12.3
If you are unsure about whether a particular act constitutes bribery or corruption, raise it with Luke Wellings.
13.
PROTECTION
13.1
Individuals who refuse to accept or offer a bribe, or who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We aim 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. We 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 compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the Staff Handbook.
13.2
14.
TRAINING AND COMMUNICATION
14.1
Training on this policy forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
14.2
Our 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.
15.
BREACHES OF THIS POLICY
15.1
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
15.2
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
16.
POTENTIAL RISK SCENARIOS: "RED FLAGS"
16.1
The following is a list of possible red flags that may arise during the course of you working for us and which may raise concerns under various anti-bribery and anti- corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.
If you encounter any of these red flags while working for us, you must report them promptly to your manager:
(a) you become aware that a third party engages in, or has been accused of engaging in, improper business practices;
(b) you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a "special relationship" with foreign government officials; (c) a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us; (d) a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;
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