In this section
CityJet Anti Bribery and Corruption Policy
- CityJet is committed to conducting all business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption in any form. We are committed to acting professionally, fairly and with integrity in all our relationships and business dealings wherever we operate and to implementing and enforcing effective systems to counter bribery.
- CityJet upholds all applicable laws relating to countering bribery and corruption. We are bound by the laws of Ireland, including the Prevention of Corruption Acts 1889 to 2010 in respect of our conduct.
- The purpose of this policy is to set out our responsibilities, and the responsibilities of those working for us, in observing and upholding our position on bribery and corruption.
- Bribery and corruption are by Irish law punishable by up to ten years' imprisonment and an unlimited fine.
- Activities Forbidden by CityJet
- CityJet strictly prohibits the offering, giving, solicitation or the acceptance of any bribe, whether cash or other inducement to or from any person or company, wherever they are situated and whether they are a public official, public foreign official, body, private person, company or any individual employee, agent or other person or body acting on CityJet’s behalf in order to gain any commercial, contractual or regulatory benefit in any unethical way.
- CityJet personnel shall not accept, solicit make or authorize anyone to make on behalf of CityJet, any payments or gifts or offers or promises to pay money or give anything of value to or for the benefit of any person, including any “Public Official”, relating to obtaining or retaining business with any person, directing business to any person, obtaining any other advantage in the conduct of business, or inducing or rewarding the “improper” performance.
- CityJet personnel shall not make contributions of funds, facilities or services of any kind to political parties or officials or candidates for office to obtain their support for executive, legislative, administrative or other action favourable to CityJet.
- CityJet personnel shall not give or offer to give on behalf of CityJet any money, gift or thing of value to a third party if they know or has reason to believe that it will be offered to a public official or any other person to obtain or retain business with any person, to direct business to any person, to obtain any other advantage in the conduct of business, or to induce or reward the improper performance by any person of any function or activity.
- All CityJet personnel are responsible for complying with this Policy and applicable anti-corruption laws in the performance of their duties as an employee, contractor or agent of the Company.
- CityJet’s accounts shall reflect, accurately and fairly, the transactions of the company and dispositions of its assets.
- Particular Key Risk Areas to be aware of:
- Excessive gifts, entertainment and hospitality: can be used to exert inappropriate influence on decision makers.
- Facilitation payments: are used by businesses or individuals to secure or expedite the performance of a routine or necessary action to which the payer has an entitlement as of right. CityJet will not tolerate such payments being made.
- Reciprocal agreements are never acceptable unless they are legitimate business arrangements which are properly documented and approved by management. Improper payments to obtain new business, retain existing business or secure any improper advantage should never be accepted or made.
- Actions by third parties for which the firm may be held responsible: can include a range of people i.e. agents, consultants and contractors, acting on the firm’s behalf. Appropriate due diligence should be undertaken before a third party is engaged. Any payments to third parties should be properly authorised and recorded.