Anti-Corruption Policy | Carter Industrial Company


Introduction to Anti-Corruption

Corruption is a pervasive problem that undermines trust, fairness, and the integrity of business practices. At Carter Industrial Company, as a leading GRS-certified synthetic leather manufacturer, we are committed to maintaining the highest ethical standards and ensuring compliance with anti-corruption laws. This Anti-corruption Policy outlines our zero-tolerance approach towards corruption and provides guidance to all employees, managers, executive officers, and members of the board of directors in upholding these principles.


Scope of Application

This policy applies to all individuals associated with Carter Industrial Company, including employees, managers, executive officers, and members of the board of directors (referred to as "employees" throughout this policy). It also extends to business partners who represent the Company or act on its behalf, such as consultants, agents, and certain service providers and suppliers. However, this policy does not apply to business partners acting independently of the Company.


Executive Summary

  • Prohibition of Bribery: It is strictly prohibited to directly or indirectly offer, promise, grant, or authorize the giving of money or anything of value to unduly influence the performance of the recipient's or someone else's professional duties or to obtain or retain an undue business advantage.
  • Public Sector Interactions: Extra care must be taken when interacting with representatives of the public sector and in relation to public procurement and governmental decision making. Benefits should never be offered to public sector representatives, their associates, or any other party with the intent of influencing an award of a bid or any other decision.
  • Third-Party Risk Assessment: Adequate third-party risk assessment procedures and contractual warranties are required to mitigate anti-corruption risks when engaging with business partners.
  • Consequences of Violations: Violations of anti-corruption laws can result in substantial monetary penalties, imprisonment, and severe reputational harm to the Company.
  • Seeking Guidance: If there is any doubt about the permissibility of a specific benefit, such as a meal, gift, event, or similar benefit, employees are encouraged to contact the Anti-corruption Compliance Officer for clarification.


Fundamental Requirements

Carter Industrial Company expects all employees to conduct business operations in strict compliance with applicable laws and regulations while upholding the highest ethical standards. The Company does not seek or accept any business advantages based on illegal, improper, or unethical behaviour. Employees should contact the Anti-corruption Compliance Officer if they have any questions regarding the laws, regulations, or policies applicable to their duties. No employee will face adverse consequences for refusing to pay bribes or for complying with this policy, even if it leads to the potential loss of business.


By adhering to this Anti-corruption Policy, we demonstrate our commitment to integrity, transparency, and responsible business practices. Together, we can foster a culture of ethical conduct and contribute to a corruption-free environment.


Expected Conduct

At Carter Industrial Company, we are committed to maintaining the highest standards of integrity and ethical conduct. Our Anti-Corruption Policy outlines the expected conduct for all employees, managers, executive officers, and members of the board of directors. It is strictly forbidden to engage in any form of corruption, whether directly or indirectly, and to offer, promise, grant, or authorize the giving of money or anything of value to unduly influence the performance of professional duties or obtain an unfair advantage. This policy applies to both the public and private sectors.


Improper Benefits and Bribes

An improper benefit, also known as a bribe, is defined as any form of gift, entertainment, invitation to events or seminars, travel and accommodation, use of property or equipment, job offers or work placements, charitable or political donations, or services, favors, or benefits provided to someone in exchange for undue influence or to gain an unfair advantage. The nature and value of the benefit will be considered when determining its impropriety.


Distinction between Public and Private Sectors

Extra caution must be exercised when interacting with representatives of the public sector. This includes employees and representatives of government agencies, courts, public authorities, publicly-owned companies, and politically exposed persons. Benefits offered to individuals in the public sector are more likely to be deemed improper and illegal.



When offering hospitality, such as lunch or dinner, to public sector representatives, it is strictly prohibited. For private-sector interactions, reasonable expenditure on hospitality is allowed, provided it does not coincide with ongoing matters such as public procurement or governmental decision-making. Luxury restaurants are not permitted, and the consumption of wine, beer, and spirits should be done in moderation.



