Business conducted with integrity.
JL Academy is committed to conducting business honestly, fairly and with integrity. Bribery, corruption, improper inducements and unethical business practices are not acceptable in any part of our work.
Ethical standards apply across JL Academy’s work.
This policy applies to people acting for or on behalf of JL Academy and to business conducted in the UK and internationally.
Who this policy applies to
- JL Academy Directors
- Employees
- Associates
- Subcontractors
- Trainers and facilitators
- Consultants
- Agents or representatives acting on behalf of JL Academy
- Delivery partners where relevant to JL Academy activity
What bribery and corruption mean
Bribery involves offering, giving, requesting, receiving or agreeing to receive something of value in order to improperly influence a decision, action or business outcome.
Corruption may involve the misuse of a position, authority, relationship or process for improper personal or organisational benefit.
Improper benefit does not have to involve cash.
Bribery and corruption are not acceptable.
No person acting for or on behalf of JL Academy should participate in improper payments, inducements or arrangements.
- Offer a bribe
- Request or accept a bribe
- Make an improper payment
- Use a third party to make an improper payment
- Offer an inducement intended to secure unfair advantage
- Accept a benefit in return for improper preferential treatment
- Falsify records to conceal a payment or benefit
- Participate in arrangements intended to disguise bribery or corruption
Professional relationships should remain transparent.
Facilitation payments
JL Academy does not make facilitation payments. These are unofficial payments made to secure or speed up routine actions or services.
If a person is placed under pressure to make a payment of this kind, the matter should be reported to a JL Academy Director as soon as reasonably possible.
Where personal safety is at immediate risk, protecting the individual takes priority. Any payment made under genuine duress should be reported and documented as soon as it is safe to do so.
Gifts and hospitality
Reasonable and proportionate gifts or hospitality may sometimes form part of normal professional relationships.
- Reasonable in value
- Appropriate to the circumstances
- Infrequent
- Transparent
- Lawful
- Connected to a legitimate professional purpose
- Unlikely to create a conflict of interest
- Unlikely to affect objective decision-making
Cash gifts or cash-equivalent gifts should not be accepted.
A benefit should never create an improper obligation.
- It appears intended to influence a decision
- It is unusually generous or excessive
- It is offered during a procurement or tender process where acceptance could create concern
- It creates an expectation of favourable treatment
- It would be embarrassing if publicly disclosed
- It creates a real or perceived conflict of interest
- It is prohibited by the rules of the recipient’s organisation
Fair procurement, transparent commissions and declared conflicts.
Business arrangements should be capable of being explained, documented and independently understood.
Procurement and tendering
JL Academy aims to compete for work fairly and transparently.
No person acting for JL Academy should attempt to influence a procurement, tender, commissioning or contracting decision through improper gifts, payments, favours or personal incentives.
Information provided during procurement should be accurate and not deliberately misleading.
Commissions and referrals
Legitimate commissions, referral fees or commercial arrangements may be used where they are transparent, properly documented and connected to genuine business activity.
They must not be used to conceal bribes, kickbacks, improper inducements, undisclosed personal payments or payments intended to influence a decision unfairly.
Commercial arrangements should be proportionate to the service provided.
Conflicts of interest
Actual, potential or perceived conflicts should be identified and managed appropriately.
- Record the conflict
- Withdraw from a decision
- Change responsibilities
- Seek independent review
- Decline a transaction or opportunity
Integrity should extend through the wider supply chain.
Third parties and associates
JL Academy may work with associates, subcontractors, consultants, partners and other third parties.
Where relevant, proportionate checks may consider:
- Professional reputation
- Qualifications and experience
- Ownership or business relationships
- Conflicts of interest
- References
- Contractual expectations
- Unusual payment requests
- Unusually high commissions
- Payments to unrelated third parties
- Requests for unexplained cash payments
No third party should be used to carry out an action that JL Academy would not permit directly.
Payments and financial records
Business payments should be properly authorised, recorded and capable of being explained.
- Invoices
- Expenses
- Commissions
- Referral payments
- Relevant gifts or hospitality
- Contracts
- Procurement activity
- Unusual payments
- Concerns raised under this policy
Records should not be falsified, altered or deliberately misleading.
Genuine purpose, transparent intent.
Charitable giving or sponsorship should not be used as a way of securing improper business advantage. Where JL Academy supports charitable or community activity, the purpose should be genuine and transparent.
Business and personal activity remain distinct.
JL Academy should not make political contributions on behalf of the business for the purpose of securing commercial or regulatory advantage. Individuals remain free to participate in lawful political activity in a personal capacity.
Suspected improper conduct should be raised promptly.
Raising a concern
Anyone who becomes aware of suspected bribery, corruption or improper inducement should raise the concern promptly.
Concerns may be raised with a JL Academy Director or, where appropriate, under the Whistleblowing and Speaking Up Policy.
A person raising a genuine concern should not be subjected to retaliation or unfair treatment for doing so.
Concerns involving a Director
Where a concern involves one JL Academy Director, it should normally be raised with the other Director where possible.
Where this is not appropriate, an external reporting route may be used depending on the nature and seriousness of the concern.
The response should reflect the seriousness of the issue.
JL Academy may take proportionate action to establish what has happened and protect the integrity of its work.
- Gather further information
- Review financial or contractual records
- Speak with relevant people
- Suspend a payment or transaction
- Seek legal, accounting or specialist advice
- Review a third-party relationship
- Terminate an arrangement
- Take disciplinary or contractual action
- Report to an appropriate authority where required
Action will depend on the circumstances and seriousness of the matter.
- Removal from a project
- Suspension of work
- Termination of an associate or subcontractor arrangement
- Disciplinary action where applicable
- Termination of a commercial relationship
- Referral to a professional body
- Referral to an appropriate authority
Prevention depends on awareness, oversight and proportionate controls.
International work
JL Academy may work with organisations and individuals in different jurisdictions.
Local business custom does not justify conduct that would amount to bribery, corruption or improper inducement.
Where local expectations differ, JL Academy will seek to maintain appropriate ethical standards while taking account of local law and legitimate cultural practice.
Training and awareness
People acting on behalf of JL Academy should understand the standards expected under this policy.
- International contracting
- Tendering and procurement
- Intermediary relationships
- Commissions or referral arrangements
- Work involving public bodies
- Unusually high-value contracts
Monitoring and improvement
JL Academy may review anti-bribery controls as part of its wider governance and quality-assurance arrangements.
- Procurement activity
- Third-party relationships
- Concerns raised
- Financial reviews
- Changes in business activity
- International work
- Relevant guidance
- Identified conflicts of interest
Related policies
This policy should be read alongside relevant JL Academy governance documents.
- Whistleblowing and Speaking Up Policy
- Quality Assurance Policy
- Safeguarding Policy
- Complaints Policy
- Privacy and Data Protection Policy
- Equality, Diversity and Inclusion Policy
- Terms and Conditions of Business
Ethical business practice is a shared responsibility.
JL Academy Directors are responsible for oversight of this policy and responding to concerns about bribery, corruption or improper inducement.
- Behave ethically
- Avoid improper influence
- Declare relevant conflicts of interest
- Keep appropriate records
- Raise concerns promptly
- Cooperate with proportionate review or investigation
The policy is reviewed periodically and sooner where risk changes.
This includes significant changes to JL Academy’s activities, procurement or contracting, international work, legislation or regulatory expectations, financial controls, third-party relationships or identified bribery and corruption risk.
Need to discuss an ethical or governance concern?
JL Academy encourages concerns about bribery, corruption, improper inducements or conflicts of interest to be raised promptly and handled appropriately.