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1. Anti bribery policy



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.



  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.




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.




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.




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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