Trace Certification ID TC5162-5220
“TRACE has successfully completed a TRACEcertification due diligence review of Milspec Services Pty Ltd. TRACE has issued Milspec Services Pty Ltd a certificate signifying that the company has completed internationally accepted due diligence procedures and has been forthcoming and cooperative during the review process. TRACE certification underscores Milspec Services Pty Ltd’s commitment to transparency in international commercial transactions.”
1 ANTI-BRIBERY POLICY STATEMENT
Bribery is both a criminal offence and bad business. Not only can individuals be guilty of an offence but a company can be prosecuted if it fails to prevent bribery, whether in the AUSTRALIA or overseas.
Without exception, Milspec Services Pty Ltd. acts with integrity in all of its dealings and strictly prohibits bribery and corruption in any form.
Milspec Services Pty Ltd. commits itself to:
(a) conducting its business fairly, honestly, accountably and transparently;
(b) not making, offering or accepting inducements or bribes, whether directly or indirectly, to gain business advantages or for any other
(c) not using a third party as a conduit, whether directly or indirectly, to channel bribes or other inducements to others; and
(d) developing a programme to implement and support these principles.
These are the values by which Milspec Services Pty Ltd. expects its staff to carry out its work on its behalf.
1.1 The meaning of bribery.
Bribery is a reward or an inducement, financial or otherwise, offered, promised or provided to improperly gain personal, commercial, regulatory or contractual advantage. It is unacceptable to:
(a) give, promise to give, or offer a payment, gift, hospitality or other financial advantage with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
(b) give, promise to give or offer a payment, gift, hospitality or other financial advantage to a government official, agent or representative to ‘facilitate’ or expedite a routine procedure;
(c) accept or solicit payment, gift, hospitality or any other financial advantage from a third party that they know or suspect is offered with the expectation that it will obtain a business advantage for them;
(d) accept a payment, gift, hospitality or any other financial advantage from a third party if they know or suspect that it is offered or provided with an expectation that a business advantage will be provided by Milspec Services Pty Ltd. in return;
(e) retaliate against or threaten a person who has refused to commit a bribery offence or who has raised concerns under this policy;
(f) do something that is improper, illegal or a breach of trust in the course of working or doing business; and/or
(g) engage in any other activity that is in breach of this policy.
1.2 Who does this Policy apply to?
Anyone who carries out work on behalf of Milspec Services Pty Ltd. must abide by these rules, including:
(a) GSE Services and Milspec Services NZ Ltd
(b) Directors and employees;
(c) Consultants and sub-contractors
(d) Temporary staff and casual workers or locum staff brought in to cover absent staff.
1.3 Why do we adopt this Policy?
As a private organisation, which is required to be transparent in all of its work, Milspec Services Pty Ltd. is committed to following the principles of integrity, transparency and accountability.
A key part of corporate integrity is complying with all applicable rules.
1.4 What happens if the Policy is violated?
Milspec Services Pty Ltd. staff can be responsible for acts of corruption and bribery committed on its behalf, anywhere in the world, even without the Milspec Services Pty Ltd.’s knowledge.
Milspec Services Pty Ltd. expects all those who are obliged to follow those rules to abide by the following principles:
(a) ensure that they read, understand and comply with this policy;
(b) sign the declaration that confirms the above; and
(c) raise concerns as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur, in the future.
Any violation of this policy by an individual acting on Milspec Services Pty Ltd.’s behalf may result in disciplinary action up to and including summary dismissal for gross misconduct and/or termination of the business relationship.
In addition, staff should note that the penalties for violating the relevant legislation against bribery and corruption are both civil and criminal and include fines and imprisonment for individuals. The penalties for Milspec Services Pty Ltd. may include unlimited fines and significant reputational damage.
1.5 Responsibility for Implementation and Monitoring.
Within Milspec Services Pty Ltd., the responsibility to control the risk of bribery and any other corruption occurring resides at all levels of personnel. It does not rest solely with one director or manager, or within a single department.
If any individual has concerns or questions arising from this policy, it can be addressed to any of the owners/directors in the Milspec Services Pty Ltd.
