Policies and Legal • Anti-corruption
Anti-Bribery Policy CTS Offshore and Marine Limited (hereafter CTS) strives to undertake our business fairly with honesty and transparency. This must be reflected in every aspect of our business affairs.
The action and conduct of CTS officers, directors and employees (hereafter referred to collectively as ‘personnel’) as well as others acting on CTS’s behalf are essential to maintaining these standards. To that end, all CTS personnel, including agents, consultants, contractors and suppliers involved in CTS’s operations must read, become familiar with and comply with this Anti-Bribery Policy and the Gifts and Entertainment Policy.
Compliance with Anti-Bribery Laws It is CTS’s policy to comply with all laws, rules, and regulations governing anti-bribery and corruption law, in all the countries where we operate. CTS has a zero-tolerance approach to acts of bribery and corruption by all personnel. Any breach of this policy will be regarded as a serious matter by the company from which disciplinary action is likely to result.
Under UK law (UK Bribery Act 2010), bribery and corruption is punishable for individuals by up to ten years imprisonment. If the company is found to have taken part in the corruption or lacks adequate procedures to prevent bribery, it could face an unlimited fine and be excluded from tendering for Government contracts and face untold damage to its reputation.
The payment or offer to pay bribes, or provisions of, or offer to provide gifts or anything of value for improper purposes, to obtain or retain business or any other benefit (whether for CTS Offshore and Marine or any other party) is prohibited. Such payments or gifts are also forbidden under the terms of this policy and may result in immediate dismissal for those involved in their payment or receipt.
• CTS Offshore and Marine is required to keep financial records and to have appropriate internal controls in place which will evidence the business reason for making payments to third parties. Application of the Policy
Definition and Interpretation Bribery is committed when an inducement or reward is provided, in order to gain any commercial, contractual, regulatory or personal advantage for CTS Offshore and Marine or another party.
This policy applies to individual employees, agents, sponsors, intermediaries, consultants or any other people or bodies associated with CTS Offshore and Marine or any of its subsidiaries and employees.
No bribes of any sort may be paid or accepted from customers, suppliers, politicians, government advisors or representative’s private person or Company. It is not permitted to establish accounts or internal budgets for the purpose of making facilitation bribes or influencing transactions (slush funds).
CTS Offshore and Marine recognise that to refuse a gift in certain circumstances and/or countries would cause offence to our trading partners.
The test to be applied in all circumstances is whether the gift or entertainment is reasonable and justifiable. What is the intention of the gift? Is the gift being offered for something in return (quid pro quo). This policy does not prohibit the following practices providing they are customary in a particular market, or are appropriate and properly recorded. Pleases refer to our code of conduct and gifts policy for further information.
The presentation, detection and reporting of bribery is the responsibility of all personnel throughout the company. Suitable channels of communication by which employees or others can report confidentially any suspicion of bribery must be provided by all personnel in positions of responsibility to all those reporting to them, even they report indirectly. Thus, the top level of management and all levels below pledge to listen to, and treat with confidence, any reports of bribery from any level of the organization.
Reporting incidents of Bribery and Corruption.
If you become aware that an activity or conduct which has taken place which you suspect is a bribe (or corrupt) you have a duty to report it. Any such incidents should be reported to your supervisor or, if that is not possible (for example if you are reporting your supervisor) to a higher level in the management hierarchy.
For further clarification, please contact CTS Offshore and Marine operations department on +44 207 653 1956.
Gifts and Entertainment Policy
CTS Offshore and Marine Limited (CTS) strives to undertake our business fairly with honesty and transparency. This must be reflected in every aspect of our business affairs. The CTS Gifts and Entertainment Policy provides guidelines for business related gifts and entertainment given or received by
CTS personnel and sets forth the limits and standards to be applied throughout the company.
This Policy aims to set the spirit of what is allowable with regard to business gifts and entertainment. However, it can never be an exhaustive list of every possible scenario. CTS recognises that to refuse a gift or specific hospitality in certain circumstances and/or countries would cause offence to our trading partners. Nonetheless, it is still the right thing to return the gift if it is inappropriate (due, for example, to its excessive value, or to the expectation that something might be given in return). When giving or receiving such courtesies personnel are required to always consider all of the following factors:
• Is it appropriate?
• Is it reasonable?
• Is it justified?
• Would you be comfortable if the courtesies became known to senior management of CTS?
• Would you be comfortable if the courtesies became known to a reasonable and moral individual or authority outside the company?
• Even if it does fit the above criteria, might anything that does not fit the above criteria be expected or hoped for by the buyer in return?
