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Anti-Corruption Policy

CML is committed to conducting business in an honest and ethical manner and has implemented systems to ensure that bribery, collusion and corruption are prevented.

Committed

We take a zero tolerance approach to such activities and expect all employees to act professionally, fairly and with the utmost integrity at all times. We are fully aware of our obligations and liabilities under UK anti-corruption legislation such as the Bribery Act 2010. Our anti-corruption policy covers all employees, whether temporary, fixed term or permanent, consultants, contractors and anyone who represents the company in dealings with third parties. Any arrangements made with third parties will generally be subject to clear contractual terms and any deviation from these terms must be documented and reviewed. 


Bribery

CML's anti-corruption policy defines bribery as follows:

"The act of giving, promising or offering a financial or other advantage to induce or influence a person to perform improperly a relevant function or activity or to reward a person for the improper performance of such a function or activity".

This definition broadly mirrors the definition given in the Bribery Act 2010 and makes it unacceptable not only for someone to offer/give an incentive which could be considered a bribe, but also for someone to accept such an incentive when it is known or believed that it would constitute a bribe. This means that CML employees need to be mindful of dealings with all third parties, whether customer, supplier or other. 

Of course, corporate hospitality and gifts are often given in good faith in the the interests of building relationships between two companies and are not inherently corrupt. In order to differentiate between these gifts and genuine attempts to influence decisions/actions, CML uses a three-part test to establish the nature of any hospitality or gifts offered either to or by the company to third parties:


  1. Intention - Is the underlying intention of the gift to reflect good working relations between the two companies, or to thank a customer for their custom? Or is there an active intention to influence a decision in the favour of the person offering the gift. 
  2. Value - Is the value of the gift relatively modest in the context of the industry. For example a lunch in a moderately-priced restaurant compared to a bottle of vintage champagne.
  3. Timing - Is the gift being given at a time critical to the making of a decision. Or is it simply an occasion such as Christmas.

    In all cases, the overall test is whether the incentive is reasonable and proportionate to the circumstances.


Collusion

CML's anti-corruption policy defines collusion as follows:

"The cooperation or conspiracy of two or more parties to cause deception for economic gain"

An example of this would be an employee authorising payment of an invoice which they know to be fraudulent in return for an incentive. As with bribery, CML has implemented several processes to ensure that collusion is prevented.  

Apart from the specific activities, processes and systems set up to detect and eliminate instances of corruption, CML promotes a culture of vigilance among all employees and constantly strives to educate our team as to the risks involved. 

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