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Anti-Bribery and Corruption Policy

Anti-Bribery and Corruption Policy

Purpose

To establish and maintain a clear and high standard of commitment and compliance with the laws and regulations governing anti-bribery and corruption in Australia. As SKL Executive operates on a foundation of trust, integrity and maintaining positive professional relationships with our clients, candidates, employees, and other stakeholders, SKL Executive has zero tolerance to bribery and corruption.

This policy displays SKL Executive’s responsibilities, and of those working for us, in observing and upholding our position against bribery and corruption; and to provide information and guidance to all workers and contacts of SKL Executive related to bribery and corruption matters.

Scope

This policy applies to all persons working directly for or on behalf of SKL Executive in any capacity, including employees at all levels such as directors, managing directors, principals, consultants, contractors, external consultants or any third party representatives or sponsors, or persons associated with us, wherever located (collectively referred to as “workers” in this Policy). 

Third party means any individual or organisation that SKL Executive employees may come into contact with during the course of their work, including actual and potential clients, candidates, government and public bodies, including politicians and political parties.

This Policy applies globally. If any workers of SKL Executive travels outside of Australia, they are subject to the laws of the country they are in; however, the principles of this Policy must be followed regardless of whether that country has bribery and corruption regulations. Where the country of travel has bribery and corruption regulations of a lesser standard to this Policy, this Policy prevails.

Policy

SKL Executive workers are not permitted to give, offer, promise, accept, request or authorise a bribe, whether directly or indirectly wherever they are located.

Defining Bribery and Corruption

Bribery is the offering, promising, giving or acceptance of any financial or other advantage, to induce the recipient or relevant beneficiary to act improperly in the performance of their functions and duties, or to reward them for improper acts as a consequence of accepting the bribe.

An advantage may include money, gifts, loans, fees, hospitality, services, discounts or anything else of value agreed between parties.

A person will be acting improperly when the act is illegal, unethical or contrary to a professional expectation of good faith and impartiality or where they have abused their position. The improper acts may be in relation to any professional or business related activity, public function or acts during the course of their employment.

Corruption is an abuse of position or power for private gain or business advantage.

What SKL Executive workers must not do

SKL Executive will not accept any of its workers or anyone on their behalf to:

  • Give or accept a gift or hospitality during any commercial negotiations or tender procedure if it can be perceived to intentionally or inadvertently influence the outcome
  • Accept a payment, gift or hospitality from any third party known or suspected to offer it with the expectation that SKL Executive will provide a business advantage to them or another entity in return
  • Offer or accept a gift, payment or hospitality to, or from, government officials or representatives or politicians or political parties
  • Engage in any other activity that will breach or lead to a breach of this policy and its purpose

Acceptable gift and entertainment expenditure

Examples of acceptable gifts and/or benefits and/or hospitality:

  • Token gifts/benefits where offered in business situations or to all participants and attendees (e.g. work related conferences, trade and business events and include, but not limited to, pens, caps, stationary, coffee mugs, stress balls, mouse pads, corporate umbrellas, memory sticks and etc.)
  • A gift/benefit for presenting or attending a work-related conference, seminar and/or business event
  • Gift/benefit given in gratitude when hosting business events or overseas delegations where refusal would be unreasonable and/or unnecessarily offensive
  • Light refreshments or modest meals during business or work-related meetings

Record-Keeping

SKL Executive will keep financial and transaction records to evidence business reasons for making payments to, or for, third parties. Examples of such records include, but are not limited to, receipts and workers’ diary entries.

The records will be subject to managerial review and internal and, or external audit. The workers must ensure all expenses claimed relating to hospitality, gifts or expenses incurred to, or from, third parties are submitted in accordance with SKL Executive’s expenses processing procedures and record the specific reason for the expenditure.

All accounts, invoices, memoranda, documents or other records related to third party dealings, such as clients, candidates and business contacts, must be prepared and maintained with strict accuracy and completeness. No accounts are to be kept “off the books” to conceal or enable improper payments.

SKL Executive notes that it is an offence under the Crimes Legislation Amendment (Proceeds of Crime and Other Measures) Act 2016 for a person to make, alter, destroy or conceal an accounting document (including being reckless in their conduct which allows such act) to facilitate, conceal or disguise corrupt conduct.

Breach of Policy

A breach of this policy by any of SKL Executive’s workers will result in disciplinary action (including termination of employment or engagement).

SKL Executive employees, Directors and third parties must recognise that:

  • A breach of this policy may result in legal or regulatory action including criminal proceedings against the person/s involved
  • All employees are personally responsible for protecting SKL Executive’s reputation and themselves from the risks arising from bribery and corruption
  • SKL Executive will cooperate with authorities if any legal, regulatory or criminal investigations or proceedings are brought in relation to alleged violation of anti-bribery and corruption laws.