Bribery Policy

This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, home workers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located.

Published: July 2019

Pages: 6

BESA Product Code: LC 39

Policy statement
It is our policy to conduct all of our business in an honest and ethical manner.
We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly
and with integrity in all our business dealings and relationships and implementing and enforcing effective
systems to counter bribery.
We will uphold all laws relevant to countering bribery and corruption.

In this policy:
Who is covered by the policy?
This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors,
employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff,
home workers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person
associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as
“workers” in this policy).

What is bribery?
A bribe is an inducement or reward offered, promised or provided in order to gain any commercial,
contractual, regulatory or personal advantage.