Effective Date: 5th December 2023
Approved By: Executive Management
Applies To: All AKoft employees, contractors, consultants, and business partners globally
1. Purpose
The purpose of this policy is to uphold AKoft’s commitment to conducting business with the highest standards of integrity, transparency, and accountability. This policy sets forth the principles and procedures designed to prevent corruption, bribery, and unethical behaviour in all business activities.
2. Scope
This policy applies to all employees, officers, directors, contractors, agents, and third parties acting on behalf of AKoft in any country where we operate.
3. Policy Statement
AKoft maintains a zero-tolerance stance toward all forms of bribery and corruption. We comply with applicable anti-corruption laws, including but not limited to:
- The Australian Criminal Code (Division 70 – foreign bribery)
- The U.S. Foreign Corrupt Practices Act (FCPA)
- The UK Bribery Act
- Any other local laws in jurisdictions where AKoft operates
No employee or representative of AKoft may offer, give, solicit, or accept bribes or improper payments in any form.
4. Key Principles
4.1 Bribery and Facilitation Payments
- Bribes, kickbacks, or “facilitation payments” are strictly prohibited, even if common in a particular country.
- This applies to interactions with public officials, private sector clients, and vendors.
4.2 Gifts, Entertainment, and Hospitality
- Modest, infrequent gifts or hospitality may be acceptable, but must not influence (or appear to influence) a business decision.
- All gifts or hospitality over AUD $100 must be disclosed and approved by a Compliance Officer.
4.3 Conflicts of Interest
- Employees must avoid situations where personal interests conflict with professional duties.
- Any actual or potential conflict must be reported to management immediately.
4.4 Political and Charitable Contributions
- AKoft does not make political donations.
- Charitable contributions must be transparent, properly documented, and not used as a channel for bribery.
4.5 Third Parties and Partners
- All third parties (consultants, agents, suppliers) must undergo due diligence and agree to comply with AKoft’s anti-corruption standards.
- Written contracts must include anti-bribery clauses.
5. Responsibilities
Employees
- Read, understand, and comply with this policy
- Complete mandatory ethics and anti-corruption training
- Report any suspected violations without fear of retaliation
Management
- Lead by example and promote ethical behaviour
- Ensure team members are trained and supported in compliance matters
- Investigate and address any breaches of this policy
Compliance Officer
- Oversee implementation of the policy
- Maintain training records and audit trails
- Investigate reports of misconduct and take corrective action
6. Reporting Concerns
Concerns or suspected violations can be reported through the following channels:
- Email: info@akoft.com
- Reports may be made anonymously, and AKoft strictly prohibits retaliation against whistleblowers.
7. Disciplinary Action
Violations of this policy may result in disciplinary action up to and including termination of employment, termination of contracts, and legal action where appropriate.
8. Monitoring and Review
This policy is reviewed annually by the Compliance Officer and approved by executive leadership to ensure it remains current with legal and operational requirements.
