Compliance Program | Carter Industrial Company

Compliance Programme


Introduction and Purpose of Program

The Compliance Program of Carter Industrial Company is designed to ensure the company's adherence to applicable laws and conduct business operations in an ethical and coherent manner. The program is implemented to maintain compliance with various regulations and promote a culture of integrity within the organization.


Compliance Program Description

The Carter Industrial Company Compliance Program establishes a comprehensive framework to guide the company's compliance efforts. It encompasses the following components:


Code of Conduct

The Code of Conduct serves as a foundational document that outlines the core principles and values of Carter Industrial Company. It includes a message from the company's Chief Executive Officer and provides a concise overview of the company's stance on key issues in the following areas:


  • Business behavior and ethics
  • Internal behavioral codes, labor standards, and human rights
  • Intellectual property
  • Environmental impact


Compliance Area Specific Manuals

To ensure compliance with applicable laws and regulations, Carter Industrial Company has developed specific manuals for various compliance areas. These manuals offer practical guidance to employees and business partners, supporting their efforts to comply with the law. The compliance areas covered by these manuals include:


  • Anti-bribery: The Anti-bribery Manual provides guidance on interactions with the public and private sectors, including hospitality, corporate events, gifts, and charitable donations.
  • Competition: The Competition Manual provides guidance on interacting with competitors, suppliers, distributors, and customers. It also covers avoiding abuse of a dominant market position and complying with merger control rules.
  • Data Protection: The Data Protection Manual addresses the legal requirements related to the protection of personal data. It provides guidance on data collection and processing, data access and retention, data quality, confidentiality, and security.
  • Trade Sanctions: The Trade Sanctions Manual provides guidance on reporting activities in high-risk countries and screening counterparties to ensure compliance with trade sanctions regulations.


Whistleblowing Policy

Carter Industrial Company has implemented a Whistleblowing Policy to provide a clear process for reporting serious misconduct within the organization. This policy ensures that employees feel comfortable reporting any violations of laws, regulations, or internal policies without fear of retaliation.


Summary of Compliance Areas

The Compliance Program of Carter Industrial Company covers the following specific compliance areas:


  • Anti-bribery: Ensuring compliance with anti-bribery laws and regulations, including guidelines on interactions with the public and private sectors.
  • Competition: Promoting fair competition by complying with competition laws and regulations, including guidelines on interacting with competitors, suppliers, distributors, and customers.
  • Data Protection: Safeguarding personal data and ensuring compliance with data protection laws, including guidelines on data collection, processing, access, retention, confidentiality, and security.
  • Trade Sanctions: Adhering to trade sanctions regulations, including guidelines on reporting activities in high-risk countries and screening counterparties for sanctions targets.


Compliance Organization

At Carter Industrial Company, the development and maintenance of the Corporate Compliance Program are overseen by the Compliance Function. The Compliance Function comprises knowledgeable compliance officers specialising in specific compliance areas.


Each compliance officer serves as the primary point of contact for inquiries related to their respective compliance area and is responsible for maintaining the associated manual. The Anti-corruption Compliance Officer is specifically accountable for the Anti-bribery Manual and the Trade Sanctions Manual.



Carter Industrial Company is committed to providing adequate training on specific compliance areas to all relevant employees. Training programs are regularly updated to align with the company's risk profile and are tailored to the responsibilities of each employee.


The training initiatives aim to ensure employees have a comprehensive understanding of compliance requirements and are equipped to fulfill their obligations effectively.


Internal Audit

The Carter Industrial Company Compliance Program is integrated into the Compliance and Governance Manual (CGM), overseen by the CGM Committee. The Compliance Coordinator is appointed by the board, is responsible for conducting objective and comprehensive audits of the Corporate Compliance Program at regular intervals.


These audits take into account the specific areas of operations, geographic locations, and legal obligations of the company. If any deficiencies are identified, the management, in consultation with the Compliance Function, is responsible for implementing corrective measures.


The internal audit process ensures ongoing evaluation and improvement of the Corporate Compliance Program, enhancing its effectiveness and alignment with the company's goals and legal requirements.


June 30, 2023

Carter Industrial Company

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