The Network Aviation Group are fully committed to ensuring that their operations comply with all applicable laws and regulations designed to combat bribery and corruption. Specifically, the UK Bribery Act 2010, the Criminal Finances Act 2017 and the US Foreign Corrupt practices Act 1977 and the standards they set. We are committed to seeking and retaining business based on merit and the excellence of our services, not through bribery or corruption.
We do not tolerate bribery or corruption involving those working for us, our agents, suppliers, customers or any person or entity connected to our business arrangements.
Our zero-tolerance policy is based on the core principles of our Anti-Bribery and Corruption Policy which maintains the group’s reputation and upholds the confidence of its customers and business partners as follows: –
Bribery is defined as offering, promising, giving, or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.
Those that work for us are strictly prohibited from corruptly offering, providing, paying, authorising, promising, soliciting, or receiving * “anything of value” directly or indirectly for the purpose of retaining or securing business or any improper business advantage. This prohibition relates to improper advantage being obtained from public officials, employees or officers of counter parties, clients, or suppliers or any of our business partners (including their relatives, friends, agents, or associates) or any other person or organisation with whom the group does or anticipates doing business.
“Anything of value” includes improper payments, such as cash bribes or kickbacks, and may also include other direct or indirect inducements, benefits, and advantages, such as inappropriate gifts, meals, travel, entertainment, charitable and political contributions and offers of employment or internships. “Anything of value” can also include corrupt payments disguised as legitimate payments for goods or services.
For the avoidance of doubt this prohibition extends not only to public officials but also to corporate clients and other private parties. Those who engage in or facilitate bribery or corruption, or who fail to comply with applicable anti-bribery laws, regulations, and the group’s Anti-corruption and bribery policy, may be subject to disciplinary action, up to and including suspension or termination.
No Acceptance of Bribes
Those that work for us are strictly prohibited from requesting or accepting bribes and other improper business advantages.
No Bribes by or Through Third Parties
The Network Aviation Group expects third parties acting on its behalf or with whom it is conducting business, to maintain appropriate policies and procedures relating to bribery and to act in a manner consistent with this Statement. Third parties include contractors, customers, suppliers, agents, and business partners.
The group also prohibits the use of third parties acting on behalf of the group to enable, route, instruct or facilitate illegal or inappropriate payments.
The group reserves the right to terminate immediately any business relationship that violates this Anti-Corruption and Bribery Statement, consistent with applicable laws and contractual terms.
No Facilitation Payments
The Network Aviation Group prohibits facilitation payments. These are payments to public officials to expedite or secure performance of a routine, non-discretionary governmental action.
The responsibility for ensuring these standards are maintained lies with both those that work for us and our business partners and associates. We must each remain vigilant about potential bribery concerns and escalate them immediately in accordance with the guidance provided in the Network Aviation Group Code of Ethics.
The Network Aviation Group also maintains robust written policies, procedures and internal controls reasonably designed to prevent, detect, and mitigate legal, regulatory, and reputational risks associated with bribery and corruption. The Network Aviation Group Anti-Corruption and Bribery Policy includes the following key components:
Governance and Oversight
As the primary coordinator of the group’s ethics and standards ethos, the Board of Network Aviation Group regularly reviews, assesses, and updates its anti-corruption and bribery systems and controls as appropriate, including bribery risk assessments, policies and procedures, communications and training, escalation processes, management reporting, as well as monitoring and assurance.
Third Party Due Diligence
Considering the heighted bribery and corruption risks associated with third parties acting on our behalf and in the business operations of the group, these relationships are subject to risk-based due diligence, monitoring and oversight processes.
Transaction Due Diligence
Transactions that are complex, not customary in the relevant market, not within ordinary course of business of the client, or present reputational, regulatory, or other issues may pose heightened bribery and corruption risks and be subject to enhanced due diligence.
Gifts, Travel and Entertainment
Pre-approval is required before anything of value is provided to “Heightened risk recipients”. These include employees or representatives of governments, government agencies, public international organisations, and state-owned enterprises. We also have controls in place governing gift, travel, and entertainment expenses with private companies and individuals.
Employment and Work Opportunities
Whether permanent or temporary, candidates referred by and/or connected to a client, potential client or public official are subject to pre and post onboarding reviews and controls.
Charitable and Political Contributions
Charitable contributions must never be made if the intent or effect is to influence inappropriately the business judgement of any person, including a public official, client, or potential client. Pre-approval by the board of Network Aviation Group is required for charitable contributions presenting higher bribery or corruption risk. We also do not permit political contributions to be used as bribes, and the group has requirements and policies governing political contributions.
The Board of Network Aviation Group regularly reviews and assesses our Anti-Corruption and Bribery Policy and approach to the subject of corruption and ethical business practices. The approach and policy on these matters may change periodically to reflect changes in legislation, best practice and to keep in line with evolving international and industry standards. It will apply lessons identified from external and internal events.