Anti-Bribery and Corruption Policy




The Company has implemented a Code of Conduct, which has at its core, the commitment to conducting business in an open and accountable way. The Company strives to maintain a high standard of integrity, investor confidence and good corporate governance.

This policy states the Company’s requirements regarding the management of gifts and benefits, which protects you and your reputation and minimises potential negative consequences for you and the Company.

This policy applies globally. If travelling outside of Australia, Company employees are subject to the laws of the country they are in; however, the principles of this policy must be followed regardless of whether or not that country has specific bribery and corruption laws.


Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal, unethical or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage and can take the form of gifts, loans, fees, rewards or other advantages e.g. Donations. Corruption is the abuse of entrusted power for private gain (as defined by Transparency International).


This policy applies to anyone who is employed by or works at the Company, including employees (whether permanent, fixed-term or temporary), contractors, consultants, secondees and directors wherever located (collectively referred to as employees in this policy).

Third party means any individual or organisation you come into contact with during the course of your work, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

This policy covers:

  • Bribes
  • Gifts and hospitality
  • Facilitation payments
  • Political contributions
  • Charitable contributions


4.1 Bribes

Company employees are not permitted to give, offer, promise, accept, request or authorise a bribe, whether directly or indirectly.

 4.2 Gifts and Hospitality

Company employees must declare and report gifts and / or benefits, either offered or accepted and valued at $200 or more, in the Gift and Entertainment Register to safeguard and make transparent their relationships and dealings with individuals, organisations and client groups.

Employees should notify their manager of the fact that they have received the gift or benefit and must make the entry within 5 working days of receiving / being offered the gift or benefit. If it is known in advance, the receipt of the gift or benefit should be discussed with your manager prior to acceptance. Gifts should not be accepted on a re-occurring basis or broken down into parts of less than $200.

Gifts and genuine hospitality and entertainment expenditure that is reasonable and proportionate is allowable provided it complies with the following:

  • Made for the right reason – it should be clearly given as an act of appreciation or common courtesy.
  • No obligation – it does not place the recipient under any obligation.
  • No expectation – expectations are not created by the giver or an associate of the giver or have a higher importance attached to it by the giver than the recipient would place on such a transaction.
  • Made openly – if made secretly and undocumented then the purpose will be open to question.
  • Reasonable value – its size is relatively small and not inconsistent with general business practice.
  • Appropriate – its nature is appropriate to the relationship.
  • At “arm’s length” – all transactions / gifts should be at an “arm’s length” basis with no special favours and no special arrangements.
  • Legal – it complies with relevant laws.

These circumstances are never acceptable:

  • Gifts in the form of cash and / or cash equivalent vouchers or gift certificates.
  • “Quid pro quo” (a benefit or advantage offered for something in return).
  • Entertainment of a sexual or similarly inappropriate nature.
  • Making incomplete, false or inaccurate entries in the ASX’s books and records, e.g. Gift and Entertainment Register.

4.3 Charitable Contributions

The Company’s community programs allow employees to support causes and charities of their choice from a broad list of charity partners. Charitable support and donations are acceptable (and indeed are encouraged via the Company in the Community), whether of in-kind 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 on behalf of the Company without the prior approval of the MD/CEO.


Under the Code of Conduct, all Company employees have a responsibility to help detect, prevent and report instances not only of bribery and corruption, but also of any other suspicious activity or wrongdoing in connection with the Company’s business. The Company is committed to ensuring that all employees have a safe, reliable and confidential way of reporting any suspicious activity.

If you are not comfortable, for any reason, with speaking directly to your manager, the Company has a Whistle-blower Policy which affords certain protections against reprisal, harassment or demotion for making the report.