JTS recognises that day-to-day operations can impact both directly and indirectly on the environment. We aim to protect and improve the environment through good management and by adopting best practice wherever possible. JTS will work to integrate environmental considerations into our business decisions and adopt greener alternatives wherever possible, throughout our operations. In all our activities we aspire to:

• Comply fully with all relevant legal requirements, codes of practice and regulations.

• Prevent pollution to land, air and water.

• Reduce water and energy use.

• Minimise waste and increase recycling where commercially possible.

• Identify and manage environmental risks and hazards.

• Involve customers, partners, clients, suppliers and subcontractors in

the implementation of our objectives.

• Promote environmentally responsible purchasing.

• Provide suitable training to enable employees to deal with their specific areas of environmental control.

• Improve the environmental efficiency of our transport and travel.

All employees are responsible for working towards the objectives contained within this policy.

Signed by Jason Bayliss

Director

 Date.......15/04/2020........

Health and Safety Policy

JTS believe that all work-related injuries and illnesses are avoidable, we are committed to integrating health and safety considerations into all our business activities to ensure the safety and wellbeing of our workforce and the public.

We are committed to:

Preventing injury and harm to all personnel undertaking activities on our behalf

Minimising the societal health and safety risks resulting from our activities

Compliance with relevant legislation and approved codes of practice and other appropriate external and internal requirements

Actively contributing to the development and implementation of new standards.

Gaining full understanding of the hazards and risks associated with our operations and implementing appropriate controls and mitigations.

Ensuring that health and safety is designed integral to our management systems and processes

Using recognised and accredited management systems to ensure that emerging health and safety risks are addressed proactively

Ensuring that line management are suitably equipped and accountable for the delivery of high standards of health and safety performance

We support these commitments by:

Providing adequate resources and competent health and safety advisers to support us in the delivery of our goals

Empowering employees to cascade information, facilitate knowledge transfer and promote a culture of excellence across all departments

Setting and communicating health and safety objectives and targets to reduce risk and drive continual improvement

Communicating accountabilities and commitments within this policy to all staff and contractors to ensure full understanding and compliance

Analysing, reviewing and assessing health and safety data to identify root causes to minimise reoccurrence

Identify and sharing best practice in health and safety performance whether internally or externally.

Ensuring that our contractors demonstrate comparable standards of commitment to health and safety

Actively encouraging and communicating wellbeing opportunities and health initiatives throughout the business

Prevention 

JTS requires its managers, staff, and trainees to act honestly, with integrity and to safeguard any JTS resources for which they are responsible at all times. The purpose of this policy is to set out the responsibilities of managers, staff, and trainees regarding the prevention of fraud, bribery, and corruption and the procedures to be followed where any of these are detected or suspected. 

1. Leadership 

1.1 JTS management is responsible for the prevention, detection, and investigation of irregularities. To discharge this responsibility, management must ensure that an adequate system of internal control is operated. The work of internal audit in reviewing the adequacy and effectiveness of the internal control system will help management to prevent and detect fraud. 

1.2 Prosecution is a particularly effective deterrent because of the risk of a custodial sentence and a criminal record. However, the threat of prosecution only deters if the threat is real. Therefore each and every case arising will normally be referred to the police irrespective of the status of the individual. 

2. Denial of Opportunity 

2.1 Fraud can be minimised through carefully designed and consistently operated management procedures which deny opportunities for fraud. Training in fraud awareness for appropriate members of staff will be co-ordinated by the Management, with support from both internal and external audit. 

2.2 Potential misuse of information technology must be prevented by managing the physical access to terminals and protecting systems with electronic access restrictions. 

3. The Role of Auditors

3.1 When new systems are being designed or existing systems are to be modified, internal auditors can advise 

management on building in ways of preventing or detecting fraud. 

3.2 A continuous review of systems by internal audit may deter attempted fraud and should result in continuous improvements. The risk of fraud should be a factor in audit plans. The external audit can give advice about systems and their reviews of financial checks and balances and validation testing will provide further deterrence. Auditors may also wish to assess systems in place to deter corruption. 

4. Employee Screening

4.1 Potential new members of staff must be screened before appointment in accordance with the Recruitment and 

Selection Procedures prepared by the Administration Department. 

Detection

5. Internal Management Systems 

5.1 This is the most important measure because the risk of processing an irregular transaction is minimised where every transaction is reviewed systematically. Detective checks and balances must be designed into all systems and applied consistently. 

5.2 Systems should identify transactions which have not followed normal procedures. However, deception may be used to make improper transactions appear legitimate. The detective elements in each system must, therefore, be complemented by a general detective approach, to capture suspicions identified through chance, exit interviews and tip-offs. 

6. Staff Responsibilities 

6.1 Every member of staff has a duty to ensure that JTS resources are safeguarded. Staff must alert their manager if they believe an opportunity for fraud exists because of poor procedures or lack of effective supervision. 

6.2 It is the responsibility of every member of staff to report details immediately to their manager or appropriate senior person if they suspect fraud may have been committed. 

6.3 Staff must also assist in any investigations by making available all relevant information and by co-operating in interviews. 

7. Whistleblowing/Public Interest Disclosure 

7.1 JTS complies with the Public Interest Disclosure Act 1998 which states that employees who disclose information on certain matters will be legally protected from being disciplined, dismissed or victimised by their employer as a result. 8. Role of Audit in Detection 

JTS’ defenses against fraud must be robust preventative measures by management, coupled with sound detective checks and balances. The audit should be regarded as a 'long stop'. The internal and external audit may be involved in identifying fraudulent transactions. 

