BUSINESS ETHICS AND CODE OF CONDUCT, ENTERTAINMENTS & GIFTS AND CONFLICT OF INTERESTS

Purpose :


  • CMRC employees are required to maintain the highest ethical standards in the conduct of their affairs, both in a professional and personal capacity. The aim of this Handbook is to ensure that each employee conducts his or her affairs, and the business of CMRC, with the utmost integrity and complies with all applicable laws and regulations in a manner that excludes any consideration of personal advantage or gain. Given the close ties between CMRC and the Government of Abu Dhabi, the importance of adhering to the policies set out in this Handbook cannot be over-emphasized.
  • This Policy shall apply, in its entirety, to all employees (including direct hires, temporary contractors, interns, trainees, volunteers, consultants, secondees, directors etc.).
  • In all circumstances, employees should avoid putting themselves into a situation which may lead to breaching their ethical obligations; in situations of doubt as to whether any action or proposed action constitutes a violation of this Handbook, please consult your immediate manager or a member of CMRC HR Department.

CMRC Values


  • Each employee shall, throughout his tenure at CMRC, use his best endeavors to adhere to CMRC’s values (as set out below) in every aspect of his employment including, without limitation, time-keeping, appraisals, dealing with other employees and personal and work conduct. CMRC’s core values are:

Integrity. Adhere to the highest standards of professionalism, ethics and personal responsibility, worthy of the trust our patients place in us.
Quality. Maintain the highest standards and achieve them by continually measuring and improving our outcomes.
Compassion. Provide the best care, treating patients and family members with dignity, sensitivity and empathy.
Teamwork. Value the contributions of all, blending the skills of individual staff members in unsurpassed collaboration
Trust. Earn the trust and confidence of our patients, families and the communities we serve
Diversity. Be inclusive; embrace and value different backgrounds, opinions, and experiences.
Achievement. Strive for excellence in all we do. Our focus is on continuous improvement, progress and achievement of individual and group goals.

Respect and Language


  • One of the challenges of a multicultural workplace is the variety of languages and the choices we make in expressing ourselves. In CMRC we believe that all our staff wish to show respect to each other and will strive to maintain a high standard of personal conduct.
  • In simple terms this means avoiding the use of any profane or potentially offensive language. If you are in any doubt about your choice of words then stop and find a different way to express yourself. Most of us do this automatically but it’s a good thing to occasionally reflect on our unconscious language habits.
  • Displaying professionalism and showing respect for our colleagues also requires everyone to be aware of the content of their conversation topics – particularly in public areas. Be sure to avoid any conversations that other colleagues may judge to be inappropriate gossip, or having discussions that involve the sharing of potentially sensitive personal or CMRC data.

Entertainment and Gifts


  • Reasonable, necessary and proportionate entertainment and/or gifts may be given by CMRC employees to third parties, at CMRC’s expense, subject to senior management approval, provided that:

– the third party in question conducts significant and/or strategic business with CMRC;
– the entertainment or gifts are consistent with professional and ethical business practices. Unless there are exceptional reasons not to do so, entertainment and gifts should be sourced and agreed;
– the entertainment or gifts given are of sufficiently limited value and in a form that will not be construed as a bribe or pay-off;
– the entertainment or gifts given are not in violation of applicable laws; and
– public disclosure of any fact or detail will not embarrass CMRC, its management or its employees.

Entertainment and Payments offered to CMRC Employees


  • Hospitality given and received is part of the general establishment of good business relationships. In the event you are offered hospitality (other than of a minor nature such as lunch), you should discuss this with your superior before accepting. If he or she regards the hospitality offered as unsuitable or excessive, you may be asked to refuse the invitation. In particular:

– CMRC employees shall not seek, or accept for themselves or others, any gifts, favors, entertainment, payments, nor shall they seek or accept personal loans other than conventional loans at market rates from financial institutions, or any persons or business organizations that do or seek to do business with or is a competitor of CMRC;
– Strict standards and, if necessary, disclosure are expected from all CMRC employees with respect to gifts, services, discounts, entertainment or considerations of any kind from clients or suppliers. Gifts received by you or your family from CMRC clients or suppliers are to be treated as the property of CMRC;
– Use of clients or suppliers facilities (such as cars, vacation homes, etc.) by CMRC employees (including families and friends) for personal use is strictly prohibited; and
– It is strictly prohibited to accept a gift in cash, or cash equivalent, such as stocks or other forms of marketable securities of any amount as this may contravene applicable share trading, market abuse or insider dealing regulations both here and in other jurisdictions. For the avoidance of any doubt, you should contact your line manager if you are involved in the trading of any marketable securities.

