anti-corruption policy.

At JRNY Consulting, we commit ourselves to conduct our business according to the highest ethical standards. This policy delineates our firm stance against all forms of corruption and bribery.

1. Policy Statement

JRNY Consulting unequivocally prohibits corruption and bribery, whether direct or indirect. This policy is applicable to all our employees, consultants, partners, and any individual or organisation representing or working with JRNY Consulting.

This policy was last updated on 2 January 2024.

3. Definitions

  • Corruption: The misuse of entrusted power for private gain.

  • Bribery: The act of offering, giving, receiving, or soliciting something of value to influence the actions of an official or other person in a position of authority.

  • Facilitation Payments: Small, unofficial payments made to expedite or facilitate routine governmental actions.

4. Standards of Conduct

  • Employees and representatives of JRNY Consulting are prohibited from engaging in any form of corruption or bribery, including facilitation payments.

  • Gifts, hospitality, and expenses must be modest and should not be intended to influence business decisions.

  • Political contributions need to be transparent and compliant with relevant laws.

  • Facilitation payments are expressly prohibited at JRNY Consulting. These are unofficial payments made to public officials to expedite or facilitate routine actions.

  • Any requests for facilitation payments must be immediately reported and declined, adhering to this policy.

5. Reporting and Whistleblowing

  • Suspected incidents of corruption, including facilitation payments, must be reported without delay.

  • JRNY Consulting assures protection against retaliation for whistleblowers.

6. Training and Awareness

Regular training sessions on this policy and related legal requirements, with a special focus on the prohibition of facilitation payments, will be provided to all staff and representatives of JRNY Consulting.

7. Compliance and Monitoring

  • Routine audits will be conducted to ensure policy compliance.

  • Failure to comply will lead to disciplinary action, potentially including termination of employment or contractual relations.

8. Review and Updates

This policy will undergo an annual review and will be updated as needed to ensure its effectiveness and compliance with the most recent legal standards and best practices. 

The next review of this policy is scheduled for 2 January 2025.

9. Comments or Questions?

If you have any questions relating to this Anti-Corruption Policy, please email: info@jrnyconsulting.com. We will endeavour to respond to you promptly.