1.6 Milspec Services Pty Ltd’s Anti-Bribery Principles.
Milspec Services Pty Ltd. expects all those who are obliged to follow these rules to abide by the principles set out below:
(a) to carry out our business with integrity, honestly, accountably and transparently;
(b) to not pay or offer to pay bribes or inducements of any nature, nor to condone the offering of bribes or inducements on our behalf to any third party and, in particular, to public officials, to gain or seek to gain new business or a business advantage.;
(c) to not accept bribes or inducements, and nor will we agree to them being accepted on our behalf in order to influence our work;
(d) If a member of staff becomes aware that any appointed adviser, or business associate, has violated this policy, they should immediately inform the General Manager, Business Development Director or Operations Manager. They will immediately terminate its relationship with that individual or organisation. We will not be associated with any person or organisation that may harm our reputation;
(e) to set out the Milspec Services Pty Ltd.’s processes for avoiding direct or indirect corruption and bribery and abiding by and supporting its values;
(f) the staff will safeguard the organisation and its resources for which they are responsible, and will keep clear records of any gifts, corporate hospitality and donations received and given to a value greater than $100 AUD;
(g) to make sure that everyone working for Milspec Services Pty Ltd. knows and understands its policies and the principles that it has established; and
(h) To regularly review and update these rules and the procedures that are relevant to their implementation.
1.7 Compliance is Mandatory
Milspec Services Pty Ltd. will always ensure that no employee will suffer dismissal, demotion or any other penalty or adverse consequence for refusing to engage in, or for reporting, questionable conduct. This is true, even if Milspec Services Pty Ltd. may suffer as a consequence. Milspec Services Pty Ltd. insists on the strict compliance with this policy by all staff and others to whom this policy applies.
1.8 Facilitation Payments
Many countries do not make a distinction between facilitation payments and bribery. Facilitation payments are small payments made directly or indirectly to secure or speed up the performance of a routine action or to avoid bureaucratic delays, for example, the issuing of permits by public officials or for goods to clear customs.
Milspec Services Pty Ltd. will not tolerate facilitation payments, because they are illegal.
2 GIFTS AND HOSPITALITY POLICY
Because bribes and inducements can sometimes be disguised as gifts, or gifts can sometimes be misinterpreted as bribes, Milspec Services Pty Ltd. must ensure that giving or receiving gifts cannot distort its business relationships, create a conflict of interest or be otherwise construed as an inducement. A conflict of interest may also arise by the giving or receiving of favours or special treatment to which no financial value can be attached. Such special treatments generally encourage a ‘payback’ expectation and can distort a professional relationship.
(a) Staff should not accept gifts or any other consideration of a value greater than $100AUD from any person having business with Milspec Services Pty Ltd. without having first obtained permission. Discretion should always be exercised in accepting hospitality. Excessively generous hospitality, however innocently offered, is always liable to misinterpretation.
(b) Sample tokens of modest value bearing the name or insignia of the organisation giving them (for example, pens, diaries or calendars), whether given personally, or received in the post, may be retained unless they could be regarded as an inducement or reward.
(c) If staff are invited to attend a meeting, present a speech or submit a written article, all speaking fees, article fees and honoraria should be paid over to the Milspec Services Pty Ltd.
(d) If staff are invited to speak or attend a commercial conference that has been organised for profit, they must seek their manager’s prior agreement
2.1 Gift Reporting
Details of any gifts, corporate hospitality and donations received, in excess of value of $100AUD, other than branded goods, must be notified to the General Manager on a monthly basis.
2.2 Charitable Contributions and Requests
Milspec Services Pty Ltd. and its staff must be vigilant to ensure that any charitable contribution or bequest is not used as a means of concealing or disguising bribery.
Milspec Services Pty Ltd. does not regularly make charitable donations to organisations. However, should Milspec Services Pty Ltd. deem it necessary to make a payment to a charitable organisation or educational fund, only the Directors are permitted to make such a decision. A donation or payment must never be made in order to gain favour or influence.
2.3 Raising a Concern
Milspec Services Pty Ltd. is committed to ensuring that all individuals have a safe, reliable and confidential way of reporting any suspicious activity.
If staff have a concern about a suspected instance of bribery or corruption, they should speak up—their information and assistance will help. The sooner they act, the sooner it can be resolved.
Concerns can be raised anonymously. In the event that an incident of bribery, corruption or wrongdoing is reported, Milspec Services Pty Ltd. will act as soon as possible to evaluate the situation.
Staff who refuse to accept or offer a bribe, or those who raise concerns or report wrongdoing, may be worried about the repercussions. We encourage openness and will support anyone who raises a genuine concern in good faith under this policy, even if they turn out to be mistaken.
Milspec Services Pty Ltd. is committed to ensuring nobody suffers detrimental treatment through refusing to take part in bribery or corruption or because of reporting a concern in good faith. If staff have any questions about these procedures, they should contact the General Manager or Business development Director.