Ethical Behaviour and Anti-Corruption Policy

 

Introduction Overview

Askable takes a zero-tolerance approach to unethical behaviour, bribery and corruption and is committed to conducting its business with honesty, integrity and the highest standards of personal, professional and ethical behaviour. Being unethical and corrupt are not compatible with Askable’s values. They are unlawful and will not be tolerated.

The executive team, management and senior staff at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy.

Purpose

The purpose of this policy is to:

          Set out Askable staff responsibilities and the responsibilities of third parties who we deal with in observing and upholding our position on bribery and corruption; and

          Provide information and guidance to Askable staff on how to recognise and deal with bribery and corruption issues

Laws and Regulations

Askable conducts all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery, corruption and slavery, and we are committed to acting professionally, fairly and with integrity in all of our business dealings and relationships, wherever we operate.

Bribery and Corruption

Bribery and corruption can take on many different shapes and forms, but typically both parties will be benefitted. It does not matter whether the bribe is:

          given or received directly or indirectly through a third party;

          for the benefit of the recipient or some other person;

          money or cash equivalent;

          unreasonable or extravagant gifts, entertainment or hospitality;

          kickbacks;

          unwarranted allowances or expenses;

          “facilitation payments” (also known as “grease payments”);

          uncompensated use of company services or facilities; or

          an advantage (whether financial or not).

Askable staff must not:

          bribe another person;

          receive a bribe;

          make “facilitation payments”;

          bribe a foreign public official or government entity/official; or

          make, or fail to make, alter, destroy or conceal a document that shows the payment or receipt of a bribe.

Gifts, Hospitality and Promotional Activity

Good faith hospitality and promotional, or other business expenditure which seeks to improve Askable’s image, to better present our products and services, or establish cordial relations, is an important part of our business. This policy does not intend to prohibit reasonable and proportionate hospitality and promotional, or other similar business expenditure intended for these purposes. For example; Askable may from time to time include giveaways, gifts with purchase and prizes, these are part of our regular marketing campaigns that are available to all. This policy does not prohibit such activities.  However, all gifts and hospitality must be for a genuine purpose, reasonable and given in the ordinary course of business.

The giving or receiving of gifts and/or hospitality must be subjected to the following tests:

          Is it made with the intention of influencing, inducing or rewarding a third party in order to gain any advantage through improper performance, or in explicit or implicit exchange for favours or benefits?

          Does it comply with local law?

          Is it part of a broader marketing campaign available and advertised to all.

          Have you disclosed it to your team leader in advance?

          Does it include any cash or cash equivalent (such as shares, gift certificates or vouchers)?

          Is it appropriate in the circumstances?  For example, it may be customary for some Askable businesses to give or receive gifts at Christmas time.

          Taking into account the reason for the gift, is it an appropriate type and value, and is it given at an appropriate time?

          Is it  given openly, not secretly?

What is not acceptable?

It is not acceptable for Askable staff (or someone on behalf of Askable staff) to:

          give, promise to give, or offer a payment, gift or hospitality with the intention of influencing, inducing or rewarding improper performance;

          give, promise to give, or offer a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure (where the payment is not a legitimate payment pursuant to local written law);

          accept a payment from a third party that is known or suspected is offered with the expectation that it will obtain a business advantage for them which will be obtained through improper performance by Askable or Askable staff;

          accept a gift or hospitality from a third party if it is known or suspected that it is offered or provided with the intention of influencing improper performance by Askable or Askable staff in return;

          threaten or retaliate against another employee who has refused to commit bribery or who has raised concerns under this policy; or

          engage in any activity that might lead to a breach of this policy.

Facilitation Payments

Facilitation payments or kickbacks are prohibited under this policy.

Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.

Kickbacks are typically payments made in return for a business favour or advantage.

All staff must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by Askable.

Donations

Askable does not make contributions to political parties, nor does it make donations at the request of government officials. Askable only makes charitable donations that are legal and ethical under the law and practices that are in accordance with our charitable objectives.

Roles and responsibilities

Executive Team – The executive team is responsible for ensuring that Askable operates in an ethical and anti-corrupt manner, in accordance with this policy.  The executive team will promote compliance with, and oversee the implementation of, this policy.

All Staff - All Askable staff and vendors (where applicable) must ensure that they read, understand and comply with this policy.

Any breach of this policy by Askable staff may result in disciplinary action, which could result in jail, penalties, fines, criminal convictions and dismissal. Remember, a bribe does not actually have to take place – just promising to give a bribe or agreeing to receive one is prohibited.

Askable reserves its right to terminate our contractual relationship with Askable staff or any third party if they breach this policy.

Policy review and evaluation

The policy and process will be reviewed by the Director of Operations every [2] years to ensure the practices therein are current and comply with relevant legislation.