Conflicts of Interest


  • CMRC employees should endeavor to avoid any situation which involves, or may involve, a potential conflict of interest between their personal interests and the interests of CMRC. As in all other aspects of their duties, employees dealing with customers, suppliers, contractors, competitors or any person doing or seeking to do business with CMRC should always act in the best interests of CMRC.
  • Each employee shall make prompt and full disclosure in writing to their supervising manager of any situation which may involve a potential conflict of interest. Such conflicts include, but are not limited to:

– having any direct or indirect personal financial interest in any CMRC project;
– ownership by an employee or by a member of an employee’s family of a significant interest in any outside enterprise which does or seeks to do business with, or is a competitor of, CMRC;
– acting as a broker, finder, go-between or otherwise for the benefit of oneself or a third party in transactions involving or potentially involving CMRC or its interests;
– any other arrangements or circumstances, including via/indirectly through family or other personal relationships, which might dissuade an employee from acting in the best interests of CMRC; and
– utilizing CMRC funds for personal or immoral, unethical unlawful purposes.

Conflicts of Commitment


_ With the acceptance of full-time employment (or other arrangement) with CMRC, an employee makes a commitment to CMRC. All employees are expected to devote their primary professional loyalty, time, and efforts to serve CMRC. Employees may sometimes engage in outside professional workto the extent these activities serve CMRC interests as well as those of the participant, and subject to the written approval from CMRC management of such commitments. In all cases, such outside interests should not interfere with the performance of one’s duties to CMRC.
_ Employees are expected to demonstrate a high level of expertise at CMRC and as a result may be required on occasion to provide advice to third parties on a consultancy basis. Offers of consultancy work should be notified to CMRC senior management for approval prior to acceptance. In accepting consultancy work, employees will be expected to ensure that the work undertaken does not conflict with CMRC’s objectives or interfere with the performance of their responsibilities within CMRC.
_ Potential conflicts of commitment by you or knowledge of a potential conflict of commitment by any other employee must be disclosed to senior management. In coordination with senior management, the relevant director or relevant person within CMRC should resolve related conflicts of commitment, and update the respective CMRC HR Department accordingly.

Confidential Information


_ Given the sensitive nature of CMRC business and, in particular, the benefits of the special relationship that CMRC shares with the Government of Abu Dhabi, it is essential that any Confidential Information (as defined below) provided to, or observed by, employees (whether in person, over the telephone, via email, or in any other form, regardless of whether it is expressly stated as being confidential) is not to be disclosed to a non-CMRC employee without first receiving express permission from the individual’s immediate supervisor or the Legal Department. Moreover, Confidential Information should only be shared internally within CMRC or with professional advisers on a need-to-know basis. If there is any doubt as to whether or not any information can be disclosed or is confidential in nature, it is the responsibility of each individual employee to check with his or her immediate supervisor or with the Legal Department prior to making such disclosure. All employees should use their discretion when discussing work related matters in casual settings when away from the office (for example, while at lunch, on a plane, at home, etc.) or even within the office building (such as in elevators).
_ If required by effect of law or for any other purpose permitted by the Company in writing, when disclosing Confidential Information to a third party (i.e. a person or entity not within or employed directly by CMRC), for example, in connection with a new or existing project or anything related to your work or the business of CMRC, you must ensure that the recipient of such Confidential Information treats that information confidentially and, when necessary, has entered into an appropriate confidentiality arrangement with CMRC. An agreement must be entered prior to making any disclosure of Confidential Information to a third party. The first form is a “one-way” confidentiality letter and the other form is a “reciprocal” confidentiality agreement. The appropriate form should be used based on whether or not Confidential Information will be shared only by CMRC, in which case a one-way letter is appropriate, or if the exchange of Confidential Information will be mutual, in which case the reciprocal agreement is appropriate. The Legal Department should approve all initial drafts of such forms prior to their distribution. Furthermore, all confidentiality agreements (whether or not using our forms) have to be reviewed and approved by the Legal Department.
_ The confidentiality provisions contained in this Handbook shall remain in full force and effect notwithstanding any termination or expiry of an employee’s contract, engagement or employment with CMRC. Any breach by an employee of these rules may result in immediate discharge and/or legal proceedings.
_ Confidential Information means all information of whatever nature relating wholly or partly to employment or the affairs of CMRC, which:

– is supplied by or on behalf of CMRC in writing or orally and whether before or after the date of an employee’s engagement;
– is obtained by the employee in writing or orally, through or following discussions with the management, employees, clients, suppliers, agents or advisers of CMRC;
– is acquired by observation by the employee at the offices or other premises of CMRC or its suppliers or clients; or
– consists of any reports, analyses, compilations, studies or other documents prepared by, on behalf of, or for, CMRC.
The confidential information of third parties on CMRC premises should also be protected. It is _ forbidden to bring confidential material of a third party to CMRC offices without that party’s written permission. Illegal copying of computer software programs is also prohibited.
Confidential Information including patient information, or practice issues in public places including social media even when no names are used. This caution applies to social networking sites, e.g. Facebook, blogs, emails, Twitter and other electronic communication media.

Interaction With and Treatment of Colleagues


_ Treat your colleagues with respect and work with them in a professional, collaborative and co-operative manner. It is important to recognize that others have a right to hold different opinions.
_ Acknowledge the experience and expertise of colleagues, and respect the contribution of all practitioners and staff involved in the care of a patient and in the development of CMRC.
_ Communicate clearly, effectively, respectfully and promptly with other nurses and health care professionals caring for the patient especially when handing over or transferring care to another member of the nursing staff, health professional, practitioner or service provider of CMRC.
_ Your behavior towards colleagues should always be respectful and not include dismissiveness, indifference, bullying, verbally abuse, harassment or discrimination. Do not discuss colleagues in public places or on social media. This caution applies to social networking sites, e.g. Facebook, blogs, emails, Twitter and other electronic communication mediums.
_ Work with your colleagues, the Nurse Manager and management of CMRC to monitor the quality of your work and maintain the safety of those in your care.
_ Support, mentor and teach colleagues and other members of the health care team, especially those who are not as experienced as you.
_ Intervene to stop unsafe, incompetent, unethical or unlawful practice. Discuss the issues with those involved. Report to the Nurse Manager or management of CMRC at the earliest opportunity. Do not discuss, gossip or talk to other colleagues or third person(s). Take action to safeguard the patients.

Respect towards Patients


_ Abide by the HAAD Code of Conduct and shall act in accordance with the scope of practice and services for which they you been engaged for.
_ Failure to attend duty at the times assigned is a serious offence considering the nature of services and the necessity of care for the patients for which CMRC has been engaged. Your moral duty towards the patient is to ensure that at no point is the patient put at risk. Failure to show up to duty without prior approval from the Nurse Manager or Management of CMRC constitutes a breach of this code of conduct and shall cause you to be subject to the Disciplinary Code.
_ Respect the dignity of patients and their families and treat them with kindness and consideration. Identify yourself and your role in their care.
_ Take all necessary precautions and steps to ensure that the environment and provision of care allows patients, their families and representatives to maintain their privacy and dignity. Do not prejudice the care you give because you believe a patient’s behavior or the actions of their family or representatives contributed to their condition.
_ Do not impose your political, religious and cultural beliefs on patient, and intervene if you see other staff members of CMRC doing this.
_ Take steps to minimize risk and ensure your care does not harm the health or safety of patients
_ Ensure care provided is culturally appropriate and acceptable to patients and in accordance with the local cultural customs and beliefs. You should try to promote access to services which meet the religious, cultural and political beliefs of the patient (eg. Recognizing prayer times, dress code etc..)
_ Respect the patient’s right to complain and respond by working with them to resolve the issue.

