As stated clearly in our Code of Ethics and Business Conduct, “CMSD does not tolerate bribery or corruption, regardless of where we are located when we do business.” To that end, we maintain a robust anti-corruption compliance program as part of our broader Ethics & Compliance program. The anti-corruption program has been specially designed to address the needs and risks facing our Company and its various subsidiaries.
As with the Ethics & Compliance program as a whole, our anti-corruption compliance program is led from the very top of our Company. CMSD’s Board of Directors takes an active role in reviewing the Ethics & Compliance program. In order to ensure an organized approach to anti-corruption compliance, CMSD develops an annual anti-corruption compliance work plan to set goals, assign responsibilities, and measure achievements for the upcoming year.
Beyond the actions of the Board and Senior Executives, we have developed a series of policies and procedures to serve as the framework for the anti-corruption compliance program, including: (i) a comprehensive anti-corruption policy; (ii) a policy for the giving and receipt of gifts to ensure that such transactions are not subterfuge for bribery; (iii) a policy on hospitality; and (iv) a policy on potential conflicts of interest. Where necessary, these policies are supplemented with implementing procedures and work instructions so that our employees have a clear understanding of their responsibilities. To ensure that these policies and procedures are widely understood and followed, we have established a formal training program that includes several courses related to anti-corruption compliance. Our training program is designed to ensure that employees in sensitive positions receive targeted training to meet the risks inherent in their duties.
Our anti-corruption compliance program places a number of responsibilities on every member of the workforce. Indeed, it is a cornerstone of our Ethics & Compliance program that compliance is a responsibility of every employee. Chief among these responsibilities is the obligation to report known or suspected misconduct. We openly publicize our OpenLine hotline and regularly remind employees of the various avenues available to report misconduct. To ensure that any reports are handled appropriately, we have developed a formal process for investigating allegations and evidence of misconduct and have a strict and formal prohibition on any retaliation toward whistleblowers.
Finally, our commitment to anti-corruption compliance is such that we demand an equal commitment from the companies with which we conduct business. CMSD’s procedures require that, prior to engaging any business partners, CMSD performs due diligence to ensure that our business partners share our commitment to ethical business practices. Our due diligence is a strict requirement for the Company and all of its subsidiaries, regardless of location.
We believe a commitment to ethical business practices is key to our continued to success as a company and will continue to enhance our anti-corruption program as needed to meet the evolving risks and challenges facing our company.