Anti-Trust

Our commitment to anti-trust compliance ensures that we are aware of and comply with the anti-trust/competition laws in the markets in which we operate, enabling us to compete effectively and fairly on a level playing field... and to win.

Anti-Trust Policy 

The Group’s Anti-Trust Policy provides that employees should “not seek competitive or other advantage through dishonest, corrupt, unlawful or anti-competitive business practices and should avoid situations where they could be compromised by a conflict of interest”.

Anti-Trust Compliance Programme

Morgan Crucible’s commitment to this Anti-Trust Policy is fundamental to its business success and an Anti-Trust Compliance Programme has been in place for a number of years. During 2011 the Group's Anti-Trust Compliance Programme was updated and fully incorporated into the Responsible Business Programme.  The Programme consists of a number of components which include: 

• Anti-Trust Policy & supporting guidelines;
• Face-to-face training;
• eLearning modules;
• Annual compliance certification requirements;
• Competitor contact reporting; and
• External audit.

Participation in the Programme and management of the site level training is managed by the local compliance officers and monitored by both the General Counsel and Company Secretary (who is Group Compliance Director) and the Compliance Director for the USA and Canada, who have a direct reporting line to the Board and Executive Committee.

Anti-Trust Compliance

Implementation of the site level training and compliance with the Policy is monitored by the General Counsel and Company Secretary and his team, with a direct reporting line to the Board and Executive Committee. The Anti-Trust Compliance Programme is also subject to independent audit by Compliance Council.

The Morgan Crucible Ethics Hotline enables employees who are aware of or suspect issues under our Anti-Trust Policy to report these confidentially. 

Feedback

We welcome feedback on our Anti-Trust related policies and systems. Please contact us by email on company.secretariat@morganplc.com or by post at the head office address listed in the contacts section.