CPFL Human Rights PolicyCPFL Human Rights Policy

CPFL Human Rights Policy

1. Purpose
Cramlington Precision Forge Ltd. (CPFL) is committed to upholding and promoting human rights in all aspects of our operations. This Human Rights Policy outlines our commitment to ensuring that our business practices, both within our company and throughout our supply chain, respect and protect the human rights of all individuals.

2. Scope
This policy applies to all CPFL employees, contractors, suppliers, and other business partners. It covers all our operations globally and is aligned with internationally recognized human rights standards, including the United Nations Universal Declaration of Human Rights, the International Labour Organization’s (ILO) core conventions, and the United Nations Guiding Principles on Business and Human Rights.

3. Core Principles
Respect for Human Rights: CPFL is committed to respecting the human rights of all individuals affected by our operations. We believe in the dignity of every person and respect the rights of all individuals, including employees, customers, suppliers, and community members.

Non-Discrimination: We are committed to providing a work environment free from discrimination, harassment, and retaliation. We do not tolerate discrimination based on race, color, religion, gender, age, national origin, disability, sexual orientation, or any other characteristic protected by applicable laws.

Fair Labor Practices: CPFL is dedicated to upholding fair labour practices. We ensure that all employees are treated with dignity and respect, receive fair compensation, and work in safe and healthy conditions. We do not engage in or tolerate any form of forced labor, child labour, or human trafficking.

Freedom of Association: We respect the rights of employees to freely associate, organize, and bargain collectively in accordance with local laws and regulations. We encourage open communication between management and employees and strive to resolve workplace issues in a fair and transparent manner.

Health and Safety: CPFL is committed to providing a safe and healthy working environment for all employees. We adhere to strict health and safety standards to prevent workplace accidents and injuries and promote the well-being of our workforce.

Community Engagement: We recognize the impact of our operations on local communities and are committed to engaging with these communities in a respectful and constructive manner. We seek to contribute positively to the social and economic development of the regions where we operate.

Environmental Responsibility: CPFL acknowledges that the protection of the environment is integral to respecting human rights. We are committed to conducting our operations in an environmentally responsible manner and minimizing our impact on the environment.

4. Implementation and Compliance
Training and Awareness: CPFL will provide training and resources to ensure that all employees understand and comply with this Human Rights Policy. We will also raise awareness among our suppliers and business partners about our commitment to human rights.

Monitoring and Reporting: We will regularly monitor our operations and supply chain to ensure compliance with this policy. Any potential human rights concerns will be investigated promptly and addressed appropriately.

Grievance Mechanism: CPFL provides a grievance mechanism for employees and other stakeholders to report any human rights concerns confidentially and without fear of retaliation. All reports will be taken seriously and investigated thoroughly.

Continuous Improvement: We are committed to continuously improving our human rights practices. We will review and update this policy as necessary to reflect changes in laws, standards, and best practices.

5. Accountability
Responsibility for implementing and upholding this Human Rights Policy lies with the senior management of CPFL. All employees, contractors, and business partners are expected to adhere to this policy, and failure to do so may result in disciplinary action, including termination of employment or contracts.

6. Conclusion
CPFL is dedicated to promoting and protecting human rights in all our operations. We believe that respecting human rights is not only a legal and ethical obligation but also essential to the sustainability and success of our business. By adhering to the principles outlined in this policy, we aim to contribute positively to the communities we serve and to the global effort to uphold human dignity and justice.

This Human Rights Policy reflects CPFL’s commitment to ethical business practices and the protection of human rights. We are dedicated to fostering a work environment where everyone is treated with respect, fairness, and dignity.


CPFL is committed to conducting business with the highest standards of integrity and ethics. Corruption is illegal, unethical, and incompatible with CPFL's values. CPFL has zero tolerance for bribery and corruption in any form. All activities must comply with applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, as well as local laws in all jurisdictions where CPFL operates.

Prohibitions:
Bribery: Employees and administrators are prohibited from giving, promising, offering, or authorizing payments or Anything of Value to any Government Official or private person to obtain an Improper Advantage.
Facilitation Payments: These are strictly prohibited and must not be made by any employee or administrator of CPFL.
Cash Gifts: It is forbidden to give cash gifts or cash equivalents, such as gift cards, to Government Officials or private persons.
Political Contributions: Employees and administrators must not make political donations or contributions on behalf of CPFL, including donations to political parties, candidates, or campaigns.
Third Parties: Employees and administrators must not use third parties to carry out activities that CPFL is prohibited from performing directly.
Guidelines:
Socioenvironmental Investments: While CPFL may make socioenvironmental investments, these must not be used to gain an unfair or improper advantage. All such investments must comply with this Policy and the Socioenvironmental Investments Policy.
Gifts, Meals, and Entertainment: Permissible if compliant with this Policy. Any gifts, meals, or entertainment offered to Government Officials exceeding established thresholds must receive pre-approval from Corporate Integrity.
Per Diem to Government Officials: Allowed only in limited cases with prior approval from Corporate Integrity.
Due Diligence: Perform appropriate Anti-Corruption Due Diligence on third parties and business acquisitions to identify potential risks.
Red Flags: Be vigilant for any Red Flags that may indicate potential corruption risks and report any concerns.
Recordkeeping: Maintain accurate and transparent records of all CPFL business transactions.
Cooperation: Employees and administrators must fully cooperate with investigations and maintain confidentiality.
Training: Corporate Integrity will conduct periodic anti-corruption training, which is mandatory for all employees.
Governance:
Board of Directors: The Board of Directors, with support from the Audit Committee, is responsible for supervising the implementation of this Policy.
Compliance Officer: Manages the Anti-Corruption Policy, overseeing Corporate Integrity, and reports directly to the Board as needed.
Consequences Management and Responsibilities:
Violations: Any violation of this Policy will result in disciplinary actions, which may include dismissal.
Legal Penalties: Violations of anti-corruption laws can lead to civil or criminal penalties.
Termination of Third-Party Relationships: CPFL may terminate its relationship with any third party found to be in violation of this Policy.
Reporting: Employees, administrators, and third parties must report any suspicious activity or potential violations immediately through the Whistleblower Channel.
General Provisions:
This Policy must be reviewed periodically, at least once every three years, to ensure its relevance and effectiveness.

This Anti-Corruption Policy is specifically tailored to CPFL, ensuring it meets the company's operational needs while maintaining a strong commitment to integrity and legal compliance.
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