Fastjet's Anti Bribery and Corruption Policy 1 Policy Statement
Fastjet's Anti Bribery and Corruption Policy 1 Policy Statement
1 Policy statement
1.1 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 and 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.
1.2 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 of the UK, including the Bribery
Act 2010, in respect of our conduct both at home and abroad.
1.3 The purpose of this policy is to:
1.3.1 set out our responsibilities, and of those working for us, in observing and upholding
our position on bribery and corruption; and
1.3.2 provide information and guidance to those working for us on how to recognise and
deal with bribery and corruption issues.
1.4 Bribery and corruption are punishable for individuals by up to ten years' imprisonment and 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.
1.5 We have identified that the following are particular risks for our business: Country risk,
sectoral risk, transaction risk, business opportunity risk, business partnership risk and
hospitality risk. To address those risks the company policy has been defined and circulated to
all key staff.
1.6 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 of services, distributors, business contacts, agents, advisers, and government and
public bodies, including their advisors, representatives and officials, politicians and political
parties.
3 What is Bribery?
3.1 A bribe is an inducement or reward offered, promised or provided in order to gain any
commercial, contractual, regulatory or personal advantage. Examples include:
3.2 Offering a bribe
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You offer a potential client tickets to a major sporting event, but only if they agree to do
business with us.
This would be an offence as you are making the offer to gain a commercial and contractual
advantage. We may also be found to have committed an offence because the offer has been
made to obtain business for us. It may also be an offence for the potential client to accept
your offer.
3.3 Receiving a bribe
A supplier gives your nephew a job, but makes it clear that in return they expect you to use
your influence in our organisation to ensure we continue to do business with them.
It is an offence for a supplier to make such an offer. It would be an offence for you to accept
the offer as you would be doing so to gain a personal advantage.
3.4 Bribing a foreign official
You arrange for the business to pay an additional payment to a foreign official to speed up an
administrative process.
The offence of bribing a foreign public official has been committed as soon as the offer is
made. This is because it is made to gain a business advantage for us. We may also be found to
have committed an offence.
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4.4 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.
7 Donations
We do not make contributions to political parties. 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 fastjet Plc’s Chief Financial Officer.
8 Your responsibilities
8.1 You must ensure that you read, understand and comply with this policy.
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8.2 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 workers are required to
avoid any activity that might lead to, or suggest, a breach of this policy.
8.3 You must notify fastjet Plc’s Chief Financial Officer as soon as possible if you believe or
suspect that a conflict with this policy has occurred, or may occur in the future. For example,
if a client or potential client offers you something to gain a business advantage with us, or
indicates to you that a gift or payment is required to secure their business. Further "red flags"
that may indicate bribery or corruption are set out in Schedule 1.
8.4 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.
9 Record-keeping
9.1 We must keep financial records and have appropriate internal controls in place which will
evidence the business reason for making payments to third parties.
9.2 You must declare and keep a written record of all hospitality or gifts accepted or offered,
which will be subject to managerial review.
9.3 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.
9.4 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.
12 Protection
12.1 Workers 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.
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12.2 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 fastjet Plc’s Chief Financial Officer
immediately. If the matter is not remedied, and you are an employee, you should raise it
formally using our Grievance Procedure.
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16.3 If you encounter any of these red flags while working for us, you must report them promptly
to fastjet Plc’s Chief Financial Officer using the procedure set out in the whistleblowing policy:
16.3.1 you become aware that a third party engages in, or has been accused of engaging
in, improper business practices;
16.3.2 you learn that a third party has a reputation for paying bribes, or requiring that
bribes are paid to them, or has a reputation for having a "special relationship" with
foreign government officials;
16.3.3 a third party insists on receiving a commission or fee payment before committing to
sign up to a contract with us, or carrying out a government function or process for
us;
16.3.4 a third party requests payment in cash and/or refuses to sign a formal commission
or fee agreement, or to provide an invoice or receipt for a payment made;
16.3.5 a third party requests that payment is made to a country or geographic location
different from where the third party resides or conducts business;
16.3.6 a third party requests an unexpected additional fee or commission to "facilitate" a
service;
16.3.7 a third party demands lavish entertainment or gifts before commencing or
continuing contractual negotiations or provision of services;
16.3.8 a third party requests that a payment is made to "overlook" potential legal
violations;
16.3.9 a third party requests that you provide employment or some other advantage to a
friend or relative;
16.3.10 you receive an invoice from a third party that appears to be non-standard or
customised;
16.3.11 a third party insists on the use of side letters or refuses to put terms agreed in
writing;
16.3.12 you notice that we have been invoiced for a commission or fee payment that
appears large given the service stated to have been provided;
16.3.13 a third party requests or requires the use of an agent, intermediary, consultant,
distributor or supplier that is not typically used by or known to us; or
16.3.14 you are offered an unusually generous gift or offered lavish hospitality by a third
party.
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