ANTI CORRUPTION POLICY
Introduction
This is the Anti-Corruption Policy for Brooksight.
Objectives
The objectives of this policy are:
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To ensure compliance with all applicable anti-bribery and corruption regulations.
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To ensure that the Company’s business is conducted in a socially responsible manner.
Scope
This policy applies to all Brooksight staff, sub-contractors and partners whether working in or out of the Office and whether inside or outside of office hours.
This policy does not form part of any employee's contract of employment and it may be amended at any time.
Policy statement
Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal 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.
Brooksight’s policy is to:
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Conduct all business in an honest and ethical manner
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Take a zero tolerance approach to bribery and corruption
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Be committed to acting professionally, fairly and with integrity in all their business dealings and relationships wherever the company operates
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Implement and enforce effective systems to counter bribery
Brooksight will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which the company operates. However, Brooksight remains bound by the laws of Australia. If Brooksight are found to have taken part in corruption, they could face prosecution, be excluded from tendering for public contracts and face damage to their reputation. Brooksight therefore takes their legal responsibilities very seriously.
Scope of Policy
Who is covered by the policy?
In this policy, third party means any individual or organisation you come into contact with during the course of your work for Brooksight, and includes actual and potential clients, subjects, persons of interest, customers, suppliers, distributors, business contacts, agents, advisors, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, temporary) consultants, contractors, sub-contractors, trainees, seconded staff, casual workers or any other person associated with us, wherever located (collectively referred to as employees in this policy).
This policy covers:
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Bribes
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Gifts and hospitality
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Facilitation payments
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Political contributions
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Charitable contributions
Bribes
Employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor).
Gifts and hospitality
Members of Brooksight staff are not permitted, under any circumstances to accept any gifts or entertainment regardless of the amount, from their clients, business suppliers and vendors.
To assist in providing guidance on what is governed by the Policy, the following are examples of what is considered unacceptable and not to be offered to any Brooksight staff (note this list is not exhaustive):
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cash and cash equivalents (such as a gift voucher or movie ticket vouchers)
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gifts (such as chocolates, wine, Christmas hampers, flowers etc.)
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invitation to lunches, cocktail functions or other events that are social or recreational (including restaurant lunches, Christmas lunches and events, harbour cruise, sporting or cultural events either as a spectator or as a participant)
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invitations or complimentary tickets to business seminars and conferences (such as Women in Insurance or a seminar or conference event paid for by you or your firm)
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promotional items (branded notepads, pens, calendars etc.)
Employees must also not offer or give any gift or hospitality to any client, Brooksight staff, sub-contractor or supplier:
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which could be regarded as illegal or improper, or which violates the recipient’s policies; or
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to any public employee or government officials or representatives, or politicians or political parties
Your responsibilities
You must ensure that you read, understand and comply with this policy.
All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for, or under the control of, Brooksight.
You must notify Management 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. Brooksight reserves their right to terminate their contractual relationship with other workers if they breach this policy.
Record-keeping
Brooksight 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.
How to raise a concern
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 Brooksight Management.
Report these concerns to any Brooksight Manager who has an obligation to enter it as an issue on the Issue Register. This will ensure that the concern is properly investigated, actioned and documented.
What to do if you are a victim of bribery or corruption
It is important that you advise Brooksight Management as soon as possible if you are offered a bribe 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.
Report these events to any Brooksight Manager who has an obligation to enter it as an issue on the Issue Register. This will ensure that the concern is properly investigated, actioned and documented.
Protection
Employees who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. Brooksight aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
Brooksight 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 Brooksight Managing Director immediately.
If a matter is not remedied, and you are an employee, you should raise it formally using the company’s issue process.
Report these events to any Brooksight Manager who has an obligation to enter it as an issue on the Issue Register. This will ensure that the concern is properly investigated, actioned and documented. More details in the Risk and Issue Management Policy.
Training and communication
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 formally accept conformance to this policy on an annual basis.
Brooksight’s 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. More information in the Supplier Management Policy.
Who is responsible for the policy?
The board of directors has overall responsibility for ensuring this policy complies with Brooksight’s legal and ethical obligations, and that all those under Brooksight’s control comply with it.
The General Manager 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 at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.
Brooksight management are obliged to log all reported potential breaches on the Issue Register or events so that they are formally followed up. More details in the Risk and Issue Management Policy.
Monitoring and review
The General Manager will monitor the effectiveness, adequacy and suitability of this policy and review its implementation. 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 General Manager and the Managing Director.
For further information please contact us on the details below.