Provision of Care


_ Be readily accessible to patients and colleagues when you are on duty.
_ Keep your professional knowledge and skills up to date.
_ Recognize and work within the limits of your competence and your scope of practice2.
_Ask for advice and assistance from colleagues especially when care may be compromised by your  lack of knowledge or skill.

Professional Behavior


_ You must declare any personal, financial or commercial interest which could compromise your professional judgment.
_ Do not misuse your professional position to promote or sell products or services for personal gain.
_ Respect the possessions and property of CMRC and patients in your care. As a member of CMRC you may have access to money, information, medical equipment and supplies. Your ethical responsibility and commitment under this Code of Conduct is to ensure that you do not engage, purport to engage or assist in theft from CMRC, other CMRC staff (your colleagues), the management, patients, patient’s family members or representatives, suppliers or any other persons. Such behavior is considered illegal under the UAE law and shall cause the employee to be subject to the disciplinary code.
_ Maintain professional boundaries between yourself and the patient and their family members and representatives involved in their care. It is forbidden to engage in sexual or intimate behavior or relationships with patients in your care or with those close to them. Keep your personal and professional lives separate as far as possible. Avoid online relationships with current or former patients. Do not use social media or electronic communication to build or pursue relationships with patients, their family members or representatives.

Termination of the contract of Employment as per The UAE Labor Law article 120


An employer may dismiss a worker without notice in any of the following cases:

_ if the worker adopts a false identity or nationality or submits forged certificates or documents;
_ if the worker is engaged on probation and is dismissed during the probationary period or on its expiry;
_ if the worker makes a mistake resulting in substantial material loss for the employer, on condition that the latter notifies the labor department of the incident within 48 hours of his becoming aware of its occurrence;
_ if the worker disobeys instructions respecting industrial safety or the safety of the workplace, on condition that such instruction are in writing and have been posted up at a conspicuous place and, in the case of an illiterate worker, that he has been acquainted with them orally;
_ if the worker does not perform his basic duties under the contract of employment and persists in violating them despite the fact that he has been the subject of a written investigation for this reason and that he has been warned that he will be dismissed if such behavior continues;
_ if the worker reveals any secret of the establishment in which he is employed;
_ if the worker is finally sentenced by a competent court for an offence involving honor, honesty or public morals;
_ if the worker is found in a state of drunkenness or under the influence of a drug during working hours,
_ if, while working, the worker assaults the employer, the responsible manager or any of his work mates,
_ if worker absents from his work without a valid reason for more than 20 non-consecutive days, or more that seven consecutive days.

WHISTLE BLOWING POLICY


1. Objective

The objective of this policy is to implement a well-defined procedure for employees who wish to report valid concerns about malpractice or impropriety in the workplace and are unable to do so through established procedures or communications channels. This policy should not be regarded as a means to circumvent established procedures or communications channels.
If in doubt – raise it! This applies to you whether you are a permanent employee, an agency or temporary staff member, an intern or a volunteer.

2. Scope of Policy


  • This policy covers raising concerns about wrongdoing in the work place by managers, employees, contractors, agency staff, interns, volunteers and anyone else engaged to work at CMRC.
  • The policy covers raising concerns about alleged wrongdoing in the work place and in any work-related setting outside the workplace e.g. business trips and work-related social events.

3. Reportable Conduct


The following list, which is not exhaustive, gives examples of reportable malpractice or impropriety:

  • Malpractice of care.
  • Poor quality care/negligence.
  • Fraudulent completion of claim forms, records, medical notes, performance monitoring data.
  • Forgery or alteration of any cheque, bank draft or any other financial or other document belonging or relating to CMRC.
  • Misappropriation of funds, supplies, or other assets.
  • Impropriety in the handling or reporting of money or financial transactions.
  • Profiteering as a result of insider knowledge of CMRC activities.
  • Disclosing confidential or proprietary information to outside parties.
  • Accepting or seeking anything of material value from contractors, vendors or persons providing services/materials to CMRC.
  • Destruction, removal or inappropriate use of records, furniture, fixtures, and equipment.
  • Any other financial malpractice, impropriety or fraud.
  • Failure to comply with laws and regulations.
  • Criminal activity.
  • Improper conduct or unethical behavior.
  • Breach of contract.
  • Danger to health and safety.
  • Damage to the environment.
  • Unofficial approach to the Media.
  • Attempts to conceal any of the above.

