Our Corporate Policies

Anti-Bribery Policy

1.0 Introduction

CWind has a responsibility to adhere to both legislation and best practice to ensure that all employees are operating to the highest professional standards.  As such, it is committed to complying with the UK Bribery Act and the anti-bribery laws of the countries and territories in which we do business, such as the U.S. Foreign Corrupt Practices Act.

CWind maintains an Anti-bribery Policy, document GMG-A-KA-0049, that is applicable to all employees of CWind (the Company) and individuals undertaking work for and on behalf of the Company.

2.0 Definition

Under the Bribery Act 2010, a bribe is a financial or other type of advantage that is offered or requested with the:

• Intention of inducing or rewarding improper performance of a function or activity; or
• Knowledge or belief that accepting such a financial or other advantage would constitute the improper performance of such a function or activity

A relevant function or activity includes any task or activity performed in the course of a person’s employment, or on behalf of another organisation or individual, where the person performing that activity is expected to perform it in good faith, impartially, or in accordance with a position of trust.

A criminal offence will be committed under the Act if:

• A person offers, promises, gives, requests or agrees to receive bribes;
• A person offers or gives a bribe to a foreign public official with the intention of influencing that official in the performance of his/her duties (where local law does not permit or require such influence);
• The organisation does not have the defence that it has adequate procedures in place to prevent bribery by its employees or associated persons;

3.0 Prohibited Activity

The Company prohibits a person from offering, promising, giving, requesting, agreeing to or accepting any bribe.  The bribe might be money, a gift or other inducement to, or from, any person or organisation, whether a public or government official, official of a state controlled industry, political party or a private person or company, regardless of whether the person is situated in the UK or overseas.

The bribe might be to ensure that a person or organisation improperly performs duties or functions (for example, by not acting in good faith or in accordance with their position of trust) to gain any commercial, contractual or regulatory advantage for the organisation in either obtaining or maintaining business, or to gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.

The Company also prohibits indirect contributions, payments or gifts made in any manner as an inducement or reward for improper performance, for example through consultants, contractors or sub-contractors, agents, advisors, customers, suppliers or other third parties.

4.0 Reporting

The Company encourages all persons to report any concerns that they may have, in line with company procedure.  Issues to be reported include:

• Any suspected or actual attempts at bribery;
• Concerns that other employees or associated persons may be being bribed;
• Concerns that other employees or associated persons may be bribing third parties, such as suppliers or government officials

Any reports of suspected or actual bribery will be investigated thoroughly. A person who reports an instance of bribery, will be supported by the Company and will not suffer to their detriment as a consequence of their report.  Any instances of detrimental treatment by a fellow employee will be treated as a disciplinary offence.

An instruction to cover up bribery is in itself a disciplinary offence. If a person in authority, regardless of their position in the Company, instructs a person not to raise or pursue a concern, the person should not agree to remain silent and should report the matter accordingly to the Head of HR.

Where there is an allegation or reasonable suspicion of bribery, the concerned person/s may be suspended from their duties whilst the investigation is being carried out. The employer’s disciplinary procedures will be initiated and proven allegations may result in a finding of gross misconduct and immediate dismissal.

The Company may also report any matter to the relevant authorities, including the Director of Public Prosecutions, Serious Fraud Office, Revenue and Customs Prosecutions Office and the Police. The organisation will fully co-operate and provide all necessary information to the relevant authorities in any subsequent prosecution.

Full details of this policy are available on request at sales@globalmarine.co.uk

Code of Conduct including Anti-Slavery & Human Trafficking

1.0 Introduction

The Code of Conduct, document GMG-A-KA-0030, encompasses the principles, values and rules of behaviour that guide decisions and actions in CWind (the Company), in a way that contributes to the welfare of its key stakeholders and respects the rights of all persons affected by its operations.

The Code aims to ensure the Company preserves its long tradition of integrity and credibility with its customers and within the industry.

2.0 Scope

Adherence to the Code is a key responsibility for:
• All employees of GMG
• All vessel staff, contractors, secondees, agency personnel, and other third party service providers undertaking work for and on behalf of GMG

All persons are accountable for complying with applicable laws, regulations and company policies, and observing high ethical standards when conducting business on the Company’s behalf.

4.3 Anti-Slavery & Human Trafficking

The Company complies with the requirements of the Modern Slavery Act 2015 and undertakes steps to ensure that we work with suppliers whose standards and practices reflect the same ethics.

Full details of this policy are available on request at sales@globalmarine.co.uk.


Our Environmental Policy

CWind has over 160 years’ experience and pride ourselves on providing subsea state-of-the-art engineering, installation and maintenance.

The Board of Directors recognise that outstanding business performance requires an outstanding risk based environmental management system and outstanding environmental performance by preventing pollution to the environment by our workforce and our subcontractors and by undertaking regular audits to identify areas of continual improvement… read more

View full Environmental and Energy Policy

Health & Safety

Our Health & Safety Policy

CWind has over 160 years’ experience and pride ourselves on providing subsea state-of-the-art engineering, installation and maintenance.

The Board of Directors recognise that outstanding business performance requires an outstanding risk based health and safety management system appropriate to our business. This means the proactive prevention of injury to, and ill health of, our personnel, our subcontractors and others who may be affected by our operations and activities.

