Professional Documents
Culture Documents
Scope
These Guidelines apply to all employees of Charter, ESAB and Howden with
the exception of employees employed by AGI or its subsidiaries who are
covered by separate guidelines issued by AGI.
Everyone at Charter must show that all business is performed to the highest
ethical standards and complies both with these Guidelines and all applicable
laws.
Policy
Senior Management (which means the MD and the FD), of the relevant
business unit, are responsible for implementing these Guidelines and
enforcing them. They must advise on and approve payments, gifts and
expenses in accordance with these Guidelines. Internal Audit must monitor
the implementation of the Guidelines and must test compliance.
Third Parties
Third parties must not be used to perform acts that violate these Guidelines or
applicable local laws.
Gifts and entertainment must only be offered and accepted for conventional
social and business purposes at a level appropriate to the status and seniority
of those involved.
Charitable Donations
Charities and donations could be used as a conduit for bribes. Charter is keen
to support charities, particularly those in its local communities, but must not
do so at the request of customers and/or business partners, unless approved
in advance in writing by Senior Management. Charitable donations, whether
made in cash or by way of contribution to charitable events, publications or
fundraising initiatives must be approved in advance in accordance with the
Charter, Howden or ESAB Corporate Authority Limits on which the Senior
Management of your business unit can provide further information.
Payments to Officials
There are circumstances where Charter must by law pay for the services of
public officials e.g. customs clearances or visits from the environmental
regulators. We expect such officials to fulfil their legal and regulatory duty and
that any fee paid has a legal basis. Before any such payment is made, a
written document setting out the legal basis for the payment must be obtained
from the official together with a receipt. Additional payments or gifts must not
be made to such officials.
For You:
o Imprisonment typically 5-10 year sentences;
o Fines of an unlimited amount (which cannot be paid by the
Company on behalf of the individual);
o Detention, and
o Disciplinary action.
Charter always gives its full support to anyone refusing to pay a bribe
whatever the inconvenience, loss of business or extra costs involved
for Charter. However, in all circumstances, you must not take any step
which is likely to endanger either your or another persons safety.
Where anyone believes the Guidelines are not being complied with or they
are being asked to carry out any act not in compliance with these Guidelines,
these concerns must be raised immediately with the immediate superior. If
the immediate superior is not the appropriate person, then the employees
concerns must be brought directly to the attention of the Charter Head of
Legal or Charters Head of Internal Audit. You may also report a suspected
violation of these guidelines through Charters whistleblowing procedures.
Training/further guidance
Questions
If you have any questions regarding these Guidelines, please contact either your line
manager or the CEO/CFO of your business unit. If there are any queries that cannot
be addressed by the relevant line manager or Senior Management, then the
assistance of the global legal team and/or internal audit should be sought.