Anti-Bribery Policy

Our Commitment to Anti-Bribery & Corruption

1. Purpose

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.

2. Scope

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 the Company’s staff members are individually responsible for complying with this Policy and any breach may lead to disciplinary action, dismissal or termination of contract.

3. Prohibition of Bribery

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 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). 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.

Bribery is:

  • The offering, promising, giving, requesting or accepting of a payment, inducement, reward or other benefit to another person in circumstances where:
    • the benefit is not legitimately due to the other person; and
    • the benefit is given with the intention of influencing the other person in order to obtain or retain business, or a business advantage, that is not legitimately due to the recipient.

Bribes can be given in many forms and do not necessarily involve payments of cash. A bribe could be, for example:

  • Kickbacks – where a percentage from a contract is improperly returned to the person awarding that contract.
  • Facilitation payments or “grease” payments – usually small, non-discretionary payments to government / public officials to speed up routine administrative processes.
  • Inflated commissions – where higher than normal commissions are paid as a reward for improper behaviour.
  • Political or charitable donations – for example, donating to a political party in exchange for their support for legislation that is favourable to the Company’s business or donating to a charity, which is used to funnel money to local government officials.
  • Excessive or inappropriate entertainment, which may influence the recipient.

It is an offence for companies or individuals to directly or indirectly bribe bribe a public official. It is unlawful to offer a bribe, regardless of whether the offer is accepted, or the benefit gained.

4. Gifts and Hospitality

Staff members must never use gifts or hospitality to improperly influence a business decision-making process, or which may be perceived as an improper influence. The Company’s Code of Conduct prohibits staff members from receiving or giving gifts, benefits, or favours where these might influence, or be perceived to influence, the decision making of yourself or another person.

Staff members are permitted to accept invitations to reasonable corporate events that will help encourage good working relationships between the Company and its stakeholders and to accept or give gifts which are of a nominal value, and which are consistent with normal business practices and/or local customs.

Staff members, contractors and third parties providing services to the Company must never give, request, offer or accept, directly or indirectly:

  • cash, loans, or cash equivalents.
  • travel and / or accommodation costs for family members.
  • invitations for family members to go to events or be provided meals where the staff member is not present.
  • gifts or hospitality during periods when important decisions regarding the award or retention of business are being made.

5. Dealings with Public Officials

Whenever the Company deals with governments, government agencies, public officials or public agencies, our staff members and contractors must apply the highest ethical standards and comply with all applicable laws. 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.

6. Documents and Record Keeping

The Company must maintain accurate books and records. Accurate and complete records of all business transactions must be kept:

  • In accordance with generally accepted accounting principles and practices.
  • In accordance with the Company’s accounting and finance policies.
  • In a manner that reasonably reflects the underlying transactions and events.

It is the responsibility of all staff members 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.

7. Reporting of Misconduct and Wrongdoing

Staff members 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.

Policy Compliance Statement

Responsible Executive: CEO
Date of Review: May 2022
Approved By:  Inclusee Ltd Board