Additionally the need for continually improving our occupational health and safety management system and our company performance is recognised… read more

View full Health & Safety Policy

Information Security Policy

1.0 Introduction

The security of information and other IT assets is considered by CWind (the Company) as being fundamental to the successful operation of its business. The Information Security Policy, document GMG-D-KA-0016, is a key component of the overall information security management framework.

The purpose of the Information Security Policy is to ensure that information stored and processed by the Company, or on behalf of the Company, across all company activities, in any form and location, is securely protected against the consequences of breaches of confidentiality, integrity, or availability of that information.

2.0 Scope

Adherence to requirements of this Company policy is the responsibility of:

  • All employees of CWind
  • All vessel staff in the Company fleet, contractors, secondees, agency personnel, and other third party service providers undertaking work for and on behalf of the Company
  • All visitors to a CWind office, depot or vessel

3.0 Policy Statements

In meeting the aims of this policy, the Company will:

  • Ensure that Information Security awareness is included as part of the induction process
  • Maintain an ongoing awareness programme to ensure that staff awareness of information security is refreshed and updated as necessary
  • Ensure that expectations regarding Information Security are incorporated into the job descriptions of relevant personnel
  • Ensure that information managed by the Company is secured to protect against the consequences of breaches of confidentiality, failures of integrity or interruptions to the availability of that information
  • Meet all information security requirements under appropriate regulations, legislation, Company policies and contractual obligations
  • Address the security of all Company services and processes to ensure that risks are identified and appropriate controls are implemented and documented
  • Provide a secure working environment for all persons at all sites where Company work is conducted
  • Produce Business Continuity and Disaster Recovery plans for strategic IT and information services, which will be maintained and tested on a regular basis
  • Require all third parties, undertaking work on behalf of the Company, to ensure that the confidentiality, integrity and availability requirements of all business systems are met
  • Promote the aims of this policy and raise awareness of information security throughout the Company.

Full details of this policy are available on request at sales@globalmarine.co.uk


Our Quality Policy

CWind is a leader in engineering and underwater services, providing subsea cable installation, maintenance and burial solutions. We operate a fleet of specially equipped cable ships, including an array of subsea associated ROVs and equipment. CWind engineers cable routes and installs subsea cables for telecoms, oil & gas and power/utilities customers.

Management are committed to the implementation of an effective management system compliant with the International Standard ISO 9001.

It is the responsibility of all CWind personnel to implement the QHSE management system described in company procedures. The system and its implementation will be subject to regular management review to ensure its suitability and effectiveness in achieving the QHSE objectives of the Company.

We aim to meet our customers’ expectations and be recognised for our commitment to quality in everything we deliver… read more

View full Quality Policy

Sustainability Policy

1.0 Introduction

CWind (the Company) is committed to establishing, promoting, maintaining and improving a culture of sustainability within the Company and its associated stakeholders.

The Company’s Sustainability Policy, document GMG-S-KA-0040, outlines the aims for sustainability.  The policy also defines how these goals are realised through implementation of Company initiatives and business processes.

2.0 Scope

This policy is applicable to all employees of CWind and individuals undertaking work for and on behalf of the Company.

3.0 Aims

CWind is fully committed to compliance with both legal requirements and its duty to address the economic, social and environmental challenges of globalisation through continual improvement of its sustainability performance.

The Company aims to:
• Integrate sustainable development as a fundamental part of its business development strategy
• Reduce the environmental impact of its activities
• Foster and support long-term development for local communities in the countries where CWind operates

Full details of this policy are available on request at sales@globalmarine.co.uk

UK Tax Strategy

Reporting requirements per Finance Act 2016 Schedule 19

This document sets out the principal approach to tax strategy and governance of CWind (‘GMG’) for the year ending 31 December 2017, and applies to all entities within the GMG that are situated within the UK.

The strategy and approach outlined below have been approved by the GMG board of directors, and are aligned with the key company values shared by our senior stakeholders.

GMG consider that the publication of this information satisfies the UK legislative requirements of paragraph 19(2) Schedule 19 Finance Act 2016 in relation to the publication of a UK tax strategy.

View full policy

Modern Slavery Statement 2018

The Global Marine Group has zero tolerance of Modern Slavery in all its varying forms both within the GMG companies and their supply chains.

Control Measures:

All new Vendor Requests are reviewed against Modern Slavery risk against the following criteria:

  • Industry Risk;
  • Country Slavery Risk: globalslaveryindex.org;
  • Country Corruption Risk: transparency.org;
  • Freedom of Political Rights & Civil Liberties: freedomhouse.org

Where a higher risk is identified, a self-assessment questionnaire is completed by the potential supplier and assessed accordingly.

GMG has undertaken a desk based assessment of risk with its top 100 (by spend) suppliers, utilising a scorecard based assessment, resulting in 32 suppliers identified as Medium risk and zero High risk.  During 2018 these Medium risk suppliers will complete self-assessment questionnaires for further review and identification of any required mitigation/compliance actions.

In 2017 GMG added a section for Modern Slavery review to its Supplier Audit requirements and all new Contracts have provision and obligations for ethical trading and compliance to the Modern Slavery Act.

In 2018 GMG aims to:

  • Develop a Supplier Code of Conduct to clearly set out our expectations of our Suppliers;
  • Develop the assessment process of self-questionnaires and follow up;
  • Extend  training and awareness to the wider GMG business (outside of procurement);

GMG remain committed to the participation and responsibility of eradicating Modern Slavery from its supply chain.