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1. Anti-corruption Initiatives

Our comprehensive framework of anti-corruption policies and procedures promotes an active understanding of our anti-corruption obligations.

Our anti-corruption initiatives are designed to ensure we do not support transactions involving bribery or corruption.

Policy, Procedure or Document


Anti-Corruption Policy

Sets out our staff’s principal obligations in deterring and preventing bribery and corruption.

Transactional Anti-Bribery Procedures

Sets out the procedures that our staff need to follow so that we comply with our obligations under the OECD Council Recommendation on Bribery and Officially Supported Export Credits, and to deter bribery in international business transactions.

Transaction Documentation

We require certain anti-bribery and corruption provisions in our financing transaction documentation.

Anti-Money Laundering and Counter Terrorism Financing (AML/CTF) Program

This program is designed to ensure that we can detect and prevent money laundering and terrorism financing. From a transactional perspective, it requires detailed due diligence of each new transaction, including a ‘know your customer’ review in accordance with AML/CTF laws. We conduct ongoing customer due diligence. The program also provides a framework for identifying and reporting suspicious activities to AUSTRAC.

Fraud Control Policy and Plan

Sets out our fraud risk assessment, controls for minimising and preventing fraud and procedures for detecting and dealing with fraud.

Incident Reporting Policy

Establishes an internal reporting process for staff members to report incidents.

Procurement and Contracts Governance Policy

This policy sets out how we procure and manage third parties across the engagement lifecycle in accordance with the core principles of the Commonwealth Procurement Rules. We complete a risk assessment for all new suppliers with respect to our procurement.

Public Interest Disclosure (Whistleblower) Policy and Procedure

Provides mechanisms for ‘public officials’ as defined under the Public Interest Disclosure Act 2013 (Cth) to report conduct engaged in by an agency, public official or contracted service provider in connection with a Commonwealth contract that involves alleged wrongdoing or illegal or improper conduct.

Code of Conduct and Gifts and Benefits Policy

Our Gifts and Benefits policy contains our policy on staff giving and receiving gifts and benefits. It provides a process around the disclosure, approval and recording of gifts and benefits, and including a framework for public reporting.

Compliance Training

We have a mandatory ongoing training program for our staff, which includes anti-corruption, fraud awareness, anti-money laundering and counter-terrorism financing training from time to time.

Modern Slavery Policy


This policy describes the application of appropriate management control systems to detect and prevent Modern Slavery and provides guidance to staff on how to raise a concern. It also covers how to deal with suspicions, allegations and reports of Modern Slavery received or identified about our customers, operations and supply chain.

See our Modern Slavery Initiatives.

We review our anti-corruption initiatives on an ongoing basis to ensure they remain relevant and effective.

2. Combatting Bribery and Corruption - Consequences of Bribery under Laws

Australian Laws

OECD countries, including Australia, are committed to combatting bribery and corruption, including in accordance with the OECD Council Recommendation on Bribery and Officially Supported Export Credits. We also go beyond these obligations by applying key measures to a broader range of products.

The Crimes Legislation Amendment (Combatting Corporate Crime) Bill 2019 (Cth) is set to further strengthen Australia’s laws in this regard. This will include a new corporate offence, under which Australian companies and entities will be held criminally liable for bribery engaged in by third party associates (such as officers, employees, agents, representatives, contractors, subsidiaries and JV partners) unless the Australian entity can establish they had ‘adequate procedures’ in place.

It is your responsibility to comply with all laws that are relevant to your export transactions; however, we draw your attention to the applicable law on bribery and corruption contained in the Criminal Code Act 1995 (Cth). In particular, bribery of domestic or foreign public officials (both defined broadly) are serious criminal offences that carry heavy penalties including up to ten years imprisonment and fines which can be up to the highest of $21 million, three times the value of the benefit obtained, or 10% of annual turnover in the year the offence was committed.  Certain acts committed abroad constitute criminal offences in Australia. The Criminal Code Act also contains offences linked to the proceeds and instruments of crime (funds generated by, or used to conduct, an illegal activity), which also attracts significant penalties.

It is also your responsibility to comply with other applicable laws in Australia, including:


  • State and Territory laws which apply to other forms of bribery within the private sector. For example, in the State of NSW, this is governed by the Crimes Act 1900 (NSW);
  • the Corporations Act 2001 (Cth) which imposes duties of good faith on directors and officers of corporations, and prohibits them from improperly using information or their position to gain an advantage for themselves or a third party; and
  • the Competition and Consumer Act 2010 (Cth) which prohibits certain kinds of conduct.

International Laws

When involved in international business transactions, you will also need to familiarise yourself, and comply, with all relevant laws and regulations prohibiting bribery in the country or jurisdiction where you are conducting business.

Further Information

We strongly encourage you to view the following resources for further information: