1.Purpose

 

The purpose of this policy is to establish controls to ensure compliance with all applicable  anti-bribery    and corruption regulations, and to ensure that the Company’s business is conducted in a socially responsible manner.

 

2.Policy statement

Bribery is the offering,  promising,  giving,  accepting  or  soliciting  of  an  advantage  as  an  inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or  provided in order to gain any commercial, contractual, regulatory or personal advantage.

It is our policy to conduct all of our business in an honest and ethical manner. We take a zero- tolerance approach to  bribery and corruption. We are committed to acting  professionally,   fairly and with integrity   in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws in India in respect of our conduct both at home and abroad.

Bribery and corruption are punishable for individuals by up to ten years' imprisonment and a fine.  If  we  are found to have taken  part  in corruption, we could face an unlimited fine, be  excluded from tendering  for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously.

3.Scope

 

1. Who is covered by the policy?

In this policy, third party means any individual or organisation you come into contact with  during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

 

This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy).

 

This policy covers:

 

• Bribes;

• Gifts and hospitality;

• Facilitation payments;

• Political contributions;

• Charitable contributions.

 

3.2Bribes

 

Employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor). Specifically, employees must not bribe a  foreign  public  official anywhere in the  world.

 

 

3.3Gifts and hospitality

Employees must not offer or give any gift or hospitality:

 

• which could be regarded as illegal or improper, or which violates the recipient’s policies; or

• to any public employee or government officials or representatives, or politicians or political parties; or

• which exceeds Rs.100  in  value  for  each  individual  gift  or  Rs.500  in  value  for  each hospitality event (not to exceed a total value of Rs.1000 in any financial year), unless  approved   in writing by the employee’s manager.

 

Employees may not accept any gift or hospitality from our business partners if:

 

• it exceeds Rs.100 in value for each individual gift or Rs.500 in value for each hospitality event (not to  exceed  a  total   of   Rs.1000   in   any  financial   year),   unless   approved   in   writing by the employee’s manager; or

• it is in cash; or

• there is any suggestion that a return favour will be expected or implied.

 

Where a manager’s approval is required above, if the manager is  below Director  level then  approval  must be sought from an appropriate Director.

 

If it is not appropriate to decline the offer of a gift, the gift may be accepted, provided it is then declared to the employee’s manager and donated to charity.

 

We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be  applied is whether in  all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.

 

Within these parameters, local management may define specific guidelines and policies to reflect local professional and industry standards. Where this policy requires written approval to be given, the Company Secretary shall put in place a process to maintain a register of all such approvals.

 

3.4Facilitation payments and kickbacks

Facilitation payments are a form of bribery made for the purpose of expediting or facilitating the performance of  a public  official for  a routine governmental action, and not to obtain or  retain  business   or any improper business  advantage.  Facilitation  payments  tend  to  be  demanded  by  low  level officials to obtain a level of service which one would normally be entitled to.

Our strict policy is that facilitation payments must not be paid. We recognise, however,  that  our  employees may be faced with situations where there is a risk to the personal security of an employee or his/her family and where a facilitation payment is unavoidable, in which case the following steps must be taken:

 

• Keep any amount to the minimum;

• Create a record concerning the payment; and

• Report it to your line manager.

 

In order to achieve our aim  of  not making any facilitation  payments, each  business  of  the  Company  will keep a record of all payments made, which must be reported to the Company Secretary, in order to evaluate the business risk and to develop a strategy to minimise such payments in the future.

 

3.5Political Contributions

 

We do not make donations, whether  in cash or kind, in support of  any political parties  or  candidates,     as this can be perceived as an attempt to gain an improper business advantage.

 

3.6Charitable contributions

 

Charitable support and donations are acceptable (and indeed are encouraged), whether of in- kind services, knowledge, time, or direct financial contributions. However, employees must  be  careful  to ensure that charitable contributions are not used as a scheme to conceal bribery. We only  make  charitable donations that are legal and ethical under local laws  and  practices]. No donation must be offered or made without the prior approval of [the compliance manager.

All charitable contributions should be publicly disclosed.

 

4.Your responsibilities

 

You must ensure that you read, understand and comply with this policy.

 

The prevention, detection and reporting  of  bribery and  other forms  of  corruption  are the  responsibility  of all those working for us  or under  our control. All  employees are required to  avoid any activity that  might lead to, or suggest, a breach of this policy.