9. Investigation 

Fraud or irregularity occurs unpredictably, in any part and at any level in an organisation. It frequently causes disruption which is out of proportion to the sums involved. Once a fraud is suspected, prompt action is needed to safeguard assets, recover losses and secure evidence for effective legal and disciplinary processes. 

10. Process of Investigation

10.1 Suspected fraud should be reported to the Managing Director who will instigate action and investigation. 

10.2 It is important to ensure that initial investigation is carried out with care and sensitivity, confidential to those who contribute to the investigation, recognising the possibility of malicious accusations. 11. Disciplinary Action 

After proper investigation, JTS will take legal and/or disciplinary action in accordance with the JTS disciplinary procedures where it is considered appropriate. JTS Managing Director will refer each case to the police as early as possible. If the case is not reported to the police, the Managing Director will advise the reason why not. A civil action against the perpetrator may also be appropriate to recover losses resulting from the fraud. The investigation will also consider whether there has been any failure of supervision and if so, appropriate disciplinary action will be taken against those responsible. 

Conclusion 

The circumstances of individual frauds will vary, but it is very important that each case is vigorously and promptly investigated and that appropriate action is taken. JTS views fraud very seriously and it will not be tolerated in any form. Any member of staff found to have committed an act of fraud is liable to immediate dismissal. 

Jason Bayliss

Director

Reviewed 03/07/2020 

JTS is a company based in West Midlands England. We actively seek to provide safe, and environmental-friendly solutions to corrosion control within the petrochemical, gas and civil construction industries. 

Our commitment to human rights 

Respect for human rights is an integral part of our company’s culture. We respect and support the protection of human rights within our sphere of influence. Our commitment to human rights includes the acknowledgment of the following international documents:

1. The Universal Declaration of Human Rights of the United Nations 

2. Fundamental Conventions of the International Labour Organization (ILO) 3. Principles of the United Nations Global Compact 

In our view, the protection of human rights is only possible when we understand human rights, are aware of abuse and know how to manage risks and opportunities to improve the conditions of the people we impact with our operations, management, and supply chain. We have a responsibility to raise our employees’ awareness about human rights related issues and encourage them to safeguard their protection. We know that our business operations have an impact on the people around us. This means we have to minimize negative effects on our business and to increase the positive influence we can have. This refers to our staff as well as job applicants, but also to our sub contractors and suppliers. Furthermore, our commitment to human rights shows respect for the customers we supply with our products and services and for the communities in which we live. 

Our commitment comprises especially the following areas:

1. Diversity and equality

Integrity, openness and mutual respect are important values for us. We are convinced that a work environment that is characterized by equal opportunities and inclusion is vital for sustaining the satisfaction of our employees as well as our acceptance as a responsible product and service provider. We do not tolerate discrimination or harassment of any person.

2. Provision of a good and safe working place

JTS as an employer cares for the health and well-being of its employees. Operational safety and health protection are significant in our business. It is our goal to achieve a positive safety culture for our employees, suppliers, and contractors. Every manager and employee has the duty to help in identifying, evaluating and eliminating any kind of risk to a safe working place. We have a responsibility towards our employees to have appropriate access to needed resources, fair remuneration, training, and education. We enable our employees to maintain a good work-life-balance. We see this as a prerequisite for employees to engage themselves with their families and in the communities in which we live and work.

3. Freedom of association and collective bargaining

We support the ILO core conventions C87 and C98. JTS respect the rights of our workers and employees to join or set up trade unions and workers’ councils of their choice to facilitate close co-operation between employee representatives and management. We respect the principles of collective bargaining and ensure that workers and employees active in trade unions or workers’ organizations are not discriminated against.

4. No acceptance of child and forced labour

We do not accept any form of child labour according to the ILO conventions C 138 and C 182. Also, we do not tolerate forced or involuntary labour of any kind corresponding to the ILO principles C 29 and C 105. No employee is required to lodge deposits or will be deprived of identity papers when starting to work.

5. Protection of local communities and indigenous people

As an international trading company, JTS can on occasions work in many places world-wide. Thus we do have the duty to minimize any negative physical, social and environmental impacts and risks on local communities and indigenous people. We recognize the special circumstances of indigenous peoples and we must understand the concerns and expectations of the communities in which we live and work to safeguard the long-term prosperity of our business. We work continuously with our staff and managers to ensure that they are well informed and trained with regard to the impacts our business can have in order to increase their ability to protect human rights and related issues.

6. Slavery and Human Trafficking.

JTS is committed to driving out acts of modern-day slavery and human trafficking within its business and that from within its supply chains, including sub-contractors, and partners.

The Company acknowledges the responsibility to the Modern Slavery Act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation. These as well as the suppliers of services make up the supply chain within JTS. As part of the companies due diligence processes into slavery and human trafficking, the supplier approval process will incorporate a review of the controls undertaken by the supplier. Imported goods from sources from outside the UK and EU are potentially more at risk for slavery/human trafficking issues. The level of management control required for these sources will be continually monitored. The company will not support or deal with any business knowingly involved in slavery or human trafficking. 

The company Directors and senior management shall take responsibility for implementing this policy statement 

Jason Bayliss

Director

Reviewed 03/07/2020