Anti-Bribery & Anti-Corruption — Facilitation Payments — Government Officials
Our World
We Prevent Bribery and Corruption
In this section, we'll cover:
Our Commitment
Always work with integrity. We never offer or accept a bribe from anyone, especially government officials – and remember, we’re responsible not only for our actions, but also for the actions of anyone who represents Jabil.
For us it’s simple: offering or accepting a bribe from anyone, at any time, is always wrong.
Why It’s Important
Bribery and corruption violate Jabil’s values, our Code, and the laws of countries in which we operate. We protect our employees and our reputation by guarding against corruption and only working with business partners who share our commitment to integrity.
Bribery of a government official and the bribery of commercial personnel, including kickbacks or bribes paid to any Jabil employee, Jabil supplier or Jabil customer, are prohibited by this Code.
How We Do the Right Thing
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No Improper Payments
Do not give or accept bribes or kickbacks, offer facilitation payments or accept or offer any other kind of improper payment.
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Get Preapproval
Disclose and get preapproval (as outlined in our Global Anti-Bribery & Anti-Corruption Policy) for any government-related expenditures, including meals, entertainment and gifts.
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Accurate Books
Keep accurate books and records so that payments can be honestly described and documented.
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Be Aware
Be aware that not reporting a bribe is a violation of this Code.
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Anti-Bribery
Follow our anti-bribery and anti-corruption standards when selecting others that provide services on our behalf. Be vigilant and monitor their behavior. Never “look the other way.” All services must be detailed and carefully documented in contracts, scopes of work, purchase orders and invoices.
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Family Members
Know that gifts to family members of a government official may be considered bribes.
The Global Impact of Bribery and Corruption
We know that paying bribes can harm our reputation and cost millions in fines and fees – but there’s even more at stake. Companies that pay bribes may win business even though their products and services are inferior to ours. In addition, corruption is especially harmful in developing countries where the money from bribes and corruption often supports corrupt regimes.
For all these reasons, we have a zero-tolerance policy on bribery and corruption. It’s not just illegal, it’s completely contrary to the way we do business.
Some of our activities pose a higher risk of bribery and corruption. If you have contacts with local government officials and agencies, such as building license agencies; safety inspectors; fire departments; environmental, labor, electrical, water and sewer inspectors or international governmental organizations, you should be especially vigilant. Exercise caution and get required pre-approvals for government-facing vendors as they present heightened risk. Review our policies and contact the Global Ethics and Compliance Team with any questions.
What It Looks Like
A bribe is anything of value that is given to influence the behavior of someone in government or the private sector in order to obtain business or financial or commercial advantage. A bribe can be something other than cash. A gift, a favor, or even an offer of a loan or a job could be considered a bribe. Before offering anything of value, refer to our policies and ask questions about what’s acceptable (and what’s not).
Government officials include employees of governments, but the term also covers employees of government-owned businesses as well as party officials, candidates for political office, members of the Royal Family and employees of international organizations such as the World Bank.
Facilitation payments are typically small payments to a low-level government official that are intended to encourage the official to perform responsibilities they are already legally obligated to do.
Doing the Right Thing – In Action
I work in a country that is considered high-risk for bribery and corruption. We are considering paying for a consultant who sometimes works with the local government to travel to the U.S. to attend a meeting. We would also provide tickets to a concert after the meeting. Is this allowed?
You need to review the situation with the Global Ethics and Compliance Team. The definitions of a government official in the U.S. and under the UK Bribery Act may be broader than local law and would likely include consultants retained by the local government. If this is the case, the proposed event tickets would not be approved since it is not business related.
Doing the Right Thing – In Action
I was authorized to hire a consultant to help us get local permits needed for a new project. They asked for a $40,000 retainer to “help move the process along.” Should I agree to this payment?
No. Before engaging the consultant, you need to seek guidance from the Global Ethics and Compliance Team and perform due diligence on the consultant. Before agreeing to make any payment, we need to know how the money will be used. We must avoid any vagueness in potential government-facing services. All services must be detailed and carefully documented in the contracts, scopes of work, purchase orders and invoices. Jabil must make sure this money is not used as a bribe or facilitation payment. You need to talk to the Global Ethics and Compliance Team about it before you do anything.
Doing the Right Thing – In Action
A prospective supplier offered me $1,000 to add them to Jabil’s Approved Vendor List (AVL). They are qualified to do the work and their pricing is competitive. Can I take the money and add the supplier to the AVL for Jabil?
No, you cannot. The money or any other thing of value is considered a bribe. A bribe can be anything of value that is given to influence the behavior of someone to obtain a business or commercial advantage. Contact the Global Ethics and Compliance Team or the Jabil Integrity Hotline so that this matter can be assessed.
In the next section, we'll cover:
Government Officials — Procurement — Government Inquiries