The CTS Gifts and Entertain Policy contains four sections:
• Section 1 – Application of the Policy
• Section 2 – General Principles
• Section 3 – Specific rules and examples of business courtesies allowed and prohibited by the Policy
• Section 4 – Non compliance
Section 1 – Application of the Policy
This policy applies to, all CTS personnel including contractors, agents and third parties whenever are they dealing with (or frequently deal with, or might conceivably deal in future with) CTS. It applies worldwide.
CTS personnel must obligate all consultants, agents, importers, dealers and other representatives, if acting on behalf of CTS, to comply with the terms of these guidelines.
Failure to comply with this policy can lead to disciplinary action up to, and including dismissal from the company. Before you offer or accept a gift or any form of hospitality, you should refer to this policy.
Section 2 – General Principles
The term business courtesy includes meals and entertainment. CTS personnel may provide or accept business courtesies provided:
The CTS Gifts and Entertainment Policy is adhered to at all times.
The practice does not violate any law or regulation, or the standards of conduct of the recipient’s organisation.
Gifts do not exceed the value of £150 or local currency equivalent.
• Business courtesies offered are not done so for the purpose of influencing a business decision and cannot be reasonably interpreted as such.
• Costs associated with the business courtesies are limited to reasonable expenses.
• The gift or entertainment would not negatively impact the reputation of the company of those involved and are not lavish or extravagant.
• Business partners must always be present at the meal/ event. November 2010 2
• CTS personnel offering or accepting the gift or entertainment would be comfortable to discuss the case with executive CTS and TML management.
• Extra care must also be taken when dealing with public officials, as in certain countries it can be illegal to entertain these officials. As a general rule gifts or entertainment of public officials are discouraged and should not be undertaken without the direct authorisation of your local legal counsel, line manager and Senior Manager or Director.
Section 3 – Rules and Specific Examples
Section 3.1 Business Entertainment
It is possible to accept certain entertainment from business partners in a way which respects their good intentions. However, the instructions in Section 2 and the following guidelines must be followed:
Meals – we understand that in certain parts of the world meetings are held over lunch and dinner and are a normal way of undertaking business. Hence, we will not place an arbitrary restriction on the number of business-related meals CTS personnel may attend. However, you must ensure they are business related, that the business partner is always present, that CTS’s independence is not compromised and that you have a record of all events for review by our auditors if required.
• Annual gathering around a festive time or business event will be deemed acceptable provided, that there is not even the perception that it will, or intends to, compromise sound business principles.
• Any social gathering, or interaction with our suppliers, dealers, customers and other parties with whom we liaise in a business capacity must be conducted in locations or establishments which are locally recognised as appropriate for the conduct of business.
• Domestic travel can be acceptable if it’s reasonable in the circumstances and directly business-related.
• Airline travel funded a business partner is not permitted except if it is a client with whom we have a contract stating this is to be reimbursed by the client as a business expense.
• As a general rule, gifts to or entertainment of public officials are discouraged and should not be undertaken without the direct authorization of your local legal counsel, line manager and CTS director.
Section 3.2 Examples of gifts and hospitality that can be permitted
• Gifts not exceeding £100 in value and complying to our Anti-Bribery Policy and all stipulations made in the Gifts and Entertainment Policy
• Normal and appropriate hospitality (given or received).
• The giving of ceremonial gifts on a festival or at another special time.
• Gifts/hospitality which is not offered/accepted with an expectation of reciprocity.
• Gifts/hospitality provided voluntarily with no intention to create influence.
• Promotional gifts which display the business partner’s logo or web site address.
Section 3.3 Examples of gifts and circumstances which are NOT acceptable and are NOT permitted
• Gifts/hospitality which are intended to influence a decision or attain an advantage.
• Where gifts or hospitality is offered with the intention to receive something in return.
• Gifts/ hospitality which are not nominal in value and do not from part of a normal sales promotion.
• Gifts of cash or cash.
• Mementos or souvenirs in the form of currency.
• Any type of discounts which are not available to all company employees.
• Tickets for an event (such as athletic, theatrical or cultural) where the supplier is not in attendance.
Section 4 Non-Compliance
Compliance with the CTS Gifts and Entertainment Policy will be reviewed as part of CTS audit and assurance activities.
To report incidents of non-compliance with this Policy you should contact your supervisor or, if that’s not possible (for example if you’re reporting your supervisor) to a higher level in the management hierarchy.
Section 4.1 Out of Policy Gifts
If you are offered or receive a gift, from our business partners, which does not comply with this Policy please undertake the following actions:
• Where possible, do not accept the item.
• Apologize if appropriate, and limit any offence that might be taken.
• Inform the business partner that the reason for your refusal is CTS’s Gifts and Entertainment Policy.
• If you cannot reject the gift (for example, for reasons of cultural sensitivity), inform your supervisor of the details.
• Where practical, store the gift on-site in a secure manner.
• As soon as possible, make arrangements to donate the item to a recognized charity.
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