4. Confidentiality


  • The employee acknowledges that in the course of the Appointment, he/she will have access to Confidential Information.
  • The employee shall not (except in the proper course of the Employee’s duties), either during the Appointment or at any time after its termination (howsoever arising), use or disclose to any person, company or other organization whatsoever (and shall use best endeavors to prevent the publication or disclosure of) any Confidential Information. This shall not apply to:

– any use or disclosure authorized by the Company or required by law; or
– any information which is already in, or comes into, the public domain other than through the Employee ‘s unauthorized disclosure.

5. Protection of the Whistleblower


  • CMRC shall maintain the confidentiality of the person making the report to the fullest extent reasonably practicable within the legitimate needs of law and any ensuing evaluation or investigation.
  • The identity of the Employee making the allegation will be kept confidential and confined to the Investigating Committee so long as it does not hinder or frustrate any investigation.
  • The investigation process may reveal the source of the information to persons involved in the investigation or resolution of the investigation report. The Employee making the report may need to provide a statement as part of the evidence required.

6. Reporting Procedure


  • The employee should make the report via email to whistleblowing@cmrc.ae
  • It is essential that the subject of any such message be shown as ‘Whistle Blowing’. The report should include the reporting employee’s name.
  • Employees who make a report shall do so only:

– In good faith;
– In the reasonable belief that the reportable issue tends to show malpractice; or impropriety; and
– After having acquired appropriate, though not necessarily complete, supporting detail and evidence.

  • Employees who make a report must not:

– Contact the suspected individual in an effort to determine facts or demand restitution;
or
– Discuss the case, facts, suspicions or allegations with anyone except the Investigating Committee or unless specifically asked to do so by it.

7. Investigation Procedure


  • The Investigation Committee will be appointed by the CEO or, in a case where the CEO is the subject of the report, the Chairman of the Board. The Investigating Committee will consider the information made available to them and decide on:

– The person who will lead the investigation;
– The procedure(s) to be followed ; and
– The scope of the concluding report.

  • Any investigation will be conducted as sensitively and speedily as possible. The investigation will include but not be limited to the following steps:

– Full details of the allegation will be obtained;
– The allegation will be fully investigated; and
– The person who made the report will be informed of the outcome of the investigation, in due course and as appropriate, of any action taken.

  • At the appropriate time (subject to the progress and status of the investigation) the person against whom a report is made will be informed of it. He will be allowed to comment and make a rebuttal to the findings before the Investigating Committee before any investigation is concluded.
  • In some instances it may be necessary to refer the matter to an external authority for further investigation, particularly in cases alleging misuse of funds.

8. Conclusion


  • This Whistle Blowing Policy is designed to maintain the high standards of integrity and reputation of CMRC and has been implemented to assure employees who, acting in accordance with this policy, make reports in good faith of malpractice or impropriety in the workplace that they will not be dismissed, victimized or discriminated against as a result of the making of such report.

ANTI-BRIBERY & ANTI CORRUPTION POLICY

CMRC (which referred to as Company) is committed to manage and to conduct the entire business in honest and ethical manner. The fundamental standards of integrity under which CMRC operates strictly prohibits bribery or other improper payments in any of its business operations.
Anti-bribery & Anti-corruption’s policy reflects the Company’s efforts to implement and to enforce an effective system to counter bribery and corruption activities.
This policy is designed to reduce the risk of bribery and corruption activities occurring and their criminal and reputational impact on CMRC and parties CMRC contracts with.

Scope


  • This policy applies to all staff, whether full-time or part-time, trainees, seconded staff, interns, and to agents, consultants, vendors, representatives (which all referred to as Stakeholders).
  • Each Stakeholder has a personal and professional responsibility and obligation to conduct CMRC’s business activities ethically and in compliance with the context of this policy and the related CMRC policies. Failure to do so will result in disciplinary action, up to including dismissal, and criminal liability.
  • All Stakeholders will be required to confirm that they have read and understood the policy and that they comply with its terms as part of their ongoing contractual assessment processes.
  • If this policy is breached, by any party, CMRC reserves the right to terminate the contractual agreement in place and it does not bear any legal liability.
  • A Stakeholder in breach of this policy shall indemnify, defend, save and hold harmless, protect and exonerate CMRC, its shareholders, directors, officers, employees, agents and representatives from and against all claims, demands, liabilities, suits, actions, damages, losses and costs of every kind and nature whatsoever including, without limitation, court costs, investigative fees and expenses, and lawyers’ fees arising out of a breach of this policy.

