Anti-Bribery and Corruption Policy Statement

CPA Global has a zero tolerance policy toward bribery and corruption in any form. Conditions of employment require all personnel to comply with this anti-bribery policy and the anti-bribery programme.

Any and all personnel who do not adhere to this policy and programme requirements will be disciplined, up to and including termination. In addition any person or organisation (third party) working with or on behalf of CPA Global must abide by CPA Global’s anti-bribery policy, which is designed to prevent, detect, and address bribery, as well as meet the requirements of the ISO - 37001 - Anti - Bribery Management Systems standards.

All prohibitions against bribery and corruption should be interpreted broadly. More specific prohibitions and guidance are provided in CPA Global’s Code of Business Ethics and Corporate Conduct. Any questions or concerns related to this anti-bribery policy or potential bribery can be asked of the Company’s Compliance group. Employees and third parties are encouraged to contact the Compliance group directly by email to compliance@cpaglobal.com or use the company’s Whistleblowing site.

 

OUR COMMITMENT TO GOVERNANCE & ETHICS

We are a global organisation representing customers’ interests in 200 jurisdictions around the world. Reputation and trust are critically important to us. The trust of our customers, business partners, suppliers, as well as the authorities and communities in countries where we operate.

The Compliance team oversees a Code of Business Ethics and Corporate Conduct that applies to all of the Company’s directors, officers and employees, contractors, temporary staff, and consultants. The Code underlines our ongoing commitment to upholding the highest levels of ethics and personal integrity in all our global business dealings, and is actively promoted through a comprehensive training and certification programme for employees. Most employees obtain Business Ethics certification within 60 days of hire.

The team also has oversight of our Regulatory Trade Compliance policy and programme which is designed to ensure compliance with bribery and corruption laws, export control, economic sanctions, boycott laws/regulations, data privacy protection, and Company policy anywhere in the world. Proactive measures include restricted-party screening, expense monitoring, IP agent anti-bribery training, third party due diligence activities, and a Whistleblowing Policy with established procedures to report actual or suspected incidents of corporate misconduct, including an independent hotline. Over the few last years, the Compliance team has delivered online Anti-Bribery and Corruption training for a number of CPA Global’s preferred IP agents around the world and produced numerous third party, anti-bribery due diligence reports.

Our UK-based Chief Data Privacy Officer works closely with local management teams to ensure we meet our data privacy obligations.

We operate a Global Quality Management System designed to drive Continual Improvement across the organization and have achieved ISO 9001:2015 certification for operations in Jersey, Noida, London, Alexandria, Minneapolis and Munich. Further, our Information Security Management System is certified to ISO 27001:2013 in Jersey, Noida, London, Alexandria, Minneapolis, Boise and San Mateo.

To ensure risk management is effectively embedded within the organisation, we have a dedicated Risk Manager, as well as a number of regional Risk Champions, who lead our risk management activities across functions and geographies, including the implementation of training programmes for employees.