DSJ Group
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    DSJ Group: Anti-Bribery & Corruption Policy

    1. Introduction

    DSJ Group is committed to conducting business with the highest ethical standards and in compliance with all applicable anti-bribery and anti-corruption laws. This Anti-Bribery & Corruption Policy (the "Policy") outlines our zero-tolerance approach to bribery and corruption and sets out the steps that we take to ensure compliance with the Bribery Act 2010 and other relevant laws and regulations.

    2. Purpose of the Policy

    The purpose of this policy is to:

    • Prevent bribery and corruption within DSJ Group and in our dealings with third parties.
    • Set out the principles and responsibilities of DSJ Group and its employees in relation to bribery and corruption.
    • Provide guidance on how employees and associates should act when faced with situations where bribery and corruption may be an issue.

    3. Scope of the Policy

    This Policy applies to all employees, officers, directors, contractors, subcontractors, consultants, agents, and any third parties who represent or work with DSJ Group (collectively referred to as "the Company").

    4. What is Bribery and Corruption?

    Bribery: A bribe is an offer, promise, gift, or payment made to someone to induce or influence them to act in a particular way, often in return for an improper advantage.

    Corruption: Corruption involves the abuse of power for personal gain, typically through bribery or other illicit means.

    Bribery can take many forms, including but not limited to:

    • Offering or accepting gifts, kickbacks, or financial incentives in exchange for preferential treatment.
    • Providing or receiving any form of compensation to influence decision-making or gain an unfair advantage.

    5. Zero-Tolerance Approach

    DSJ Group operates a strict zero-tolerance approach to bribery and corruption. We will not tolerate any form of bribery or corrupt conduct, whether committed by our employees, contractors, business partners, or other third parties acting on our behalf.

    6. Prohibited Conduct

    It is strictly prohibited for anyone working for or on behalf of DSJ Group to:

    • Offer, give, solicit, or receive any bribe or improper payment.
    • Make any facilitation payments (i.e., payments to expedite routine government actions).
    • Engage in any form of corruption, including but not limited to kickbacks, improper gifts, or conflicts of interest.
    • Accept or offer lavish or inappropriate gifts or entertainment that could influence business decisions.

    7. Gifts and Hospitality

    The giving and receiving of gifts or hospitality can be legitimate in some business contexts, but they must always be proportionate, transparent, and reasonable. Any gift or hospitality should:

    • Be for a legitimate business purpose.
    • Not influence or be perceived to influence business decisions.
    • Be consistent with local customs and laws.
    • Not be given in exchange for, or in anticipation of, any improper advantage.

    All gifts and hospitality should be recorded in the Company's gift register, and any gifts exceeding a value of £50 must be approved by the appropriate management.

    8. Reporting Concerns

    If any employee, contractor, or third party has concerns about potential bribery or corruption, they must report it immediately. DSJ Group provides a safe and confidential mechanism for reporting any suspicions of bribery or corruption. Employees are encouraged to report concerns to their line manager, HR, or through the Company's whistleblowing procedure.

    The Company will treat all reports seriously and investigate them promptly. Retaliation or victimization against individuals who report concerns in good faith will not be tolerated.

    9. Due Diligence on Third Parties

    DSJ Group requires that all third parties (e.g., suppliers, agents, joint venture partners, etc.) adhere to the principles of this Policy. We will conduct appropriate due diligence before entering into any business relationship to ensure that our third parties are not involved in bribery or corruption.

    10. Training and Awareness

    All employees will receive training on the provisions of this Policy and on how to recognize and deal with bribery and corruption. Training will be provided upon joining the Company and at regular intervals thereafter.

    11. Monitoring and Enforcement

    DSJ Group will monitor compliance with this Policy through regular audits, assessments, and reviews. Violations of this Policy will result in disciplinary action, up to and including termination of employment, as well as potential legal consequences.

    12. Consequences of Violations

    Employees or third parties who breach this Policy may face disciplinary action, including dismissal, and could be subject to criminal prosecution under the Bribery Act 2010. Legal penalties for bribery can include fines and imprisonment for individuals involved.

    13. Responsibilities

    • Management: Senior management is responsible for setting the tone and ensuring that anti-bribery and anti-corruption practices are integrated into the Company's culture. They must promote ethical behavior and lead by example.
    • Employees: All employees must comply with this Policy and report any concerns or incidents of bribery or corruption.
    • Third Parties: All third parties must abide by the principles of this Policy and must not engage in bribery or corruption when dealing with or on behalf of DSJ Group.

    14. Policy Review

    This Anti-Bribery & Corruption Policy will be reviewed regularly to ensure its effectiveness and to comply with any changes in laws or regulations. Any amendments to the Policy will be communicated to all employees and stakeholders.