CMRC does not tolerate practices of bribery and corruption in any form or wherever paid.

It is the responsibility of all employees who are involved at any time in engaging the services of external bodies (consultants, suppliers or advisers, etc.) to ensure that such individuals are made aware of the content of CMRC Anti-Bribery and Anti-Corruption policy at the outset of the relationship and on a regular basis thereafter.

  • This Policy Covers:

– Bribery and Kickbacks.
– Facilitation payments
– Public officials
– Gifts, hospitality and expenses
– Any other improper activity that might fall under the definition of bribery and corruption.

Policy


Bribes and kickbacks

Bribery involves the following:

  • When a financial or other advantage is offered, given, or promised to any stakeholder with an intention to reward them to perform their duties and responsibilities improperly.
  • When a financial or other advantage is requested, agreed to be received or accepted by another person with the intention to reward them to perform their duties and responsibilities improperly.
    Bribes can take many forms, for example:
  • Money ( cash or cash equivalent,); Unreasonable gifts, entertainment or hospitality;
  • A typical indirect bribery would be a case where a company employs a commercial agent to help it win a deal. The agent is paid by commission based on a percentage of the deal revenues, and part of that commission is passed on to a third agent.

Kickbacks

Kickbacks arise when suppliers or service providers pay part of their fees to the individuals who give them the contract or some other business advantage.
It does not matter whether the bribe is offered or requested directly or through a third party.
The company prohibits its employees from engaging in acts of corruption, and from paying bribes or kickbacks to, or accepting bribes or kickbacks from, public officials and private individuals such as the personnel of companies with which the company does business.

Facilitation payments
Facilitation payments are any payments, no matter how small or in which form given to another person or received by other person to increase the speed at which they do their job, or to get a business details that might have financial impact on business and/or personal level. Examples include payments to obtain clients; selecting suppliers, accelerate visa processing, etc.
Facilitation payments are prohibited. Staff must report any incident where they feel forced to make a facilitation payment to their line manager at the earliest opportunity. The company will stand by employees who find themselves placed in exceptional situations provided that the employee has provided absolute transparency as to the circumstances surrounding a payment shortly after the incident has occurred.

Public officials
Bribing or corrupting a public official is a serious offence, can carry severe penalties and can cause significant reputational damage. This policy provides detailed guidelines on gifts and hospitality. Approval must be secured in advance in relation to gifts or benefits received from or offered to public officials, particularly the giving of anything of value to a public official.

Gifts, hospitality and Expenses
Company employees may not offer to, or accept from, third parties, gifts, hospitality, rewards, benefits or other incentives that could affect either party’s impartiality, influence a business decision or lead to the improper performance of an official duty.
Similarly, they may not offer or accept cash donations. Company employees may offer and accept ‘reasonable’ and ‘proportionate’ gifts and entertainment, such as dinner, theatre parties or sporting events, which should need Management’s permission as per Delegation of Authority.
In determining, what is ‘reasonable’ and ‘proportionate’, employees should consider the value of the gift or benefit (see below), as well as the frequency with which the same or similar gift or benefit is offered. In all cases they must ensure that the gift or benefit:

  • Is being given as an expression of goodwill and not in expectation of a return favour (a gift designed to secure a return favour is a bribe).
  • Is being provided openly and transparently, and is of a nature that will not cause the company embarrassment if publicly reported.
  • Complies with local laws and regulations, including the recipient’s own rules (bearing in mind that government rules on offering and receiving gifts or benefit are often particularly tight).
  • Meets the value limits set by the company and has all required approvals. In cases of uncertainty, employees must seek advice from their line managers

Employees must seek prior approval as per the Delegation of Authority from their Department heads for all gifts or benefits received or offered with a value of more than AED300 (or equivalent) prior to final acceptance. Approval must be given in writing, and records of gifts received, from whom and by whom, must be recorded in an office or function log established for such purpose.
Please refer to CMRC gifts policy in the Employee handbook.

