Anti-Bribery.

The Cartwright Group is committed to conducting all of its business in an honest and ethical manner. 

In accordance with the Bribery Act 2010 we operate governance by implementing and enforcing robust policies and procedures to guard against any illegal behaviour. 

The Cartwright Group acts openly in relation to all of its dealings with customers, colleagues, suppliers and all third party contacts. Please refer to the Group’s Anti Corruption and Anti Bribery Policy as detailed below. If any of our colleagues, customers, suppliers or any third party we work with have any concerns or issues that they wish to raise then they should contact our Managing Director.

 The Cartwright Group has a zero tolerance approach to any breach of the Bribery Act 2010 and any issues raised will be treated with the utmost importance.

Policy Statement

The Cartwright Group (Cartwright) is committed to conducting business fairly, ethically and within the law. As part of the UK Government’s commitment to eradicating bribery, the Bribery Act 2010 came into force on 1 July 2011. We run our business honestly and will not tolerate bribery or corruption in any of our dealings or relationships or from any of our colleagues. We therefore have systems in place to prevent bribery and corruption and require all our employees and associated persons to make decisions in line with it. Cartwright does not tolerate any form of bribery and corruption.

Who is Covered by this Policy?

The Cartwright Group (Cartwright) is committed to conducting business fairly, ethically and within the law. As part of the UK Government’s commitment to eradicating bribery, the Bribery Act 2010 came into force on 1 July 2011. We run our business honestly and will not tolerate bribery or corruption in any of our dealings or relationships or from any of our colleagues. We therefore have systems in place to prevent bribery and corruption and require all our employees and associated persons to make decisions in line with it. Cartwright does not tolerate any form of bribery and corruption.

What is Bribery?

Bribery is any activity that is a criminal offence under the Bribery Act 2010. There are four offences (the “Bribery Act Offences”):

  • bribing another person (section 1);
  • being bribed (section 2);
  • bribing a foreign public official (section 6); and
  • failure of a commercial organisation to prevent bribery (section 7).

Bribing another person (section 1)

Where a person (P) offers, promises or gives a financial or other advantage to another person (R), and P intends the advantage to induce R to perform a relevant function or activity improperly, P commits an offence.

A relevant function or activity means one that is:

  • connected with business;
  • performed in employment; or
  • performed on behalf of another body, that should be performed in good faith, or impartially, and/or by a person in a position of trust.

Being bribed (section 2)

Where a person requests, agrees to receive or accepts a financial or other advantage intending that a relevant function or activity is performed improperly he commits an offence.

Bribing a foreign public official (section 6)

A person (P) who bribes a foreign public official commits an offence if it is P’s intention to:

  • influence him in his capacity as a foreign public official; and
  • obtain or retain business or an advantage in the conduct of business.

Failure of a commercial organisation to prevent bribery (section 7)

A relevant commercial organisation is guilty of an offence if a person associated with it bribes another person intending to obtain or retain business for the organisation, or an advantage in the conduct of the organisation’s business.

Gifts, Hospitality, Entertainment and Expenses

All those associated with Cartwright must not engage in any activity that might lead to, or suggest, a conflict of interest with the business of Cartwright.

The offering, or giving, of gifts, hospitality and entertainment must:

  • not be given/received with the intention of influencing a third party to obtain or retain business or a business advantage, to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
  • not constitute an offence under the Bribery Act;
  • comply with local law;
  • be given at corporate level not an individual level;
  • not include cash or a cash equivalent;
  • be appropriate, reasonable, proportionate, given in good faith at an appropriate time;
  • be given openly; and
  • not be offered to, or accepted from, government officials, representatives, politicians or political parties without the express prior approval of a member of the Cartwright Board of Directors.

Facilitation Payments and Kickbacks

Cartwright does not make, and will not accept, facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure, or expedite, a routine administrative action by a UK or foreign government official. Kickbacks are another way of describing a bribe and typically consist of payments made in return for a business favour or advantage. You must not engage in any activity that might lead to, or suggest, that a facilitation payment or kickback will be made, or accepted, by Cartwright.

Cartwright recognises that in some countries facilitation payments are permitted in law. Cartwright is subject to the provisions preventing facilitation payments in the UK regardless of whether local law permits facilitation payments. They are therefore completely prohibited by Cartwright regardless of country.

Donations

Cartwright does not make contributions to political parties. We only make charitable donations that are legal and ethical under local laws and practices. No donation of any kind must be offered, or made, on behalf of Cartwright without the express consent of a member of the Board of Directors of Cartwright, or the Group General Counsel and Company Secretary.

Your Responsibilities

You must ensure that you have read and understand the terms of this Policy. You must comply with its terms at all times when acting on behalf of Cartwright. You must inform Cartwright of the details of any third party or other engaged by you on behalf of Cartwright and you must ensure that they agree to be bound by, and comply with, the terms of this Policy. If you employ staff who act as agent on behalf of Cartwright or engage others to do so (where permitted) you must ensure that those persons are fully aware of the terms of this document, and where necessary ensure training is provided. Under no circumstances may you offer gifts (cash or otherwise) to any of our colleagues. Any such offer shall be refused. Offers of corporate hospitality are subject to the provisions of paragraph 4 above and may only be accepted by colleagues if they have obtained the appropriate authority in advance. Colleagues must declare any offers received.

Record Keeping Provisions

You must ensure that you retain documentation identifying and relating to any third party or other engaged by you on behalf of Cartwright.

Communication

This Policy will be communicated to our suppliers, contractors, agents and business partners who will be asked to review the Policy and agree to abide by its terms.

Raising Concerns and Seeking Guidance

Employees, suppliers or agents can make contact confidentially with Cartwright by writing to:

The Board of Directors
c/o The Managing Director
The Cartwright Group
Atlantic Street
Broadheath
Altrincham
Cheshire WA14 5EW.

Anyone raising a concern in good faith will not be criticised or penalised in any way even if it is shown, after investigation, that they were mistaken. Any form of reprisal or victimisation against anyone who has raised a genuinely held concern is forbidden and will not be tolerated and itself will be treated as a disciplinary matter.

Penalties

Violations of the UK Bribery Act 2010 are a serious matter and could result in significant criminal and/or civil, penalties for Cartwright and for those individuals responsible for an offence. Penalties include imprisonment for individuals committing the offence for up to 10 years together with unlimited fines for individuals and the business. Senior Officers who were aware of the bribes may also face penalties.

Fines imposed on individuals WILL NOT BE paid by Cartwright. A violation will also result in disciplinary action by Cartwright, up to, and including termination of employment or other contract.