 

You must notify your manager OR the Company Secretary or the confidential helpline as  soon  as  possible if you believe or suspect that a conflict  with  or  breach  of  this  policy  has  occurred, or may occur in the future.

 

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy.

 

5.Record-keeping

 

We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

 

You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.

 

You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third

parties are submitted in accordance  with  our  expenses  policy  and  specifically  record  the  reason for the expenditure.

 

All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared  and  maintained  with  strict  accuracy and completeness. No accounts must be kept "off-book" to facilitate or conceal improper payments.

 

6.How to raise a concern

 

You are encouraged to raise concerns about any issue or suspicion of  malpractice  at  the  earliest possible stage. If you are unsure whether a  particular  act  constitutes  bribery  or  corruption, or if  you have any other queries or concerns, these should be raised with your line manager OR the Company Secretary or through the confidential helpline.

 

7.What to do if you are a victim of bribery or corruption

 

It is important that you tell  the Company Secretary or  the confidential  helpline  as  soon as  possible if  you are offered a bribe by a third party, are asked to make one, suspect that this  may happen in the  future, or believe that you are a victim of another form of unlawful activity.

 

8.Protection

 

Employees who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We aim to  encourage openness and will support anyone who raises genuine concerns  in  good faith  under this policy, even if they turn out to be mistaken.

 

We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform Colm Shevlin immediately. If the matter is not remedied, and  you  are  an  employee,  you  should  raise  it  formally using the company’s Grievance Procedure.

 

9.Training and communication

 

Training on this policy forms part of the induction process for all new employees. All existing employees  will receive regular, relevant training on how to implement and adhere to this policy. In addition, all employees will be asked to formally accept conformance to this policy on an annual basis.

 

Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.

 

10.Who is responsible for the policy?

 

The board of directors has overall responsibility for ensuring this policy  complies  with  our  legal and ethical obligations, and that all those under our control comply with it.

 

The Company Secretary has primary and day-to-day responsibility for implementing this

policy, and for monitoring  its  use  and  effectiveness  and  dealing  with  any  queries  on  its  interpretation. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.

 

11.Monitoring and review

 

The Company Secretary will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements  identified  will  be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.

 

All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.

 

Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Company Secretary.

 

This policy does not form  part of  any employee's  contract of  employment  and it may be  amended at  any time.

 

Signed on the 1ST April 2021 for and on behalf of JOHN GALT INTERNATIONAL

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Nondiscrimination/Anti-Harassment Policy and Complaint Procedure

 

 

John Galt International is committed to a work environment in which all individuals are treated with respect and dignity. Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits unlawful discriminatory practices, including harassment. Therefore, John Galt International expects that all relationships among persons in the office will be business-like and free of explicit bias, prejudice and harassment.

John Galt International has developed this policy to ensure that all its employees can work in an environment free from unlawful harassment, discrimination and retaliation. John Galt International will make every reasonable effort to ensure that all concerned are familiar with these policies and are aware that any complaint in violation of such policies will be investigated and resolved appropriately.

Any employee who has questions or concerns about these policies should talk with the director of human resources or a member of the personnel practices committee.

These policies should not, and may not, be used as a basis for excluding or separating individuals of a particular gender, or any other protected characteristic, from participating in business or work-related social activities or discussions. In other words, no one should make the mistake of engaging in discrimination or exclusion to avoid allegations of harassment. The law and the policies of John Galt International prohibit disparate treatment on the basis of sex or any other protected characteristic, with regard to terms, conditions, privileges and perquisites of employment. The prohibitions against harassment, discrimination and retaliation are intended to complement and further those policies, not to form the basis of an exception to them.

Equal employment opportunity

It is the policy of John Galt International to ensure equal employment opportunity without discrimination or harassment on the basis of race, color, religion, sex, sexual orientation, gender identity or expression, age, disability, marital status, citizenship, national origin, genetic information, or any other characteristic protected by law. John Galt International prohibits any such discrimination or harassment.

Retaliation

John Galt International encourages reporting of all perceived incidents of discrimination or harassment. It is the policy of John Galt International to promptly and thoroughly investigate such reports. John Galt International prohibits retaliation against any individual who reports discrimination or harassment or participates in an investigation of such reports.

Sexual harassment

Sexual harassment constitutes discrimination and is illegal under federal, state and local laws. For the purposes of this policy, “sexual harassment” is defined, as in the Equal Employment Opportunity Commission Guidelines, as unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature when, for example: a) submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment, b) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual, or c) such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive working environment.

