Anti-Bribery & Corruption Policy

McCabe Curwood Pty Ltd ACN 626 085 685 is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery and corruption is prevented. McCabe Curwood is committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the world we operate.

Who is covered by the policy?

The anti-bribery & corruption policy applies to all Shareholders, Directors, employees and consultants (employees).

In the context of this policy, third-party refers to any individual or organisation McCabe Curwood meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – including their advisors, representatives and officials, politicians, and public parties.

Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with.

Definition of bribery

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.

A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

Employees must not engage in any form of bribery, whether it be directly, passively or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s Proper Officer.

What is and what is not acceptable

1. Gifts and hospitality

McCabe Curwood accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:

The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the compliance manager should be sought.

2. Facilitation payments and kickbacks

McCabe Curwood does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action.

McCabe Curwood does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.

3. Political contributions

McCabe Curwood will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.

4. Charitable contributions

McCabe Curwood accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.

Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.

McCabe Curwood ensures that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the Proper Officer.

Training and communication

McCabe Curwood provides training on this policy as part of the induction process for all new employees. Employees also receive regular, relevant training on how to adhere to this policy, and are asked annually to formally accept that they will comply with this policy.

McCabe Curwood’s anti-bribery & corruption policy and zero-tolerance attitude is clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.

Record keeping

McCabe Curwood keeps detailed and accurate financial records and has appropriate internal controls in place to act as evidence for all payments made. We declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.

Monitoring and reviewing

McCabe Curwood’s Proper Officer is responsible for monitoring the effectiveness of this policy and reviewing its implementation on an annual basis.

Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.