Violations of the competition laws in which CTH companies do business, can have dramatic consequences for the group, its directors and staff. We could face a variety of negative repercussions, including serious fines, lawsuits, exclusion from public contracts and serious harm to our reputation.
Individuals who agree with others to violate competition laws also face severe external repercussions, including possible imprisonment, heavy fines and, in the case of the directors of our businesses, disqualification. CTH will not show any leniency towards employees or directors who disregard competition laws. Even if a business matter runs into difficulties through no fault of the employee or director, resorting to unlawful agreements with competitors is not acceptable. Compliance is the only permissible course of action, even in a crisis. If an employee or director becomes aware of conduct within or outside the firm that appears to involve a risk of secret cooperation with a competitor, it is essential that it is brought to the attention of more senior staff or directors immediately to ensure that this is stopped and reported.
More detailed guidance on competition law compliance can be found in the document attached to this letter and on the website of the Competition and Markets Authority as indicated, competition law compliance can be complex. If you are in doubt then do not hesitate to seek guidance from more senior colleagues.
I wish to make it very clear that compliance with regulatory obligations of our companies is a top priority of the Board of CTH and of myself as our Chairman. Competition law compliance is an essential element in that policy.
Non Executive Chairman