Anti-Bribery and Anti-Corruption Policy

Private Jet Charter LLC, trading as AircraftCharter (hereinafter referred to as ‘the Company’).

Policy version supplied: August 2024

WHAT DOES OUR POLICY COVER?

This anti-bribery policy exists to set out the responsibilities of
AircraftCharter and those who work for us in regard
to
observing and upholding our zero-tolerance position on bribery and
corruption.
It also exists to act as a source of information and guidance for
those working for AircraftCharter . It helps them
recognise and deal with bribery and corruption issues, as well as
understand their responsibilities.

POLICY STATEMENT

AircraftCharter is committed to conducting business in an ethical
and honest manner and is committed to implementing and enforcing systems
that ensure bribery is prevented. AircraftCharter has
zero-tolerance for bribery and corrupt activities. We are committed to
acting professionally, fairly, and with integrity in all business
dealings and relationships, wherever in the country we operate.
AircraftCharter will constantly uphold all laws relating to
anti-bribery and corruption in all the jurisdictions in which we
operate. We are bound by the laws of the UK, including the Bribery Act
2010, in regard to our conduct both at home and abroad.
AircraftCharter recognises that bribery and
corruption are punishable by up to ten years of imprisonment and a fine.
If our company is discovered to have taken part in corrupt activities,
we may be subjected to an unlimited fine, be excluded from tendering for
public contracts, and face serious damage to our reputation. It is with
this in mind that we commit to preventing bribery and corruption in our
business and take our legal responsibilities seriously.

WHO IS COVERED BY THE POLICY?

This anti-bribery policy applies to all employees (whether temporary,
fixed-term, or permanent), consultants, contractors, trainees, seconded
staff, home workers, casual workers, agency staff, volunteers, interns,
agents, sponsors, or any other person or persons associated with us
(including third parties), or any of our subsidiaries or their
employees, no matter where they are located (within or outside of the
UK). The policy also applies to Officers, Trustees, Board, and/or
Committee members at any level.
In the context of this policy, third-party refers to any individual
or organisation our company meets and works with. It refers to actual
and potential clients, customers, suppliers, distributors, business
contacts, agents, advisers, and government and public bodies – this
includes their advisors, representatives and officials, politicians, and
public parties.
Any arrangements our company makes with a third party is subject to
clear contractual terms, including specific provisions that require the
third party to comply with minimum standards and procedures relating to
anti-bribery and corruption.

DEFINITION OF BRIBERY

Bribery refers to the act of offering, giving, promising, asking,
agreeing, receiving, accepting, or soliciting something of value or of
an advantage so to induce or influence an action or decision.
A bribe refers to any inducement, reward, or object/item of value
offered to another individual in order to gain commercial, contractual,
regulatory, or personal advantage. Bribery is
not limited to the act of offering a bribe. If an individual is on
the receiving end of a bribe and they accept it, they are also breaking
the law.
Bribery is illegal. Employees must not engage in any form of bribery,
whether it be directly, passively (as described above), or through a
third party (such as an agent or distributor). They must not bribe a
foreign public official anywhere in the world. They must not accept
bribes in any degree and if they are uncertain about whether something
is a bribe or a gift or act of hospitality, they must seek further
advice from the company’s compliance manager.

WHAT IS AND WHAT IS NOT ACCEPTABLE

This section of the policy refers to 4 areas:

Gifts and hospitality.
Facilitation payments.
Political contributions.
Charitable contributions.
1. Gifts and hospitality

AircraftCharter accepts normal and appropriate gestures of
hospitality and goodwill (whether given to/received from third parties)
so long as the giving or receiving of gifts meets the following
requirements:

It is not made with the intention of influencing the party to
whom it is being given, to obtain or reward the retention of a business
or a business advantage, or as an explicit or implicit exchange for
favours or benefits.
It is not made with the suggestion that a return favour is
expected.
It is in compliance with local law.
It is given in the name of the company, not in an individual’s
name.
It does not include cash or a cash equivalent (e.g. a voucher or
gift certificate).
It is appropriate for the circumstances (e.g. giving small gifts
around Christmas or as a small thank you to a company for helping with a
large project upon completion).
It is of an appropriate type and value and given at an
appropriate time, taking into account the reason for the gift.
It is given/received openly, not secretly.
It is not selectively given to a key, influential person, clearly
with the intention of directly influencing them.
It is not above a certain excessive value, as pre-determined by
the company’s compliance manager (usually in excess of

£100).

It is not offer to, or accepted from, a government official or
representative or politician or political party, without the prior
approval of the company’s compliance manager.

Where it is inappropriate to decline the offer of a gift (i.e. when
meeting with an individual of a certain religion/culture who may take
offence), the gift may be accepted so long as it is declared to the
compliance manager, who will assess the circumstances.
AircraftCharter recognises that the practice of
giving and receiving business gifts varies between countries, regions,
cultures, and religions, so definitions of what is acceptable and not
acceptable will inevitably differ for each.
As good practice, gifts given and received should always be disclosed
to the compliance manager. Gifts from suppliers should always be
disclosed.
The intention behind a gift being given/received should always be
considered. If there is any uncertainty, the advice of the compliance
manager should be sought.

