CM Newtech LTD Anti –Bribery & Conflict of Interest Policy Statement

The of Directors of CM New Tech Limited, in recognition of its obligations under the Bribery Act 2010; are fully committed to zero tolerance of any actual or attempted act of Bribery by any member or associate of their organisation.

  It is therefore the policy of Cm New Tech Ltd that under no circumstances, shall any member of staff or associate company or persons acting on its behalf, commit or attempt acts of bribery as defined by the Bribery Act 2010; in order to gain business, retain business, award business or achieve business advantage.

 Any proven cases of deliberate acts of Bribery, will result in staff disciplinary actions or termination of business agreements.

It is also acknowledged by CM New Tech Ltd that activities such as corporate hospitality and promotional events, whilst permitted under the Bribery Act 2010; could be misinterpreted as forms of Bribery.

 It is therefore the organisations policy, that all such events shall be transparent in their intent, proportional to the business and without obligation to invited parties.  Invitation to or inclusion of interested parties in such events, shall only be via approval by CM New Tech Ltd Directors.

In order to meet this commitment, the organisation shall identify those staff or associates in positions of potential risk and ensure they are fully conversant with this policy.  In addition, identified staff shall be given guidance on the requirements of the Bribery Act 2010 and associated management controls.

  Any member of staff who has direct or indirect interest in a business transaction or other business arrangement which may, or have potential to, conflict with the interests of the business, shall declare such interest to the Directors immediately and prior to commencement of that transaction or arrangement.

Any member of staff or associate that has reason to believe an act of Bribery has been committed or a ‘Conflict of Interest’ exists, shall notify the Directors immediately.

For and on behalf of the Directors,

Charlotte Holden – Director

July 2021