Business conduct and compliance

This page sets out how JOOM expects its people, collaborators and suppliers to conduct business in every country where we work. It supplements Working with JOOM: agreements and Jurisdictions and governing law.

Integrity and anti-bribery

1. We do not offer, pay, request or accept bribes or improper payments or advantages of any kind, directly or through an intermediary, to or from anyone, whether a public official or a private person. This includes facilitation payments.
2. We comply with the United Kingdom Bribery Act 2010, including the corporate offence of failing to prevent bribery by persons associated with us, with the anti-bribery and anti-corruption provisions of Egyptian law (including the Penal Code), the United States Foreign Corrupt Practices Act where it applies, the anti-bribery laws of Saudi Arabia, the United Arab Emirates and the countries of Europe, and the law of each other country in which we work.
3. We do not give or accept gifts, hospitality or entertainment that are lavish, that are intended to influence a decision, or that are given during a tender, a permit application or a procurement. Gifts and hospitality of modest value that are ordinary and transparent are acceptable and are recorded.
4. We use agents, introducers or consultants only after due diligence, on written terms that include anti-corruption obligations, and we pay only for genuine services at a market rate.
5. We keep accurate records of our dealings.

Sanctions, export controls and money laundering

1. We comply with the sanctions regimes that apply to our business, including those of the United Kingdom (including the Sanctions and Anti-Money Laundering Act 2018), the United Nations and, where they apply, the European Union and the United States.
2. Before we agree to work, we take proportionate steps to identify the Client, its ownership and control where the project's size or risk requires it, and the source of funds, and we keep records of those steps. We may decline or end a project, or delay a payment, if we believe on reasonable grounds that continuing could breach sanctions, anti-money-laundering, anti-terrorist-financing or anti-corruption law.
3. We do not transfer technology, data or designs in breach of export-control law.

Conflicts of interest

We identify and tell the Client about any actual or potential conflict of interest in a project, and we manage it, including by stepping aside, where we cannot manage it properly. We do not accept an appointment that would put us in a position of conflict with another client without the informed consent of those affected.

Confidentiality and information security

We protect the Client's confidential information and our own. We limit access to information to those who need it, we use secure systems for project files, and we follow data-protection law (see the Privacy notice). We require staff and collaborators to keep client information confidential.

Health, safety and the built environment

1. Safety is a design duty. We design with the health and safety of the people who will build, use, maintain and demolish the building in mind, and we raise risks with the Client and the project team.
2. In the United Kingdom, where we are appointed to a role under the Construction (Design and Management) Regulations 2015 or the Building Safety Act 2022, we comply with the duties of that role. In Egypt and elsewhere, we comply with the local building, fire-safety and occupational-safety law.
3. We do not issue a design that we believe to be unsafe, and we tell the Client in writing if an instruction would reduce the safety of a building.

Honesty in how we present our work

We describe our work accurately. We do not present a design as a built building, we do not claim work done by others, and we credit collaborators. See Disclaimers and representation of projects.

People, fairness and human rights

We treat people with respect and do not discriminate on the grounds of race, colour, nationality, ethnic origin, religion, sex, gender, sexual orientation, age, disability or any other ground protected by law. We do not use forced, bonded or child labour, and we expect our collaborators and suppliers to meet the same standard, and to pay the people who work for them lawfully and on time. We expect the same of the contractors and suppliers on the projects we design, and we raise any concern we see.

Collaborators, suppliers and consultants

We expect those we work with, including related companies and the Egyptian Entities, to follow this page and the law, and we include these obligations in our agreements with them. We may end a relationship with anyone who does not.

Environmental responsibility

We design with attention to the energy, water, materials and waste implications of a building over its life, and to the climate and setting in which it stands, and we comply with environmental law and planning requirements in each country.

Raising a concern

If you see conduct that breaches this page or the law, you can tell us in confidence (see Contacting us and complaints). We will investigate and will not tolerate retaliation against anyone who raises a concern in good faith.

Review

JOOM's management reviews this page from time to time and updates it as the law, our business and our risks change.