Facilitation Payments and Kickbacks

AircraftCharter does not accept and will not make
any form of facilitation payments of any nature. We recognise that
facilitation payments are a form of bribery that involves
expediting or facilitating the performance of a public official for a
routine governmental action. We recognise that they tend to be made by
low level officials with the intention of securing or speeding up the
performance of a certain duty or action.
AircraftCharter does not allow kickbacks to be made
or accepted. We recognise that kickbacks are typically made in exchange
for a business favour or advantage.
AircraftCharter recognises that, despite our strict
policy on facilitation payments and kickbacks, employees may face a
situation where avoiding a facilitation payment or kickback may put
their/their family’s personal security at risk. Under these
circumstances, the following steps must be taken:

Keep any amount to the minimum.
Ask for a receipt, detailing the amount and reason for the
payment.
Create a record concerning the payment.
Report this incident to your line manager.
1. Political Contributions

AircraftCharter will not make donations, whether in
cash, kind, or by any other means, to support any political parties or
candidates. We recognise this may be perceived as an attempt to gain an
improper business advantage.

Charitable Contributions

AircraftCharter accepts (and indeed encourages) the
act of donating to charities – whether through services, knowledge,
time, or direct financial contributions (cash or otherwise) – and agrees
to disclose all charitable contributions it makes.
Employees must be careful to ensure that charitable contributions are
not used to facilitate and conceal acts of bribery.
We will ensure that all charitable donations made are legal and
ethical under local laws and practices, and that donations are not
offered/made without the approval of the compliance manager.

EMPLOYEE RESPONSIBILITIES

As an employee of AircraftCharter , you must ensure
that you read, understand, and comply with the information contained
within this policy, and with any training or other anti- bribery and
corruption information you are given.
All employees and those under our control are equally responsible for
the prevention, detection, and reporting of bribery and other forms of
corruption. They are required to avoid any activities that could lead
to, or imply, a breach of this anti-bribery policy.
If you have reason to believe or suspect that an instance of bribery
or corruption has occurred or will occur in the future that breaches
this policy, you must notify the compliance manager.
If any employee breaches this policy, they will face disciplinary
action and could face dismissal for gross misconduct. AircraftCharter
International LLC has the right to terminate a contractual relationship
with an employee if they breach this anti-bribery policy.

WHAT HAPPENS IF I NEED TO RAISE A CONCERN?

This section of the policy covers 3 areas:

How to raise a concern.
What to do if you are a victim of bribery or corruption.
Protection.
1. How to raise a concern

If you suspect that there is an instance of bribery or corrupt
activities occurring in relation to AircraftCharter ,
you are encouraged to raise your concerns at as early a stage as
possible. If you’re uncertain about whether a certain action or
behaviour can be considered bribery or corruption, you should speak to
your line manager, the compliance manager, the director, or the Head of
Governance and Legal.
AircraftCharter will familiarise all employees with
its whistle- blowing procedures, so employees can vocalise their
concerns swiftly and confidentially.

What to do if you are a victim of bribery or corruption

You must tell your compliance manager as soon as possible if you are
offered a bribe by anyone, if you are asked to make one, if you suspect
that you may be bribed or asked to make a bribe in the near future, or
if you have reason to believe that you are a victim of another corrupt
activity.

Protection

If you refuse to accept or offer a bribe or you report a concern
relating to potential act(s) of bribery or corruption, Private
Jet Charter understands that you may feel worried about potential
repercussions. AircraftCharter will support anyone who
raises concerns in good faith under this policy, even if investigation
finds that they were mistaken.
AircraftCharter will ensure that no one suffers any
detrimental treatment as a result of refusing to accept or offer a bribe
or other corrupt activities or because they reported a concern relating
to potential act(s) of bribery or corruption.
Detrimental treatment refers to dismissal, disciplinary action,
treats, or unfavourable treatment in relation to the concern the
individual raised.
If you have reason to believe you’ve been subjected to unjust
treatment as a result of a concern or refusal to accept a bribe, you
should inform your line manager or the compliance manager
immediately.

TRAINING AND COMMUNICATION

AircraftCharter will provide training on this
policy as part of the induction process for all new employees. Employees
will also receive regular, relevant training on how to adhere to this
policy, and will be asked annually to formally accept that they will
comply with this policy.
AircraftCharter’s anti-bribery and corruption
policy and zero-tolerance attitude will be clearly communicated to
all suppliers, contractors, business partners, and any third- parties
at the outset of business relations, and as appropriate thereafter.
AircraftCharter will provide relevant anti-bribery
and corruption training to employees etc. where we feel their knowledge
of how to comply with the Bribery Act needs to be enhanced. As good
practice, all businesses should provide their employees with
anti-bribery training where there is a potential risk of facing bribery
or corruption during work activities.

RECORD KEEPING

AircraftCharter will keep detailed and accurate
financial records and will have appropriate internal controls in place
to act as evidence for all payments made. We will declare and keep a
written record of the amount and reason for hospitality or gifts
accepted and given and understand that gifts and acts of hospitality are
subject to managerial review.

MONITORING AND REVIEWING

AircraftCharter’s compliance manager is
responsible for monitoring the effectiveness of this policy and will
review the implementation of it on a regular basis. They will assess its
suitability, adequacy, and effectiveness.
Internal control systems and procedures designed to prevent bribery
and corruption are subject to regular audits to ensure that they are
effective in practice.
Any need for improvements will be applied as soon as possible.
Employees are encouraged to offer their feedback on this policy if they
have any suggestions for how it may be improved. Feedback of this nature
should be addressed to the compliance manager.

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