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Anti-Bribery and Anti-Corruption Policy

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PURPOSE

CTI is committed to conducting business ethically and responsibly. This policy establishes controls to ensure compliance with anti-bribery and corruption laws and to safeguard our reputation.

POLICY STATEMENT

Bribery involves offering, giving, receiving, or soliciting anything of value to improperly influence actions. CTI adopts a zero-tolerance approach to bribery and corruption. We act with integrity in all dealings and comply with applicable laws, including the Australian Criminal Code Act 1995, UK Bribery Act 2010, and U.S. Foreign Corrupt Practices Act.

CTI has a “zero tolerance” approach to acts of bribery and corruption and breaches may result in disciplinary action, termination, and referral to law enforcement.

SCOPE

This policy applies to all CTI employees, contractors, consultants, and associated parties worldwide. It governs interactions with clients, suppliers, business partners, and public officials.

KEY PRINCIPLES

  • Bribery and Corruption: Employees must not engage in bribery or corruption, directly or indirectly.
  • Gifts and Hospitality:
    • Do not solicit gifts.
    • Cash gifts are prohibited.
    • Modest hospitality may be accepted if it does not create obligation or influence decisions.
    • Gifts over $100 require director approval; gifts from non-trading entities are prohibited.
    • All offers (accepted or declined) must be reported.
  • Giving Gifts: Token gestures under $100 require prior approval. Gifts to non-trading entities are prohibited.
  • Facilitation Payments: Strictly prohibited except in cases of personal safety. Any payment must be minimal, documented, and reported.
  • Political and Charitable Contributions:
    • Political donations are prohibited.
    • Charitable donations must be legal, ethical, approved by a director, and publicly disclosed.

 Responsibilities

Employees must read, understand, and comply with this policy. Report any suspected breaches immediately to your manager or the executive committee.

Record Keeping

Maintain accurate financial records and declare all gifts or hospitality. Off-book accounts are prohibited.

Raising Concerns

Report unethical conduct promptly. Refer to the Whistleblower Policy (POL-0049) and Raising a Concern about Business Conduct procedure (PRC-0054).

Protection

CTI supports employees who refuse bribes or report concerns in good faith. Retaliation will not be tolerated.

Training and Communication

All employees receive training on this policy. Our zero-tolerance stance is communicated to suppliers and partners.

Governance

The Board oversees compliance and reviews effectiveness. Management ensures awareness and training. Regular audits will monitor adherence.