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Anti Bribery and Corruption Policy


1.  This policy sets out Durolenz’s requirements in relation to managing Bribery and Corruption risks and compliance with relevant laws.  It is important because Bribery and Corruption impacts our stakeholders, our financial position, and our reputation.  It supports Durolenz’s purpose and strategy by prohibiting Bribery and Corruption and providing clear requirements on the management of Bribery and Corruption risks. 

2. This Policy is designed to: 


a.  Provide clear rules in relation to Durolenz’s anti-Bribery and Corruption requirements, including the prohibition of facilitation payments and requiring the accurate maintenance of records. 

b.  Ensure Bribery and Corruption risks are appropriately identified and managed; and 

c.  Ensure Durolenz meets its legal requirements.

Who this applies to and when

3.  This Policy applies to everyone who works for Durolenz. This includes all employees, contractors, and directors of Durolenz. 

4.  It applies whenever you act for or on behalf of Durolenz.


Bribery and Corruption are prohibited

5.  You must not engage in, ignore, condone, or otherwise tolerate any attempt to commit any act of Bribery or Corruption. 

6.  The prohibition of Bribery and Corruption under this Policy includes the offer of, provision or conveying of, anything of value to any third party, customer, Official or candidate for public office, or their family members, or other personnel, whether directly or indirectly, to improperly influence or to secure any improper advantage (personal or business). 

7.  You must not solicit or accept money or anything of value that may improperly influence or be seen to improperly influence your decision making.

Compliance with the law

8.  You must comply with domestic and applicable foreign laws relating to Bribery and Corruption. 

9.  If applicable local or extra territorial laws, codes of conduct, or regulations are more restrictive than this Policy or Australian laws, then you must comply with the more restrictive requirements. 

Facilitation payments are prohibited

10.  You must not offer or make a Facilitation Payment, of any kind, regardless of the provisions of applicable law. 

11.  The exception is if a Facilitation Payment is necessary to prevent a perceived or actual immediate danger to your, or another individual’s personal safety.   You must report any Facilitation Payment in writing as soon as practicable but no later than 24 hours after the incident occurred to the Managing Director.

Gifts, benefits, and hospitality

12.  You must not offer, give, or accept Gifts, Benefits, or Hospitality, including entertainment:

​a.  With the intent or prospect of influencing decision-making or other conduct.

b.  With the intent to obtain any improper or undue advantage.

c.  Which are reasonably capable of being regarded in any way as a bribe.

Accurate Record Keeping

13.  Keep accurate and complete records of all business transactions:

a.  In accordance with applicable laws and generally accepted standards, principles and practices; 

b.  In accordance with relevant policies; and 

c.  In a manner that reasonably reflects the underlying transactions and events. 

Speaking up and reporting

14. We are each responsible for ensuring that we meet our commitments. Durolenz expects its employees and contractors to speak openly and raise concerns about possible breaches of the Employee Code of Conduct and this policy with their manager or supervisor.


15. Durolenz takes breaches of our policies seriously.  Depending on the severity of the breach, consequences may range from a warning, termination of employment or Durolenz ending its business relationship with you.


“Bribery” means the providing, offering, accepting, promising or soliciting of a benefit, or causing the provision, offering, accepting, promising or solicitation of a benefit to, another person, to whom the benefit is not legitimately due, with the intention of improperly influencing a person in order to obtain or retain business, or obtain and retain a personal or business advantage, which is not legitimately due.

“Corruption” (including corrupt conduct or behaviour) means any act or omission for an improper or unlawful purpose, which involves the misuse or abuse of position or a position of trust, to achieve a personal gain, or to influence an outcome, or advantage for themselves or for another person or entity.

“Gift, Benefit or Hospitality” means any item or anything of value that is exchanged, or otherwise provided, offered, promised or solicited. This may include, but is not limited to, cash, travel, entertainment and meals, any of which may be tangible or intangible.

“Facilitation Payment” means a payment or other inducement made to a person or persons with the intention of securing or expediting a routine duty or action or facilitating approval of some type of business transaction or activity outside of the official channels.

“Official” means a person who, regardless of rank or title, is: 

  • engaged in public duty (whether elected or appointed) in a government agency (including national, state/territory or local government agencies); 

  • a member of or candidate for any legislative, administrative, or judicial body; 

  • an employee of a government-owned or government-controlled entity, including state-owned entities that operate in the commercial sector; or 

  • acting in an official capacity for a government, government agency, or state-owned enterprise.

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