Personal conflicts of interest
Company employees must avoid situations or transactions in which their personal interests could conflict or might be seen to be in conflict with the interests of the company.
This includes: acting on any client information gained through their employment with the company for personal gain; passing such information to a third party; or acting in any way that could be construed as insider trading.
Conflicts of interest can arise if individuals have a personal interest in business dealings involving the company. Personal interest can be direct or indirect, and refers not only to personal interests but to those of family members and friends. If there is a potential for conflict, the interests of the company must take priority.
Employees must disclose any personal conflict of interest or perceived conflict to their line manager.
Please refer to CMRC gifts policy in the Employee handbook.

Charitable donations
As part of its corporate citizenship activities, CMRC may support local charities or provide sponsorship, for example, to sporting or cultural events. Any such sponsorship must be transparent and properly documented. CMRC will only provide donations to organisations that serve a legitimate public purpose, and which are themselves subject to high standards of transparency and accountability. Appropriate due diligence must be conducted on the proposed recipient charity and a full understanding obtained as to its bona fides.

Political activities
The company has a policy of strict political neutrality; it does not make donations to any political parties,
organisations, or individuals engaged in politics. The company will co-operate with governments and other official bodies in the development of policy and legislation that may affect its legitimate business interests, or where it has specialist expertise. Employees are entitled to their own political views and activities, but they may not use company premises or equipment to promote those views or associate their views with those of the company.

How to Raise a Concern


You 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 or concerns, these should be raised with your line manager, director or the Director or HR or the Risk and business improvements associate. If you feel you cannot raise it with any of the above, then please discuss with the CEO or Chairman and refer to our Whistleblowing Policy.
All reports will be treated confidentially.

Training


The company will make this policy available on the company’s intranet for all employees. It is also part of the General Orientation program within one month of joining the company. In order to maintain the highest standards of integrity, employees must ensure that:

  • They are fully briefed on the background and reputation for integrity of agents, representatives and subcontractors before hiring them. The company will conduct due diligence enquiries to review the integrity records of agents, representatives and subcontractors before entering a commercial relationship with them.
  • The engagement process is fully documented; and that final approval of the selection of agents, representatives and subcontractors is made by someone other than the person selecting or managing the company’s relationship with them.
  • Agents, representatives and subcontractors are fully briefed on the company’s Anti-Bribery and Anti-Corruption policy, and have made a formal commitment in writing to abide by it.
  • Fees and commissions agreed will be appropriate and justifiable remuneration for legitimate services rendered.
  • Once agreements have been signed, the company will continue to monitor its relationships with agents, representatives and subcontractors to ensure that there are no infringements of its Anti-Bribery and Anti-Corruption policy.

Contractual agreements will include appropriate wording making it possible to withdraw from the relationship if agents, representatives or subcontractors fail to abide by this policy.

Non-Compliance


Company failure to ensure compliance with this policy could lead to the following consequences for the company:

  • Criminal or civil liabilities for the company including unlimited fines and imprisonment;
  • Serious reputational damage leads to CMRC’s decline in business and growth.

Employees Failure to ensure compliance with this policy could lead to the following consequences:

  • Personal criminal liability followed by fines or imprisonment
  • Disciplinary action initiated by the company, including dismissal; and
  • Personal reputational damage.

 

Monitoring and review


Human Resources Director and risk and business improvement associate will review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness.
Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.

Summary


CMRC’s Staff and all stakeholders are:

  • Prohibited from offering, promising or paying a bribe of any kind;
  • Prohibited from soliciting, accepting or receiving a bribe of any kind;
  • Prohibited from giving or offering anything of value to a public official;
  • Required to comply with the company’s guidelines and authorization levels in relation to the giving and receiving of gifts and hospitality; and
  • Prohibited from making facilitation payments.

Affiliated Policies:


  • Conflict of Interests.
  • Gifts and hospitality.
  • Code of conduct.
  • Employee handbook.