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Anti-bribery policy

CIMA is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. It is committed to preventing and prohibiting corruption in all its forms, including extortion and bribery, in accordance with the 10th principle of the UNGC and the Bribery Act 2010. CIMA will not tolerate any form of bribery by, or of, its employees, agents or consultants or any person or body acting on its behalf.

“Bribery” is defined as “an offer or receipt of any gift, loan, fee, reward or other advantage to or from any person as an inducement to do something which is dishonest, illegal or a breach of trust, in the conduct of CIMA’s business”

Likewise, all those with whom CIMA does business will be expected to confirm that they will abide by the principles set out in CIMA’s anti-bribery policy in all respects; if you do not have commensurate anti-bribery procedures in place it is unlikely that CIMA will do business with you.

What is prohibited?

CIMA prohibits employees or associated persons from offering, promising, giving, soliciting or accepting any bribe. The bribe might be cash, a gift or other inducement to, or from, any person or company, whether a public or government official, official of a state-controlled industry, political party or a private person or company, regardless of whether the employee or associated person is situated in the UK or overseas.

The bribe might be made to ensure that a person or company improperly performs duties or functions (for example, by not acting impartially or in good faith or in accordance with their position of trust) to gain any commercial, contractual or regulatory advantage for CIMA in either obtaining or maintaining CIMA business, or to gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.

This prohibition also applies to indirect contributions, payments or gifts made in any manner as an inducement or reward for improper performance, for example through consultants, contractors, sub-contractors, agents, sub-agents, sponsors or sub-sponsors, joint-venture partners, advisors, customers, suppliers or other third parties.
Due diligence will be undertaken and recorded by employees and associated persons prior to entering into any contract, arrangement or relationship with a potential supplier of services, agent, consultant or representative in accordance with CIMA’s procurement and risk management procedures.

Employees and associated persons are also required to keep accurate, detailed and up-to-date records of all corporate hospitality, entertainment or gifts accepted or offered in CIMA’s hospitality register.

Facilitation payments

CIMA prohibits its employees or associated persons from making or accepting any facilitation payments. Facilitation payments, or offers of such payments, will constitute a criminal offence by both the individual concerned and CIMA under the Bribery Act 2010, even where such payments are made or requested overseas.

CIMA depends on its employees and associated persons to ensure that the highest standards of ethical conduct are maintained in all its business dealings. Employees and associated persons are requested to assist CIMA and to remain vigilant in preventing, detecting and reporting bribery.

CIMA will investigate fully any instances of alleged or suspected bribery.