Inclusee Ltd (the Company) is committed to conducting its business in a fair and ethical way, without using unlawful practices to obtain unfair advantages in our business dealings. The Company acknowledges that bribes and corrupt practices are morally unacceptable, as they harm societies in which these acts are committed and prevent economic growth and development. They are also illegal in Australia and in most countries around the world.
This Policy will be communicated to all Company staff members and business associates working on our behalf. Any breach of this Policy will be regarded as a serious matter and may result in disciplinary action, dismissal or termination of contract.
This policy applies to the Company, its directors, officers and staff members as well as any contractors or other third parties engaged to provide services on behalf of the Company.
This Policy applies in all jurisdictions where the Company does business. It must be adhered to in all Company business dealings and transactions in all countries, with domestic or foreign government / public officials and transactions with private companies or persons.
All of Inclusee’s directors, officers, staff members, contractors or other third parties engaged to provide services on behalf of Inclusee, are individually responsible for complying with this Policy and any breach may lead to disciplinary action, dismissal or termination of contract.
The Company will not engage in bribery or corruption in any form, whether it involves individuals or companies in the public or private sector, in Australia or any other jurisdictions in which the Company operates.
It is strictly prohibited for directors, officers, staff members, contractors and third parties providing services on behalf of the Company to directly or indirectly accept, request, agree to receive, promise, offer or give a bribe.
All Company business activities must be conducted in full compliance with this Policy and all applicable anti-bribery and corruption laws including, but not limited to, the Commonwealth of Australia Criminal Code Act 1995 (Cth) and Crimes Legislation Amendment (Combatting Foreign Bribery) Act 2024 (Cth). To the extent that laws and regulations in any countries in which the Company operates with are more rigorous or restrictive than this Policy, those laws and regulations should be followed.
The offering, promising, giving, requesting or accepting of a payment, inducement, reward or other benefit to another person in circumstances where:
Bribes can be given in many forms and do not necessarily involve payments of cash. A bribe could be, for example:
It is an offence for companies or individuals to directly or indirectly bribe a public official. It is unlawful to offer a bribe, regardless of whether the offer is accepted, or the benefit gained. It is also an offence for a company or its directors or officers to fail to prevent bribery.
It is important to note that Inclusee Ltd strictly prohibits all staff members, volunteers, contractors, board members, and any other representative of the organisation from accepting gifts in any form. All offers of gifts must be declared to the CEO.
Invitations to reasonable corporate events that support the development of positive relationships with stakeholders, are permittable.
Inclusee staff members, volunteers, contractors, board members and any other representative of the organisation, must never give, request, accept or offer:
Whenever the Company deals with governments, government agencies, public officials or public agencies, all of Inclusee’s directors, officers, staff members, contractors and any third parties providing services on behalf of the Company, must apply the highest ethical standards and comply with all applicable laws.
This includes candidates for public office and could include employees of state-owned commercial enterprises. No one acting on behalf of the Company should exert, or attempt to exert, any improper or illegal influence on public officials. Improper or secret payments or improper transfers of any value made to public officials are strictly prohibited. This includes transfers made through intermediaries, or to a third party.
The Company must maintain accurate books and records. Accurate and complete records of all business transactions must be kept:
It is the responsibility of our directors, officers, staff members, contractors and any third parties providing services on behalf of the Company, to ensure that all business transactions are recorded honestly and accurately and that any errors or falsification of documents are promptly reported to the Company and corrected.
Directors, officers, staff members, contractors and any third parties providing services on behalf of the Company that become aware of any breach of this Policy should immediately report it to their manager or the CEO. Reports may also be made under the Whistleblower Policy, on an anonymous basis if desired.
For any questions about Inclusee’s policies, please contact us.
Responsible Executive: CEO
Date of Review: September 2025
Approved By: Inclusee Ltd Board
