Ethics

Table of Contents

ALCHEMY CARTA LTD
Anti-Bribery & Corruption Policy

Introduction

At Alchemy Carta Ltd, we are committed to conducting our business in a fair and transparent manner. We take a zero-tolerance approach to bribery and corruption in all its forms. We expect every employee, officer, director, and representative of the company to conduct themselves with integrity and uphold our anti-bribery policy.

Purpose

This Anti-Bribery Policy aims to prevent and deter bribery and corruption by setting clear expectations and guidelines for employees, officers, directors, and representatives of Alchemy Carta Ltd.

The policy is designed to ensure that we comply with all applicable laws and regulations related to anti-bribery and corruption. This includes, but is not limited to, the UK Bribery Act 2010, the US Foreign Corrupt Practices Act, and relevant legislation in other jurisdictions where we operate.

Definitions

(For the purposes of this policy)

  • Bribery : Any offer, promise, or payment, either directly or indirectly, made by any person or organization in order to influence, induce, or coerce an employee, officer, director, or representative of Alchemy Carta Ltd to take action that benefits a third party.
  • Corruption : The abuse of power, position, or opportunity for personal gain or benefit.

Prohibited Conduct

  1. Making or accepting any bribe, offer, promise, or payment in connection with the conduct of business, regardless of whether it is directly or indirectly related to a specific transaction.

  2. Requesting, accepting, or soliciting any gift, entertainment, travel allowance, or other benefit that could be perceived as an inducement or reward for performing services or taking action on behalf of Alchemy Carta Ltd.

  3. Participating in or facilitating the payment or acceptance of bribes, gifts, or other benefits to any individual or organization in connection with business transactions.

  4. Using a third party (e.g., agent, consultant, or intermediary) to make or receive payments that could be considered as bribery.

Permitted Conduct

  1. Reasonable and necessary expenses related to the promotion of our products or services, such as hospitality, entertainment, or travel.

  2. Gifts that do not exceed a reasonable value (e.g., £25) and are not intended to influence business decisions.

  3. Business entertaining in accordance with the following guidelines:

    • Entertainment must be reasonable and directly related to the conduct of business.
    • Hospitality must not be excessive or lavish.

  4. Travel expenses can be reimbursed only if they relate directly to business travel.

Reporting Obligations

All employees, officers, directors, and representatives of Alchemy Carta Ltd are required to report any suspected bribery or corruption immediately.

Reports should include:

  1. A detailed description of the alleged incident.

  2. The date and time when it occurred.

  3. The names of any individuals involved.

Investigation and Disciplinary Action

Upon receipt of a report, Alchemy Carta Ltd will conduct an investigation into the matter. If an employee is found to have breached this policy:

  1. Initial disciplinary action may include verbal or written warning.

  2. Repeated breaches may result in more severe disciplinary action, up to and including dismissal.

Political Contributions

We do not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage.

Charitable contributions

Charitable support and donations are acceptable, (and indeed are encouraged), whether of in-kind services, knowledge, time, or direct financial contributions. However, employees must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery. We only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without prior approval.

This Anti-Bribery Policy is effective immediately and supersedes any previous policies or procedures related to bribery and corruption. It will be reviewed and revised as necessary.

The Alchemy Carta Ltd
St.Mary's Mill, Unit 43 Faircharm Trading Estate,
Evelyn Drive, Leicester, LE3 2BU.

SLAVERY AND HUMAN TRAFFICKING STATEMENT

Introduction

We are committed to eliminating acts of modern-day slavery and human trafficking within our business and from within our supply chains.

Our annual turnover is under £36 million and, although we are not legally obliged to report on slavery and human trafficking, this statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and is our slavery and human trafficking statement for The Alchemy Carta Ltd.

Organisational structure, business and supply chains

We are a manufacturer and supplier of costume jewellery and giftware, and are an independent company operating solely within the UK.

Our business comprises one manufacturing unit and associated head office support based at the above address.

Policy on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business or in our supply chains. This policy reflects our commitment to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere within our supply chains.

Due diligence

We consider ourselves to be a ‘low risk’ business with regard to slavery and human trafficking. However, we foster a culture that encourages the identification and reporting of any such risks within our business. We recruit all our employees either directly or through recruitment agencies who are members of the Recruitment and Employment Confederation. We do not recruit from outside the UK or use agency workers.

Assessing and managing risk

We have a whistle-blowing policy in place and, as part of our efforts to identify and mitigate risks within our supply chain, we continue to put in place systems to identify, assess and monitor potential risk areas.

Effectiveness in combating slavery and human trafficking

We have zero tolerance to slavery and human trafficking. To ensure that all those in our supply chains comply with our values, we have in place a supply chain compliance programme that requires our suppliers to confirm that they have a slavery and human trafficking policy, and that they require the same from their suppliers.

Training

We are providing appropriate training to ensure that relevant employees understand the risks of modern slavery and human trafficking within our business and supply chains.