Anti Bribery Policy
TABLE OF CONTENTS
Introduction
The Digital Project Corporation Pty Ltd (Company) is committed to conducting business in an ethical and transparent manner, and we have a zero-tolerance approach towards bribery and corruption. This Anti-Bribery and Corruption Policy (Policy) outlines our commitment to prevent bribery and corruption in the workplace and provides guidance to all employees, contractors, and stakeholders on their responsibilities in this regard. This Policy is designed to ensure compliance with all applicable anti-bribery and corruption laws, including State and Territory crimes legislation, the Corporations Act 2001 (Cth), the Commonwealth Criminal Code, and any other relevant legislation, regulations, and best practices both in Australia and offshore.
Scope
This policy applies to all individuals who work for or on behalf of the Company, including but not limited to employees, contractors, consultants, agents, intermediaries, and business partners. It covers all our business operations, both within Australia and internationally, and includes interactions with government officials, customers, suppliers, and other third parties.
Definitions
For the purposes of this Policy, the following definitions apply:
Bribery means the offering, promising, giving, accepting, or soliciting of a benefit or business advantage (financial or otherwise) as an inducement or reward for an individual or entity to act improperly or to secure an improper advantage.
Compliance Officer means a person appointed by the Company to oversee compliance with this policy.
Corruption means the abuse of entrusted power for private gain, which includes bribery and other forms of unethical or unlawful conduct.
Prohibited conduct
The Company strictly prohibits any form of bribery, corruption, or facilitation payments, whether direct or indirect, in any business activity or relationship. This includes but is not limited to:
- Offering, promising, giving, or accepting bribes, kickbacks, or improper payments, in cash or any other form, to anyone, including domestic or foreign government officials, customers, suppliers, or any other third party, to influence or obtain improper business advantages.
- Making or receiving facilitation payments, which are small payments made to expedite routine actions or processes that are otherwise part of an official's duties.
- Creating or using slush funds, off-books accounts, or any other form of undisclosed or unrecorded payments or transactions.
- Using third parties, such as agents, intermediaries, or consultants, to facilitate or conceal bribery or corruption.
- Conspiracy, aiding and abetting or complicity in bribery or corruption.
- Money laundering.
- Engaging in any other conduct that may violate anti-bribery and corruption laws or the principles of fairness, integrity, and transparency.
Responsibilities
Management
- The senior management of the Company is responsible for setting the tone at the top and promoting a culture of integrity and compliance.
- Working with the Compliance Officer, they are accountable for ensuring that all employees, contractors, and stakeholders are aware of and comply with this policy and applicable anti-bribery and corruption laws.
- They will also periodically conduct a risk assessment of the Company's operations, activities, and transactions to identify and address potential areas of vulnerability to bribery and corruption.
Employees and contractors
- All employees and contractors are expected to understand and comply with this policy, as well as relevant laws and regulations.
- They must avoid engaging in any conduct that may be perceived as bribery or corruption, and report any suspected or actual violations to their supervisor, manager, or the designated Compliance Officer.
- They must avoid situations where they could be influenced, or could be perceived to be influenced, by a personal interest in carrying out otherwise legitimate transactions on behalf of the Company. For more information, see the Company's Conflict of Interest Policy.
- Third parties
- The Company expects all third parties, such as agents, intermediaries, and business partners, to comply with this policy and applicable laws.
- The Company will conduct due diligence on third parties before engaging in any business relationship, and include anti-bribery and corruption clauses in contracts and agreements.
- Gifts, hospitality, and expenses
- Gifts and hospitality
The Company acknowledges that giving and receiving gifts, hospitality, and entertainment may be a legitimate part of business relationships, but they should not be used to influence or obtain improper business advantages. The Company's Gift Policy governs the giving and receiving of gifts, hospitality and entertainment.
6.2. Expenses
All expense claims must be accurate, supported by valid receipts, and incurred for legitimate business purposes. Falsifying expense claims or using them to cover up bribes or other improper payments is strictly prohibited.
- Record-keeping and transparency
The Company maintains accurate records of all financial transactions and business activities, and ensures that they are transparent, verifiable, and auditable. All employees and contractors must accurately record all business transactions in the Company's books and records, and report any irregularities or suspicions to their supervisor, manager, or the Compliance Officer.
- Reporting, investigation and whistleblower protection
8.1. Reporting
All employees and contractors are encouraged to report any suspected or actual violations of this policy or applicable anti-bribery and corruption laws to their supervisor, manager, or the Compliance Officer.
8.2. Investigation
All reported violations will be promptly and thoroughly investigated by the Company's designated investigation team, which will follow established investigation protocols and ensure confidentiality to the extent possible. Employees and contractors are expected to cooperate fully with any investigation and provide accurate and truthful information.
8.3. W histleblower protection
The Company is committed to ensuring that no person who reports any actual or suspected violation of this Policy or any applicable anti-bribery and corruption laws in good faith suffers any form of retaliation, discrimination, or adverse employment consequence. Any employee who engages in such retaliation, discrimination, or adverse employment consequence will be subject to disciplinary action, up to and including termination of employment.
- Consequences of violations
Violations of this policy or applicable anti-bribery and corruption laws may result in disciplinary action, up to and including termination of employment or contract, as well as civil or criminal liability. The Company will take appropriate remedial measures to address any confirmed violations, including implementing corrective actions, improving controls, and reporting to relevant authorities as required.
- Compliance with laws and regulations
The Company is committed to full compliance with all applicable laws and regulations, including anti-bribery and corruption laws in Australia and other countries where we operate. Failure to comply with this policy or applicable laws may result in severe legal consequences for both the individual and the Company.
- Monitoring and review
The Company will periodically review and update this policy to ensure its effectiveness and compliance with changing laws, regulations, and best practices. The Compliance Officer will monitor and assess the Company's compliance with this policy and report to senior management and the board of directors as appropriate.
- Training and awareness
The Company provides:
Policy and Familiarisation Understanding Risks Roles and Responsibilities Training and Case Studies Consequences and Legal Implications Assessment and Evaluation
- Further information and advice
For further information, contact the Compliance Officer (Nikki Scott).