Anti Corruption

Anti-Bribery and Corruption Policy

1.     INTRODUCTION AND PURPOSE

Computer Alliance is committed to conducting business in an honest and ethical manner.  We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, and with integrity in all our relationships with customers, suppliers, and all other stakeholders. 

This policy is developed and implemented in order to provide clarity for our staff involved with business relationships and to reduce the risk of improper activity or a breach of applicable laws.  Our intent is to implement effective systems to counter bribery and corruption and maintain a culture that is resistant to corruption.

2.     DEFINITIONS

Bribery: an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

Facilitation payments: unofficial payments made to secure or expedite a routine government action by a government official.

Kickbacks: payments made in return for a business favor or advantage that relates to a particular transaction.

Gifts: something voluntarily transferred by one person to another without expectation of compensation.  Gifts related to corrupt activities may be used as a screen where personal or organizational advantage may be sought.

Charitable Donation: a gift made by an individual or an organization to a nonprofit organization, charity or private foundation.

Money Laundering: the act of disguising the source or true nature of money obtained through illegal means

3.     SCOPE

This policy applies to all Computer Alliance Staff and relationships between staff and all external organizations including customer, suppliers, regulatory authorities, and other stakeholders.

This policy considers actions that may relate to corruption or bribery and highlights areas of risk such as gifting, donations, kickbacks, financial transactions that may facility money laundering, and other transactions where there is potential for normal business relationships to transform into corrupt activity.

4.     RESPONSIBILITIES, REPORTING, AND COMMUNICATION

The Managing Director and General Manager are responsible for the development and oversight of this policy and to ensure a culture resistant to corruption is maintained and developed at Computer Alliance.

The Financial Controller is responsible for monitoring all transactions with an expectation to question any payments or transactions that indicate a breach of this policy.

The training of this policy forms part of the induction process for new employees.  The Human Resources Manager is responsible for ensuring training is completed as part of the induction process. 

All staff must ensure that they have read, understood, and agree to comply with this policy.

All staff members are responsible for the success of this policy and if they believe they have witnessed a possible breach of this policy, they should directly communicate their concerns to their immediate supervisor, or at their discretion should approach the Managing Director, or General Manager with their concerns.

Computer Alliance believe that an important tool to avoid corruption is the open communication of all business relationships within our organization, particularly when gifts or payments in any form are involved. 

Where any payments or gifts are given or received between business partners and staff, the nature of the transaction should be communicated to supervisors or senior staff who are not directly involved in the transaction.  This communication will reduce the risk that the transaction might be seem as inappropriate or potentially lead to corrupt activity.

5.     CONSEQUENCES OF BREACHING THIS POLICY

Bribery and the related improper conduct addressed by this Policy are very serious offences.

A breach of this policy by a Computer Alliance staff member will be considered serious misconduct and lead to disciplinary action which may include termination of employment. 

If an employee’s conduct is believed to have resulted in Computer Alliance or a staff member to be in breach of any applicable law, then the Managing Director will report the breach to the appropriate authority and any impacted stakeholders.

6.     FACILITATION PAYMENT AND KICKBACKS

We do not make, and will not accept, facilitation payments or "kickbacks" of any kind.

All representatives must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

All staff members who make payments on our behalf must be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. A receipt which details the reason for the payment should be obtained.

The Financial Controller will monitor or payments and question any transactions where reasons for a payment is unclear.

7.     GIFTS AND HOSPITALITY

Personnel must not offer or give any gift or hospitality which could be regarded as illegal or improper, or which violates the recipient’s policies.

Gifts of money are not generally acceptable and may only be accepted if authorized by the Managing Director.

Occasionally, a customer may offer a staff member an unsolicited gift in response to exceptional service.  A small gift unrelated to any expectation of future benefit may be acceptable however, the staff member must report the gift to their supervisor who will assess whether the gift is appropriate.  If the gift seems excessive or its intent uncertain, it should be declined. 

No staff member may solicit a gift for service and doing so would be a breach of this policy.

Occasionally, a customer may offer equipment they no longer require, but still has some value, to a member of staff.  This may occur in the service department where, for example, work may have shown the equipment not worth fully repairing or upgrading.  In these situations that member of staff must seek authorization from their supervisor or a senior staff member to accept any gift.  If the equipment retains substantial value, it will be declined.  If a staff member is ever found to have modified the outcome of work with the intent to solicit a gift of the related equipment, such an action would be considered a serious breach of this policy.

8.     CHARITABLE CONTRIBUTIONS

From time to time, Computer Alliance may choose to assist external organizations with charitable support in the form of cash, equipment, or time and expertise.

Staff must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery and all company donations must be authorized by the Managing Director.

9.     REFUNDS - MONEY LAUNDERING AND FRAUD

Where a refund for a purchase is provided, that refund should be made in the same form and to the same account that the payment was originally paid from.  Particularly, when a payment is made from a credit card, PayPal, a bank account, or other account, and refund should be made to the same account.

This policy reduces the risk that the refund may be received by a different party.  For example, if a customer’s employee returns company property we must ensure that the company receives the refund, not the employee.

Where a refund by the same method and account is not possible, then the staff member issuing the refund must consult with a manager authorized to make decisions related to refunds, such as the Financial Controller or senior staff, and gain approval to refund by a different means. 

Whatever means is approved for a refund must allow for a reasonable identification of the person receiving the payment.

Any staff member found to knowingly facilitate a refund to an inappropriate person is in breach of this policy.

10.  MONITORING AND REVIEW

The Managing Director will review this policy annually and consult with senior staff concerning any changes or additions.

Auditing related to this policy is integrated into company processes and procedures, particularly those related to the management and monitoring of financial transactions.