AddressUnit 8, Atley Way, North Nelson Industrial Estate, Cramlington
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Office01670 716811
Write usenquiries@cpfl-tvs.co.uk
CPFL Anti-Corruption Policy
Purpose:
The purpose of this Anti-Corruption Policy is to reinforce a culture of integrity at Cramlington Precision Forge Ltd. (CPFL) and ensure strict compliance with anti-bribery and anti-corruption laws across all jurisdictions where CPFL operates.
Scope:
This Policy applies exclusively to Cramlington Precision Forge Ltd. (CPFL). All employees, directors, and members of CPFL’s leadership must comply with this Policy and its associated procedures, even if local laws permit behaviors that this Policy prohibits. The higher and more restrictive standard will always apply. Additionally, third parties representing or acting on behalf of CPFL must conduct themselves in accordance with this Policy’s anti-corruption rules.
References:
Code of Conduct
Human Rights Policy
Risk Management Policy
Definitions:
Administrator: Any member of the Board of Directors, Fiscal Council, Advisory Committees, and the Executive Board of CPFL.
Anything of Value: Includes, but is not limited to, money, gifts, meals, entertainment, sponsorships, donations, job opportunities, goods, or properties.
Bribery: The offer, promise, payment, or granting of Anything of Value to improperly induce a Government Official or any other person to provide an Improper Advantage.
Corruption: Dishonest, unethical, or illegal conduct by someone in a position of authority, often involving an Improper Advantage to gain personal or business benefits.
Facilitation Payments: Payments made to expedite or secure routine governmental actions by a Government Official.
Government Official: Includes elected officials, employees, agents, or representatives of any government or state-owned entity, and officials in international organizations like the United Nations.
Improper Advantage: A benefit that a company or individual is not entitled to, often obtained through bribery or corrupt practices.
Third Parties: Any individual, company, or entity doing business with CPFL, including suppliers, clients, business partners, and recipients of socioenvironmental investments.
Principles:
CPFL is committed to conducting business with the highest standards of integrity and ethics. Corruption is illegal, unethical, and incompatible with CPFL's values. CPFL has zero tolerance for bribery and corruption in any form. All activities must comply with applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, as well as local laws in all jurisdictions where CPFL operates.
Prohibitions:
Bribery: Employees and administrators are prohibited from giving, promising, offering, or authorizing payments or Anything of Value to any Government Official or private person to obtain an Improper Advantage.
Facilitation Payments: These are strictly prohibited and must not be made by any employee or administrator of CPFL.
Cash Gifts: It is forbidden to give cash gifts or cash equivalents, such as gift cards, to Government Officials or private persons.
Political Contributions: Employees and administrators must not make political donations or contributions on behalf of CPFL, including donations to political parties, candidates, or campaigns.
Third Parties: Employees and administrators must not use third parties to carry out activities that CPFL is prohibited from performing directly.
Guidelines:
Socioenvironmental Investments: While CPFL may make socioenvironmental investments, these must not be used to gain an unfair or improper advantage. All such investments must comply with this Policy and the Socioenvironmental Investments Policy.
Gifts, Meals, and Entertainment: Permissible if compliant with this Policy. Any gifts, meals, or entertainment offered to Government Officials exceeding established thresholds must receive pre-approval from Corporate Integrity.
Per Diem to Government Officials: Allowed only in limited cases with prior approval from Corporate Integrity.
Due Diligence: Perform appropriate Anti-Corruption Due Diligence on third parties and business acquisitions to identify potential risks.
Red Flags: Be vigilant for any Red Flags that may indicate potential corruption risks and report any concerns.
Recordkeeping: Maintain accurate and transparent records of all CPFL business transactions.
Cooperation: Employees and administrators must fully cooperate with investigations and maintain confidentiality.
Training: Corporate Integrity will conduct periodic anti-corruption training, which is mandatory for all employees.
Governance:
Board of Directors: The Board of Directors, with support from the Audit Committee, is responsible for supervising the implementation of this Policy.
Compliance Officer: Manages the Anti-Corruption Policy, overseeing Corporate Integrity, and reports directly to the Board as needed.
Consequences Management and Responsibilities:
Violations: Any violation of this Policy will result in disciplinary actions, which may include dismissal.
Legal Penalties: Violations of anti-corruption laws can lead to civil or criminal penalties.
Termination of Third-Party Relationships: CPFL may terminate its relationship with any third party found to be in violation of this Policy.
Reporting: Employees, administrators, and third parties must report any suspicious activity or potential violations immediately through the Whistleblower Channel.
General Provisions:
This Policy must be reviewed periodically, at least once every three years, to ensure its relevance and effectiveness.
This Anti-Corruption Policy is specifically tailored to CPFL, ensuring it meets the company's operational needs while maintaining a strong commitment to integrity and legal compliance.