Title VII of the Civil Rights Act of 1964 recognizes two types of sexual harassment: a) quid pro quo and b) hostile work environment. Sexual harassment may include a range of subtle and not-so-subtle behaviors and may involve individuals of the same or different gender. Depending on the circumstances, these behaviors may include unwanted sexual advances or requests for sexual favors; sexual jokes and innuendo; verbal abuse of a sexual nature; commentary about an individual’s body, sexual prowess or sexual deficiencies; leering, whistling or touching; insulting or obscene comments or gestures; display in the workplace of sexually suggestive objects or pictures; and other physical, verbal or visual conduct of a sexual nature.

Harassment

Harassment on the basis of any other protected characteristic is also strictly prohibited. Under this policy, harassment is verbal, written or physical conduct that denigrates or shows hostility or aversion toward an individual because of his or her race, color, religion, sex, sexual orientation, gender identity or expression, national origin, age, disability, marital status, citizenship, genetic information, or any other characteristic protected by law, or that of his or her relatives, friends or associates, and that: a) has the purpose or effect of creating an intimidating, hostile or offensive work environment, b) has the purpose or effect of unreasonably interfering with an individual’s work performance, or c) otherwise adversely affects an individual’s employment opportunities.

Harassing conduct includes epithets, slurs or negative stereotyping; threatening, intimidating or hostile acts; denigrating jokes; and written or graphic material that denigrates or shows hostility or aversion toward an individual or group that is placed on walls or elsewhere on the employer’s premises or circulated in the workplace, on company time or using company equipment by e-mail, phone (including voice messages), text messages, social networking sites or other means.

Individuals and Conduct Covered

These policies apply to all applicants and employees, whether related to conduct engaged in by fellow employees or by someone not directly connected to John Galt International (e.g., an outside vendor, consultant or customer).

Conduct prohibited by these policies is unacceptable in the workplace and in any work-related setting outside the workplace, such as during business trips, business meetings and business-related social events.

Reporting an Incident of Harassment, Discrimination or Retaliation

John Galt International encourages reporting of all perceived incidents of discrimination, harassment or retaliation, regardless of the offender’s identity or position. Individuals who believe that they have been the victim of such conduct should discuss their concerns with their immediate supervisor, any member of the personnel practices committee, human resources or any ombudsman. See the complaint procedure described below.

In addition, John Galt International encourages individuals who believe they are being subjected to such conduct to promptly advise the offender that his or her behavior is unwelcome and to request that it be discontinued. Often this action alone will resolve the problem. John Galt International recognizes, however, that an individual may prefer to pursue the matter through complaint procedures.

Complaint Procedure

Individuals who believe they have been the victims of conduct prohibited by this policy or believe they have witnessed such conduct should discuss their concerns with their immediate supervisor, human resources, any member of the personnel practices committee or any ombudsman.

John Galt International encourages the prompt reporting of complaints or concerns so that rapid and constructive action can be taken before relationships become irreparably strained. Therefore, while no fixed reporting period has been established, early reporting and intervention have proven to be the most effective method of resolving actual or perceived incidents of harassment.

Any reported allegations of harassment, discrimination or retaliation will be investigated promptly. The investigation may include individual interviews with the parties involved and, where necessary, with individuals who may have observed the alleged conduct or may have other relevant knowledge.

John Galt International will maintain confidentiality throughout the investigatory process to the extent consistent with adequate investigation and appropriate corrective action.

Retaliation against an individual for reporting harassment or discrimination or for participating in an investigation of a claim of harassment or discrimination is a serious violation of this policy and, like harassment or discrimination itself, will be subject to disciplinary action. Acts of retaliation should be reported immediately and will be promptly investigated and addressed.

Misconduct constituting harassment, discrimination or retaliation will be dealt with appropriately. Responsive action may include, for example, training, referral to counseling or disciplinary action such as a warning, reprimand, withholding of a promotion or pay increase, reassignment, temporary suspension without pay, or termination, as John Galt International believes appropriate under the circumstances.

If a party to a complaint does not agree with its resolution, that party may appeal to John Galt International’s executive director or the chief operating officer.

False and malicious complaints of harassment, discrimination or retaliation (as opposed to complaints that, even if erroneous, are made in good faith) may be the subject of appropriate disciplinary action.