ANTI-BRIBERY/CORRUPTION COMMITMENT

Julie Sandlau Vietnam (JSV) is committed to operating with the highest standards of integrity and promoting a culture in which accountability flourishes. JSV opposes bribery, corruption and facilitation payments as they erode free and fair competition, damages good government and harms society at large.

In order to prevent bribery, corruption and facilitation payments, JSV recognizes that it should:

assess whether the charity is at risk and, if so, the level of that risk
put in place procedures proportionate to the risk identified
show a clear commitment to the prevention of bribery
use due diligence to assess who we deal with and who we appoint to represent us
communicate, train and raise awareness among employees and business partners
monitor and review procedures
committed to protect all individuals who have reported bribery or corruption in the company

ANTI-BRIBERY PROCEDURES

DEFINITIONS

Bribery and corruption:

Bribery is the offering, promising, giving, accepting or soliciting of money, a gift or other advantage as an inducement to do something that is illegal or a breach of trust in the course of carrying out an organisation’s activities.

Corruption is the misuse of public office or power for private gain

Facilitation payments:

Facilitation payments are payments which induce officials to perform routine functions they are otherwise obligated to perform. Facilitation payments are bribes and there is no exemption for them. Facilitation payments do not include legally required administrative fees and legitimate fast-track services.

RESPONSIBILITIES

HR department

HR depts are responsible for informing the CEO of any gifts or hospitality that they have received

They are responsible for ensuring that the services JSV provides are properly planned and that risks are assessed and managed in line with this policy.

Individuals

Individuals are expected to safeguard and uphold JSV's core values by operating in an ethical, professional and lawful manner at all times. Individuals are responsible for not giving or receiving bribes and challenging instances where bribery may occur. They are also responsible for reporting all bribery that they are aware of to HR depts via the procedures laid out in this policy.

Compliance with JSV's policy in relation to bribery and corruption is regarded as part of an individual's contract of employment. Any member of staff found to have accepted or attempted bribery or made facilitation payments will be subject to disciplinary action, including dismissal.

Individuals must not offer money to any public officials in order to speed up service or gain improper advantage. This type of bribery is a "facilitation payment" and is illegal. In the unlikely event that an individual is faced with a demand for a facilitation payment, such payment must be actively resisted.

BRIBERY PREVENTION

Risk assessment

Effective risk assessment lies at the very core of the success or failure of this policy. Risk identification pinpoints the specific areas in which JSV may face bribery and corruption risks and allows the organization to better evaluate and mitigate these risks and thereby protect itself.

JSV will carry out a risk assessment of the key risks facing the organization in respect of bribery and corruption and review these risks, on an annual basis. JSV recognizes that the threat of bribery varies across countries, areas of work, partners and transactions and that the charity must respond proportionately to those risks.

Recruitment

JSV recognizes that good anti-bribery practice starts from the outset of employing an individual. It therefore ensures that all employment contracts prohibit the giving or receiving of bribes on behalf of JSV.

In addition, a program of staff communication and training is provided to those employees working in areas of perceived higher risk.

Working with service suppliers and in partnerships

JSV therefore requires all staff, suppliers and partners to ensure that, where appropriate:

Key service suppliers and partners are selected through a transparent and competitive selection process.
Due diligence is carried out on partners and key suppliers before entering into contracts in accordance with the procurement policy.
Contractual agreements explicitly prohibit the giving or receiving of bribes on behalf of JSV.
Any conflicts of interest are declared.

Communication

All people described in the scope of this policy must understand and comply with JSV's antibribery policy. To ensure that this is communicated, JSV publishes this policy on its website and internally in the factory.

Record-Keeping

Many serious global bribery and corruption offences have been found to involve some degree of inaccurate record-keeping. We must ensure that we maintain accurate records and financial reporting within JSV and for significant business partners working on our behalf. Our records and overall financial reporting must also be transparent. That is, they must accurately reflect each of the underlying transactions.

Where bribery is suspected or where it occurs

To enable proper investigation, you should record the details of any bribery or requested or attempted bribery, as soon as possible after the event. Any instances of actual or potential bribery should be properly and promptly investigated by an General Director.

The objectives of an investigation should be to:

Confirm whether or not a bribe has taken place, and to identify who was responsible.
Confirm whether internal controls and anti-bribery procedures have worked in practice.
Identify any improvements required to anti-bribery procedures.

Depending on the findings of the investigation, subsequent action will be determined. This may involve disciplinary action against staff involved or external reporting to:

A senior official or director of another organization, if the person making the bribe is from that organization
Local police/ law enforcement agencies (if deemed appropriate)

MONITORING AND REVIEW

This policy will be reviewed annually or after a significant change in operations or a significant incident, whichever is sooner.