Introduction

We value integrity and hold the high business ethical standards in all of our conduct and value a society that is free from corruption and anti-competitive behaviour.

Plotlogic has a zero tolerance to bribery and corruption, and is committed to ensuring that all employees, Directors, trainees, work experience students and contractors (Team Members) behave in a lawful, ethical and professional way.

Purpose

The purpose of this Policy is to set out Plotlogic’s approach to bribery and corruption, and to better enable Team Members to prevent, detect and respond to bribery and corruption risks.

Scope

This policy applies to all Team Members of Plotlogic.

Plotlogic refers to Plotlogic Pty Limited (ACN 115 988 308) trading as Plotlogic and the related bodies corporate of those entities.

This Policy covers any activity or behaviour undertaken during the course of, or in connection with, employment or engagement with, or acting on behalf of, Plotlogic, regardless of the geographical location in which that activity or behaviour occurs.

For any parts of Plotlogic that are impacted by foreign or local laws, regulatory requirements or contractual obligations that conflict with this Policy, Plotlogic and all Team Members must comply with the more stringent standard and ensure that local laws are not contravened.

For the sake of clarity, “Plotlogic’s environments” include means any physical or virtual place made available or authorised by Plotlogic for official use in connection with Plotlogic’s activities, including:

• Plotlogic’s offices (and any offsite locations used in Plotlogic’s activities); and
• where applicable, online environments (including Plotlogic’s website, email, LinkedIn profile and Facebook profile etc.).

Definitions

“Bribery” means the offer, promise, giving, requesting, authorising or receiving of anything of value (whether a financial or other advantage) directly or indirectly to another person(s) with the intention of influencing or rewarding improper performance. It can include “active bribery” (i.e. a person offers or gives something of value to influence performance or obtain an unfair advantage for themselves or another) or “passive bribery” (i.e. a person receives, attempts to receive, or requests something of value in exchange for improper performance).

“Corruption” means an act or omission for an improper or unlawful purpose, which involves the abuse of a position of trust or power.

“Facilitation payment” means a payment of minor value paid to a public official via unofficial channels to expedite or secure the performance of a routine government action of a minor nature.

Core principles

This Policy has been designed to deter wrongdoing and to promote all Team Members to comply with their obligations to:

• act lawfully, ethically and in the public interest;
• not tolerate behaviour within Plotlogic, Plotlogic’s clients or suppliers, or public officials with whom Plotlogic deals with, that is illegal, unethical or breaches human rights (including modern slavery);
• not accept or offer bribes or participate in corrupt practices. Plotlogic has a zero tolerance for bribery and corruption in any form by any party; and
• follow high standards of ethical conduct around the world, including aspiring to the ten principles of the UN Global Compact (including anti-bribery).

Responsibilities

Team Members are expected to act and perform their duties ethically and honestly, and with the utmost integrity.
Team Members must:

NB: Other political related expenditure, such as sponsorships, memberships, payments to attend political events, and gifts or entertainment to be given to political stakeholders or senior government officials, must undergo appropriate approvals and conform with relevant policies, standards and procedures (including this Policy);

• ensure they do not aid, abet or encourage other persons to engage in the conduct above (or any other unlawful or inappropriate conduct);
• be aware of and respond to bribery and corruption risks and incidents;
• follow the complaint procedure in this Policy if they experience or see any instances of bribery or corruption;
• report any bribery or corruption concerns in Plotlogic’s environments in accordance with the complaint procedure in this Policy; and
• maintain confidentiality as far as possible if they are involved in the complaint procedure.

The CEO must:

• ensure all Team Members understand and are committed to the principles contained in this Policy and applying it in Plotlogic’s environments;
• ensure Plotlogic has a culture that does not tolerate bribery and corruption;
• take all complaints regarding bribery and corruption seriously, and treat all complaints as confidential as far as possible;
• set an example by their own behaviour;
• immediately and appropriately take steps to minimise or eliminate bribery and corruption in Plotlogic’s environments; and
• ensure ongoing support and guidance is provided to all Team Members in relation to anti-bribery and corruption principles and practice in the workplace.

Transparency and record keeping

Plotlogic maintains transparency by ensuring appropriate records will be kept in relation to any:

• gifts and entertainment;
• political donations and lobbying;
• conflicts of interest;
• corporate expenses and reimbursements;
• employee due diligence and recruitment; and
• donations and sponsorships.

Plotlogic ensures appropriate records of financial and non-financial controls are maintained, and ensure that they are accurate and protected against improper use or loss of integrity.

Awareness

Plotlogic ensures that all Team Members are:

• aware of Plotlogic’s zero tolerance to bribery and corruption; and
• regularly reminded of their obligations under this Policy.

Compliance

It is the personal responsibility of each Team Member to adhere to the standards and restrictions imposed by all applicable laws and obligations relating to bribery and corruption.

Any Team Member who is unsure whether a situation violates any applicable legislation, Plotlogic’s practice or this Policy should discuss the situation with their managers, the Vice President – People and Culture or the CEO.

Internal reporting

Team Members must report all concerns in relation to bribery and corruption at the earliest opportunity to the Vice President – People and Culture and CEO. This includes if Team Members are offered a bribe, are asked to make a bribe, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.

Plotlogic will not retaliate or tolerate retaliation or victimisation for reports of this nature made in good faith. If a Team Member has concerns about their own wellbeing, treatment at work or career prospects as a result of reporting a concern, they should tell the Vice President – People and Culture and CEO as soon as possible so that appropriate supports and protections can be put in place.

Breach of this Policy

Any breach of this Policy by a Team Member may result in counselling and/or disciplinary action, including up to termination of employment or cessation of engagement without notice in accordance with PC11: Discipline, Performance Management & Termination Policy.

Team Members must also acknowledge that a breach of this Policy may also constitute a breach of applicable legislation, which could result in personal legal or regulatory action (including criminal action and penalties) and / or legal or regulatory actions against Plotlogic, significant reputational damage and substantial financial loss.

Review

This document will be reviewed every two years or more frequently, if required, by the CEO and Vice President – People and Culture to ensure continued compliance.