Purpose of the Anti-Corruption Policy

This policy outlines acceptable and non-acceptable behaviors to ensure compliance with anti-corruption laws, such as the US Foreign Corrupt Practices Act (FCPA). This includes compliance with all laws, prohibiting improper payments, gifts or inducements of any kind to and received from any person, including officials in the private or public sector, customers and suppliers.

Helpful Definitions

Bribe:  Anything of value given in an attempt to affect a person’s actions or decisions in order or to gain or retain a business advantage.  Anything of value includes cash, entertainment or other gifts or courtesies.

Corruption:  The misuse of a public office or power for private gain or the misuse of private power in relation to business outside the realm of government.

Facilitation payments:  Small sums paid to government officials to facilitate or expedite routing. Non-discretionary government actions are considered facilitation payment.

Kickbacks:  The return of a sum already paid or due as a reward for awarding of furthering business.

What Does ‘Anti-Corruption’ Mean to You? 

Corruption can take place in many types of activities.  It usually is designed to obtain financial benefits or other personal gain.  For example, bribes are intended to influence behavior – they could be in the form of money, a privilege, an object of value, an advantage, or merely a promise to influence a person in an official or public capacity.  Usually, two people are involved and both will benefit.  Examples of a bribe include:

  • Offer or receipt of cash in the form of a kickback, loan, fee or reward
  • Giving of aid, donations or voting designed to exert improper influence

The areas of business where corruption, including bribery, can most often occur include:
1.    Gifts, Entertainment and Hospitality
2.    Facilitation Payments
3.    Procurement Process
4.    Political, Community and Charitable Contributions

1. Gifts, Entertainment and Hospitality 

Gifts, entertainment and hospitality are acceptable if they are reasonable, proportionate and made in good faith and in compliance with our company policies.  These activities must be in compliance with our Code of Business Conduct (guiding principle: ‘avoiding conflicts of interest’), Cambridge’s Customer Entertainment Policy and Corporate Hospitality Guidelines. Although no two situations are the same, the Corporate Hospitality Guidelines define what is usually acceptable and what is never acceptable.

Examples of gifts, entertainment and hospitality include the receipt or offer of gifts, meals or tokens of appreciation and gratitude, invitations to events, functions, or other social gatherings, in connection with matters related to our business. These activities are acceptable provided they fall within reasonable bounds of value and occurrence.

How do you know if an offered gift, entertainment or hospitality by Cambridge or to Cambridge is acceptable?  First, take a step back and ask yourself the following:

  • What is the intent – is it to build a relationship or is it something else?
  • How would it look if these details were on the front of a newspaper?
  • What if the situation were reversed – would there be a double standard?

If you find it difficult to provide a comfortable answer to one of the above questions, ASK your manager, or Compliance Office.

What to do when you doubt if you can accept?  If you are unsure if you should accept something of value – ASK.  Ask your manager.  If your manager is participating, seek a higher-level manager.  If you prefer, ask your Compliance Office.

As a general rule, Cambridge employees and business partners should not provide gifts or hospitality to, or receive them from, a government or other public official (or their close families and business associates). You may give a modest gift to these parties when appropriate and allowed by local law provided you discussed it with and received written approval in advance from the legal department, senior officer and legal counsel.

2. Facilitation Payments 

Facilitation payments are not allowed. If you are unsure whether certain payments represent facilitation payments, please contact your local Compliance Office.

3. Procurement Process

You must follow Cambridge processes and adhere to the system of internal controls around supplier selection.  Supplier selection should never be based on receipt of a gift, hospitality or payment.  When supplier selection is a formal, structured invitation for the supply of products or services (often called a ‘tender’), it is most important we maintain documentation supporting our internal controls. In the public sector, such a tender process may be required and determined in detail by law to ensure that such competition for the use of public money is open, fair and free from corruption.

A tender process includes an invitation for other parties to make a proposal, on the understanding that any competition for the relevant contract must be conducted in response to the tender, no parties having the unfair advantage of separate, prior, closed-door negotiations for the contract where a bidding process is open to all qualified bidders and where the sealed bids are in the open for scrutiny and are chosen on the basis of price and quality.

4. Political Community and Charitable Contributions    

You are not allowed to make political contributions from Company funds without authorization.  Political contributions, as permitted by law, must be approved in advance by legal counsel.

Contributions made by Cambridge to community projects or charities need to be made in good faith and in compliance with our Code of Business Conduct,

Books, Records and Internal Control Requirements

Expenses must never be hidden or purposefully misclassified.  Many serious bribery and corruption scenarios are found to involve inaccurate record-keeping.  To prevent this, anti-corruption laws generally require detailed and accurate accounting records for transactions, including cash and bank accounts.  We must ensure we maintain accurate books, records and financial reporting.

All business units must maintain an effective system of internal control and monitoring of our transactions.  It is your responsibility to be knowledgeable of control procedures and ensure compliance.

You Are Responsible

Cambridge takes corruption and bribery very seriously.  Any violation of this policy will be regarded as a serious matter by the Company and is likely to result in disciplinary action, including termination, consistent with local law.

Bribery is a criminal offense. As an employee you will be accountable whether you pay a bribe yourself or whether you authorize, assist, or conspire with someone else to violate an anti-corruption or anti-bribery law. Punishment for violating the law are against you as an individual and may include imprisonment, probation, mandated community service and significant monetary fines which will not be paid by Cambridge.


Implementation – December 2013


Review and Updating

This policy will be reviewed and updated on a semi – annual basis by an executive of Cambridge. The Cambridge Executive Committee will receive an annual report on this policy and the company’s performance.