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BRIBERY & CORRUPTION POLICY

Cargostore Worldwide (Cargostore) will conduct all of its business in an honest and ethical manner. We are committed to acting professionally, ethically, fairly and with integrity in all our business dealings and relationships. This includes implementing and enforcing effective systems to counter bribery.

Bribery and corruption are punishable for individuals by up to 10 years’ imprisonment and if we are found to have taken part in corruption we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibility seriously.

In this policy, “third party” means any individual or organisation Workers come into contact with during the course of their work for the Company and includes actual and potential customers, suppliers, distributors, business contacts, agents, advisors and government and public bodies, including their advisers, representatives and officials.

The Finance Manager and Quality Manager are the compliance managers under this policy

What is covered by the policy

This policy applies to all individuals working at all levels and grades, including directors, company officers, managers, employees (whether permanent, fixed term or temporary), agents and consultants or any other associated with the company (collectively referred to as “Workers” in this policy).

What is bribery?

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

Gifts & Hospitality

We acknowledge the importance of business networking. This policy does not prohibit normal and appropriate hospitality (given & received) to or from third parties. The giving or receipt of gifts is not prohibited, if all of the following requirements are met:

  • It is not made with the intention of influencing a third party to obtain or retain business or business advantage, or reward the provision or retention of business or a business advantage, or in implicit exchange for favours or benefits.
  • It complies with local law.
  • It is given in our name, not the Workers name.
  • It does not include cash or cash equivalent (such as gift certificates or vouchers); It is appropriate in the circumstances. For example, in the UK it is customary for small gifts to be given at Christmas time.
  • Taking into account the reason for the gift, it is of an appropriate type and value and given at the appropriate time.
  • It is given openly and not secretly.
  • It complies with the provisions of Annex I of this policy.

Gifts should not be offered to, or accepted from, government officials or representatives, or politicians or political parties without the prior consent of the Managing Director.

We appreciate that the market practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift or hospitality should always be considered.

A guide to what we consider to be acceptable with regards to hospitality is at Annex I. This guide will be included below and the agent handbook.

What is not acceptable?

It is not acceptable for you (or someone on your behalf) to:

  • Give, promise to give, or offer, a payment , gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given.
  • Give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure.
  • Accept payment from a third party if you know or suspect that it is offered with the exception that it will obtain a business advantage for them.
  • Accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return.
  • Threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy.
  • Engage in any activity that might lead to breach of this policy.

Facilitation payments and kickback

We do 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 government action by a government official. They are not commonly paid in the UK, but are common in some countries.

If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for payment. If you have suspicions, concerns or queries regarding payment, you should raise these with the Managing Director.

Kickbacks are typically payments made in return for business favour or advantage. All workers must avoid any activity that might lead to, or suggest, that facilitation payment or kickback will be made or accepted by us.

Donations

We do not make contributions to political parties. We only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of the Managing Director.

Your responsibilities

You must ensure that you read, understand and comply with this policy.

You must notify the Managing Director as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. Further “red flags” that may indicate bribery or corruption are set out in Annex II of this policy.

An employee who breaches this policy will face disciplinary action which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other Workers if they breach this policy.

How to raise a concern

Workers are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with a Managing Director.

 

Protection

The Company encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. If a Worker believes that they have suffered any detrimental treatment as a result of refusing to take part in bribery or because of raising a genuine concern in good faith, they should inform the Managing Director immediately. If the matter is not remedied, then employees should raise it formally using the Company’s Grievance Procedure.

Training and communication

Appropriate training on this policy will be given to Workers.

Where proportionate and appropriate to do so, our approach to bribery and corruption will be communicated to all suppliers, contractors and business partners.

 

Who is responsible for the policy?

The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under control comply with it.

The Managing Director has primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness and dealing with any queries on its interpretation. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given training on it.

 

Monitoring & review

The Managing Director will monitor the effectiveness and review the implementation of this policy annually.

This policy does not form part of any employee’s contract of employment and maybe amended at any time.

ANNEX I

This will be included in the employee/agent handbook.

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

Gifts and hospitality

The tables below set out guidance on giving or receiving gifts or hospitality. If you have any concerns whatsoever, you should speak to the Managing Director.

Remember, any gift or hospitality, however small or low in value may be construed as a bribe. It is important for you always to consider the purpose or motive behind the giving or receiving of gifts or hospitality. If you find yourself in one of the situations set out in Clause 5 of the anti-corruption and bribery policy (“What is Acceptable”), or the giving or receiving of a gift or hospitality is in any other way improper, then it must not be given or received, regardless of its value.

You should also be careful if you give or receive a number of small gifts or attend a number of hospitality events with the same individual or organisation over a period of time. Whilst in isolation, a small gift or hospitality event might not be inappropriate, taken together in terms of the amount or frequency it might not be reasonable or justifiable.

Register of gifts and hospitality

The company must keep a register of gifts or hospitality received in excess of
£25.00 and the amount spent. This will enable the company to fulfil its obligations with regard to anti-corruption and bribery.

Facilitation payments/”kickbacks”

We do not make, and will not accept, facilitation payments or “kickbacks” of any kind. Please refer to clause 6 of the anti-corruption and bribery policy.

ANNEX II

Potential risk scenarios; “red flags”

The following is a list of possible red flags that may arise during the course of working and which may raise concerns under anti-bribery laws. The list is not intended to be exhaustive and is for illustration purposes only.

If you encounter any of these red flags, you must report them promptly to the Managing Director:

  • You become aware that a third party engages in, or has been accused of engaging in, improper business practices.
  • You learn that a third party has a reputation for paying bribes, or requiring bribes are paid to them.
  • A third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business.
  • A third party demands lavish entertainment or gifts commencing or continuing contractual negotiations or provision services.
  • A third party requests that you provide employment or some other advantage to a friend or relative.
  • A third party insists on the use of side letters or refuses to put terms agreed in writing.
  • You notice that we have been invoiced for a payment that appears large given the service stated to have been provided.
  • A third party request or requires the use of an agent, intermediary, consultant or supplier that is not typically used by or known to us.
  • You are offered an usually generous gift or offered lavish hospitality by a third party. 

Reviewed and updated February 2020