Gifts to the public sector are strictly prohibited unless it is a well-established and legally permissible local practice and written pre-approval from the Anti-corruption Compliance Officer has been obtained. In the private sector, reasonable business expenditures related to company promotions are allowed, with the value of the gift not exceeding USD50 without specific permission. Employees may accept promotional products and samples in moderation, but the value should not exceed USD50 without approval.


Corporate Events

Corporate events organized or attended by anyone representing the Company must have a legitimate business purpose. Invitations to such events should clearly indicate the business purpose and compliance with corporate policies. "Plus-one-invitations" are not acceptable. For events involving the private sector, the business relevance should outweigh the entertainment portion. When engaging with the public sector, entertainment should be minimized, and the event should be of significant business relevance.


Charitable Donations

Any charitable donations or larger company sponsorship programs require written pre-approval from the Anti-corruption Compliance Officer and must be made public on the Company's website. Smaller charitable donations, such as employee fundraising initiatives, are generally allowed but should obtain prior approval from the Anti-corruption Compliance Officer.


Business Partners

When interacting with third parties on behalf of the Company, it is essential to exercise diligence and care to ensure compliance with anti-corruption laws. Those responsible for appointing and hiring third parties, such as consultants and agents, must conduct due diligence to evaluate their reputation and standing regarding anti-corruption compliance. Due diligence is not required for third parties acting independently, such as suppliers. Prior to entering into a business relationship, all relevant third parties should contractually agree to comply with applicable anti-corruption laws and this policy.


Do's and Don'ts


  • Contact the Anti-corruption Compliance Officer if there is any doubt regarding the permissibility of specific benefits, such as meals, gifts, events, or similar offerings.
  • Obtain written pre-approval from the Anti-corruption Compliance Officer before initiating any charitable contributions or sponsorships.
  • Pay careful attention to interactions with the public sector, including public officials and politically exposed persons, and adhere to specific limitations.
  • Remember that this policy applies to everyone acting on behalf of the Company, including the board of directors, employees, and business partners.
  • Conduct third-party risk assessments to ensure compliance with anti-corruption standards.
  • Trust your instincts. If something feels wrong, consult with your supervisor or the Anti-corruption Compliance Officer.


  • Offer, promise, or authorize the provision of money or anything of value to anyone with the intent to unduly influence their professional duties or gain an unfair business advantage.
  • Accept, request, or promise money or anything of value from anyone other than the Company in exchange for performing your professional duties.
  • Offer gifts of any kind to individuals within the public sector, except in cases where it is a well-established and legally permissible local practice, and written pre-approval from the Anti-corruption Compliance Officer based on special circumstances has been obtained.
  • Engage in hidden discounts, commissions, bonuses, or kickbacks, whether offering, promising, authorizing, accepting, or requesting them.
  • Make facilitation payments. Facilitation payments, also known as "grease payments," are strictly prohibited. These refer to small payments made to expedite routine, non-discretionary acts that public officials are obligated to perform. Even if these payments are exempted under certain jurisdictions, the Company does not apply any such exemption.


Reporting Process

Employees who suspect a violation of anti-corruption laws within the Company are required to follow the standard reporting process or the reporting process outlined in the Whistleblowing Policy. We encourage employees to promptly report any concerns or suspicions of corrupt practices to the designated channels. The Company ensures that all reports will be handled confidentially and that appropriate action will be taken to investigate and address the reported matter.



Carter Industrial Company provides comprehensive training to all relevant employees, tailored to the Company's risk profile and aligned with individual responsibilities. The training programs aim to educate employees on anti-corruption laws, regulations, and best practices. By equipping employees with the necessary knowledge and awareness, we promote a culture of integrity and compliance throughout the organization.


Internal Audit

The Compliance Coordinator is responsible for conducting objective and comprehensive audits of the Corporate Compliance Program, including anti-corruption measures. These audits are conducted periodically, taking into account the Company's specific areas of operations, geographic locations, and legal obligations. The audits assess the effectiveness of the anti-corruption controls and identify areas for improvement. The Compliance Coordinator ensures that the audit findings are appropriately addressed and that corrective actions are implemented as necessary.


June 30, 2023

Carter Industrial Company

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