Anti-Bribery Policy



The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations and to ensure that the Company’s business is conducted in a socially responsible manner.


It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption in all jurisdictions in which we operate. However, we are bound by the laws of Australia in respect to our conduct both at home and overseas and take our legal responsibilities very seriously.


In this policy, third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies.

This policy applies to all individuals working at all levels, including managers, directors, employees (whether permanent or casual), consultants, contractors, trainees, volunteers, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy)

The policy covers:


Employees must not engage in any form of bribery, either directly or through any third party. Specifically, employees must not bribe a foreign public official anywhere in the world.

Gifts and Hospitality

Employees must not offer or give any gift or hospitality which could be regarded as illegal or improper or which violates the recipient’s policies OR to any public employee or government officials or representatives, or politicians or political parties OR which exceeds $50 in value for each individual gift or $200 in value for each hospitality event (not to exceed a total value of $1000 in any financial year) unless approved in writing by a Director.

Employees must not accept any gift or hospitality from our business partners if it exceeds $50 in value for each individual gift or $200 in value for each hospitality event (not to exceed a total of $1000 in any financial year) unless approved in writing by a Director OR it is in cash OR there is a suggestion that a return favour will be expected or implied.

If it is not appropriate to decline the offer of a gift, the gift may be accepted, provided it is then declared to a Director and donated to charity.

We appreciate that the practice of giving business gifts varies as does what may be considered normal and acceptable. The test to be applied is whether in all circumstances the gift or hospitality is reasonable and justifiable. The intention should always be considered.

Within these parameters, management may define specific guidelines and policies to reflect local professional and industry standards. Where the policy requires written approval to be given, the Company Secretary shall implement a process to maintain a register of all such approvals.

Facilitation Payments and Kickbacks

Our strict policy is that facilitation payments must not be paid. We recognise, however, that our employees may be faced with situations where there is a risk to the personal security of an employee or his/her family and where a facilitation payment is unavoidable, in which case the employee must keep any amount to a minimum, create a record of the payment and report it to a Manager/Director.


In order to achieve our aim of not making any facilitation payments, the Company will keep a record of all payments made, which must be reported to the Company Secretary, in order to evaluate the business risk and to develop a strategy to minimise such payments in the future.


Political Contributions

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


Charitable Contributions

Charitable support and donations are acceptable (and encouraged), whether of inkind 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 the prior approval of a Director.



You must ensure that you read, understand and comply with this policy.


The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of policy.


You must notify your Manager OR the Company Secretary as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future.


Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy.



We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.


You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.


You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.


All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept ‘off-book’ to facilitate or conceal improper payments.



You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries or concerns, these should be raised with a Manager or Company Secretary.



It is important that you tell the Company Secretary as soon as possible if you are bribed by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.



We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Company Secretary immediately. If the matter is not remedied, and you are an employee, you should raise it formally as outlined in the Fair Work Act.



Training on this policy forms part of the induction process for all new employees. All existing employees will receive regular, relevant training on how to implement and adhere to this policy. In addition, all employees will be asked to accept conformance to this policy on an annual basis.


Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.



The Directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.


The Company Secretary has primary and day-to-day responsibility for implementing this policy, and for monitoring its use and effectiveness and dealing with any queries on its interpretation. Management is responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.



The Company Secretary will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.


All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.


Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Company Secretary.


This policy does not form part of any employee’s contract of employment and it may be amended at any time.


Deborah Venus

Company Secretary

17th January 2014

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