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Anti-corruption framework

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.

Policy / procedure


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

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

We perform a risk assessment for potential and existing suppliers to Export Finance Australia

Public Interest Disclosure Policy and Procedure 

Provides mechanisms for ‘public officials’ as defined under the Public Interest Disclosure Act 2013 (Act) 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

Includes a gifts and entertainment policy that defines the circumstances in which it is appropriate for our staff to give and receive gifts and entertainment, and sets out a system for the disclosure and monitoring of such decisions

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

We review our anti-corruption framework on an ongoing basis to ensure it remains relevant and effective.

OECD Anti-bribery Recommendation

As a member of the OECD Working Party on Export Credits and Credit Guarantees, we comply with the OCED Council Recommendation on Bribery and Officially Supported Export Credits. The OECD Anti-Bribery Recommendation outlines measures to be taken by members and adherents to deter and combat bribery in connection with officially supported export credits. We go beyond these obligations by applying key measures to a broader range of products.

One of our obligations under the OECD Anti-Bribery Recommendation is to raise awareness among our clients of the legal consequences of engaging in bribery in international business transactions. Bribing a foreign or domestic public official is a serious criminal offence that carries heavy penalties. 

The Australian Government has in place a foreign bribery online learning module. To access the module, and for more information, visit the Attorney-General’s Department website.