is a criminal offenCe. A Jolly Consulting Ltd (AJC) strictly prohibits any form of bribery and corruption and requires adherence to the highest ethical standards and all applicable anti-bribery laws. Integrity and transparency are paramount to us, and we maintain a zero-tolerance policy towards corrupt activities of any kind, whether by AJC employees or third parties acting on our behalf.

PURPOSE

The purpose of this policy is to inform all employees and stakeholders of AJC about our unequivocal stance against bribery and our commitment to conducting business in a fair, professional, and legal manner.

OFFENCE

It is a criminal offenCe to:

• Offer a bribe
• Accept a bribe
• Bribe a foreign official
• Fail, as a commercial organisation, to prevent a bribe

Conviction for bribery could lead to up to 10 years in prison and/or an unlimited fine. AJC could also face prosecution and significant penalties.

DEFINITIONS OF BRIBERY AND CORRUPTION

• Corruption: The misuse of office or power for private gain.
• Bribery: Giving or receiving money, gifts, meals, entertainment, or anything of value as an inducement to perform dishonestly or illegally.

SCOPE

This policy applies to all AJC employees, regardless of seniority or location, as well as anyone working for or on our behalf (e.g., contractors or self-employed workers). We encourage the application of this policy with third parties, including suppliers and contractors.

GIFTS AND HOSPITALITY

AJC recognizes that giving and receiving gifts and hospitality can foster positive relationships when done proportionally and transparently. Such actions are not considered bribery when they involve no expectation of reciprocation and are properly recorded.

Definitions:

• Gifts: Includes money, goods (e.g., flowers, vouchers, food, drink), or services given as a token of appreciation or friendship.
• Hospitality: Includes entertainment, meals, or event tickets provided to develop or initiate business relationships.

Policy:

• No gift or hospitality should be given or accepted without prior written approval from the appropriate AJC representative.
• All instances of gifts and hospitality must be recorded.

POLICY

It is prohibited, directly or indirectly, to:

• Offer, give, request, or accept any bribe (e.g., gift, payment, reward) in cash or any other form to gain commercial, contractual, or regulatory advantage for AJC, or for personal gain in an unethical way.
• Influence a foreign public official by making payments on their behalf.

If you are offered or solicited for a bribe, do not accept unless your safety is at risk. Report the incident immediately to the designated AJC representative, providing a written account of the events if required.

Additional Measures:

• Conduct appropriate checks before engaging suppliers or third parties.
• Ensure transparency and legitimacy in all transactions, including sponsorships and charitable donations.

AJC takes any actual or suspected breach of this policy seriously. Violations will lead to investigations and appropriate actions, including dismissal for employees or termination of contracts for third parties.