Anti-Bribery and Corruption Policy

This Anti-Bribery and Corruption Policy describes the policy, rules and procedures of an organisation with respect to the dealings and management of gifts, benefits and payments of money to any third party or the receipt of gifts, benefits and money by a third party.

This Anti-Bribery and Corruption Policy is used to supplement and expand on the organisation’s Code of Conduct and is suitable for organisations of all sizes.


  1. Purpose. 1
  2. Scope. 2
  3. Bribery and corruption. 2
  4. Principles. 3
  5. Procedures and processes. 4
  6. Record-Keeping. 5
  7. Organisational responsibilities. 5
  8. Senior management 5
  9. Employees. 5
  10. Document information. 6


The purpose of this Anti-Bribery and Corruption Policy is to make a statement about [Organisation name]’s position on, and a commitment to, maintaining a high standard of integrity and ensuring that all decisions and activities of [Organisation name] are not influenced by gifts, benefits and bribery.

The processes and procedures implemented for the management of gifts and benefits under this Anti-Bribery and Corruption Policy have been put in place to also protect all directors, officers, employees, consultants and contractors of [Organisation name] (staff) from the risk of a loss of their personal reputation, integrity and objectivity due to a conflict of interest and consequent actions or omissions taken by staff which may be illegal, immoral or unethical.

The principles by which this Anti-Bribery and Corruption Policy is formulated are based on the principles of integrity, fairness and ethics in alignment with [Organisation name]’s Code of Conduct.


This Anti-Bribery and Corruption Policy applies to all staff in a global capacity. If travelling outside of Australia for any business-related activity, all staff must still comply with the principles and guidelines of this Policy whether or not the country in which they are in has specific anti-bribery and corruption laws.

This Anti-Bribery and Corruption Policy extends to all current and future activities of [Organisation name], and to any new opportunities [Organisation name] may encounter from time to time.

Bribery and corruption

Bribery of both public officials and private individuals is a criminal offence in Australia under relevant Bribery Laws.

Bribery occurs when you offer, or provide, a payment or a benefit to someone to either influence the performance of that person’s duty, or encourage misuse of that person’s authority, or both in order to gain any commercial, contractual, regulatory or personal advantage for yourself, your family member or for another person or third party.

A “benefit” can include any form of advantage such as:

  1. Giving or lending money;
  2. Giving or lending tangible or intangible property e.g. car, support or backing;
  3. Personal advantage e.g. employment of public officials or their relatives;
  4. Promotional, travelling or accommodation expenses;
  5. Facilitation payments;
  6. Political or charitable donations; and
  7. Any form of gift or corporate hospitality.

The benefit can be given directly or indirectly to the individual e.g. providing the benefit to a family member or friend or corporation controlled by the individual to influence the individual in the performance of their duty can still be considered bribery.

If you do not personally provide the benefit but assist or ask a colleague, friend or family member to provide the benefit to the individual, then you may be found to have aided, abetted, counselled or procured a bribe. Aiding and abetting a criminal activity, is in itself, also a crime under the Bribery Laws.


[Organisation name] has implemented a process for managing the provision of gifts and benefits to any person or entity by any staff of [Organisation name] whom the staff has come into contact with during the course of their work including:

  1. any actual or potential clients or customers;
  2. any actual or potential suppliers, distributors or vendors;
  3. any actual or potential business contacts, agents or advisors;
  4. any government or public bodies, and their advisors, representatives and officials;
  5. any politicians or political parties.

Principle 1: Prohibition on giving or receiving bribes

No staff of [Organisation name] may give, offer, promise, accept, request or authorise a bribe from or to any other person, whether directly or indirectly.

Principle 2: Management of gifts

Only gifts and benefits that are offered, provided or received for the following reasons and in the following circumstances are permissible:

  1. The gift or benefit is offered, provided or received as an act of appreciation or common courtesy associated with standard business practice;
  2. The gift or benefit offered, provided or received does not impose any obligation on either the giver or the recipient to do an act or omit to do an act;
  3. There are no expectations or importance attached to the gift or benefit offered, provided or received by the giver;
  4. The gift or benefit was offered, provided or received openly and not secretly or in an undocumented form;
  5. The gift or benefit is of reasonable value, small and in accordance with general business practice;
  6. The gift or benefit is appropriate to the nature of the relationship;
  7. The gift or benefit is offered at “arms’ length” with no special favours and no special arrangements;
  8. The gift or benefit is legal in that it does not in any way breach any rules or regulations and complies with all relevant laws; and
  9. The gift or benefit is documented and recorded in the Gift and Entertainment Register.

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