Anti-Corruption and Bribery Policy

Austinsure’s Anti-Corruption and Bribery Policy

It is Austinsure’s policy to conduct all of its business in an honest and ethical manner. Austinsure takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all business dealings and relationships wherever Austinsure operates.

The purpose of this policy is to:

  • set out Austinsure’s responsibilities, of those working for Austinsure, customers and suppliers in observing and upholding Austinsure’s position on bribery and corruption; and
  • provide information and guidance to those working for Austinsure on how to recognise and deal with bribery and corruption issues in order to ensure that Austinsure, and those working for Austinsure, comply with all applicable legal obligations.

In this policy, ‘third party’ means any individual or organisation Austinsure comes into contact with and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

Bribery and corruption are criminal offences in New Zealand and many other jurisdictions. Austinsure is bound by laws, including the Crimes Act and global anti-corruption instruments that New Zealand is a signatory to.

What is bribery?
The offer, promise or giving of anything of value in order to improperly influence a person’s actions or decisions to gain or retain a business benefit. Bribery and corruption can take many forms including, the provision or acceptance of cash payments, facilitation payments, kickbacks, political contributions, charitable contributions, social benefits, gifts, travel, hospitality and rebates or

No individual shall, either directly or indirectly through third parties:

  • Offer, promise or give to; or
  • Seek, accept, request or agree to receive a financial or other advantage from a customer, supplier or any other third party with the intention of inducing or rewarding them to secure an improper business benefit.

Bribery of public officials of any country, as well as companies and private individuals is equally
prohibited under the laws of many countries and under this Policy.


Offering a bribe

Offering a potential client tickets to a major sporting event, but only if they agree to do business
with Austinsure.

This would be an offence as you are making the offer to gain a commercial and contractual advantage. Austinsure may also be found to have committed an offence because the offer has been made to obtain business for Austinsure. It may also be an offence for the potential client or supplier to accept the offer.

Receiving a bribe
A supplier gives your nephew a job, but makes it clear that in return they expect you to use your influence in Austinsure to ensure that it continues to do business with them.

It is an offence for a supplier to make such an offer. It would be an offence for you to accept the
offer as you would be doing so to gain a personal advantage.

Bribing a foreign official
You arrange for Austinsure to pay an additional payment to a foreign official to speed up an administrative process.

The offence of bribing a foreign public official has been committed as soon as the offer is made. This is because it is made to gain a business advantage for us. Austinsure may also be found to have committed an offence.

Political Donations and Charitable donations

Political donations shall not be made to political parties, candidates, or to any political cause or election fund in or for Austinsure’s name. The only valid exception is where a donation has been expressly approved by the Board. Charitable donations shall not be made for purposes of gaining commercial advantage.

Gifts and hospitality
This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties.

The giving or receipt of gifts is not prohibited, if the following requirements are met:

  • it complies with local law;
  • it does not include cash or a cash equivalent (such as gift certificates or vouchers);
  • it is appropriate in the circumstances. For example, small gifts to be given or received at Christmas time;
  • taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time; and
  • it is given openly, not secretly.

We appreciate that the market practice of giving business gifts varies. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.

What is not acceptable?

It is not acceptable for you (or someone on your behalf) to:

  • Give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope  that a business advantage will be received, or to reward a business advantage already given.
  • Give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure.
  • Request, agree to receive, or accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them.
  • Request, agree to receive, or accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided in return.
  • Threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy.
  • Engage in any activity that might lead to a breach of this policy.

Your Responsibilities

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify a senior member of Austinsure as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a client or potential client offers something to gain a business advantage, an Austinsure employee offers something to gain you as a client, or indicates that a gift or payment is required to secure

Any employee who breaches this policy will face disciplinary action, which could result in summary dismissal for gross misconduct. Austinsure also reserves its right to terminate any contractual relationship with non-employees if they breach this policy.

Record keeping
All employees must detail and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.

All employees must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with the usual expenses procedure and specifically record the reason for the expenditure.

All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.

How to raise a concern

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with a senior member of Austinsure.

It is important that you tell a senior member of Austinsure as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.


Anyone who refuses to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. Austinsure encourages openness and will support anyone who raises genuine concerns in good faith.

Austinsure is committed to ensuring that no-one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform a senior member of staff, or if you are a customer or supplier: [email protected].