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Anti-Bribery and Corruption (ABAC)
Version: 1.0
Number: POL01
Effective date: 15 November 2012
Page 2 (7)
The contents of this document are confidential. Unauthorised use, disclosure or reproduction without prior
written permission from TFS is prohibited.
CONTENTS 1. Purpose ........................................................................................................................ 3 2. Scope ........................................................................................................................... 3 3. Definitions ..................................................................................................................... 3 4. Policy statement ........................................................................................................... 3 5. Key principles of anti bribery and corruption ................................................................ 4 6. Responsibilities ............................................................................................................. 4 6.1 The Board of Directors and the CEO ............................................................................ 4 6.2 The Financial Department ............................................................................................ 4 6.3 The Financial Department ............................................................................................ 5 6.4 The Quality Assurance Department ............................................................................. 5 6.5 All TFS Employees ....................................................................................................... 5 6.6 TFS Employees ............................................................................................................ 5 7. Record keeping ............................................................................................................ 6 8. Training ......................................................................................................................... 6
Anti-Bribery and Corruption (ABAC)
Version: 1.0
Number: POL01
Effective date: 15 November 2012
Page 3 (7)
The contents of this document are confidential. Unauthorised use, disclosure or reproduction without prior
written permission from TFS is prohibited.
1. PURPOSE The purpose of this policy is to ensure that all TFS interactions with third parties are carried out in compliance with relevant laws and regulations with the highest standards of integrity in an ethical, lawful and professional manner and to inform employees that corrupt practices are not acceptable in TFS business conduct.
2. SCOPE This Policy applies to all permanent and temporary employees of TFS, the Chief Executive Officer (CEO) and the Board of Directors. It also applies to any individual or corporate entity associated with TFS or who performs functions in relation to, for, or on behalf of, TFS, including, but not limited to, directors, agency workers, casual workers, contractors, consultants, seconded staff, agents and suppliers (“associated persons”). All employees and associated persons are expected to adhere to the principles set out in this Policy.
3. DEFINITIONS Bribery is the giving, offering or receipt of something of value (eg a loan, payment, or other reward) for the purpose of influencing a person to do something which is dishonest, illegal or a breach of trust, in the conduct of TFS business. Bribery is not limited to financial reward, but can include other “gifts” such as tickets, travel and entertainment where these would be considered excessive and unwarranted. The provision of undue rewards to persons other than the individual themselves (such as a family member) would also be included within the scope of this policy. Corruption is dishonest or fraudulent conduct by those in power typically, though not exclusively, bribery. Associated Person is any individual associated with TFS or who performs functions in relation to, for, or on behalf of TFS, including, but not limited to, directors, agency workers, casual workers, contractors, consultants, seconded staff, agents and suppliers.
4. POLICY STATEMENT All employees and associated persons are required to:
Anti-Bribery and Corruption (ABAC)
Version: 1.0
Number: POL01
Effective date: 15 November 2012
Page 4 (7)
The contents of this document are confidential. Unauthorised use, disclosure or reproduction without prior
written permission from TFS is prohibited.
• Comply with any anti-bribery and anti-corruption legislation that applies in any jurisdiction in any part of the world in which they conduct business
• Act honestly, responsibly and with integrity • Safeguard and uphold TFS core values by operating in an ethical, professional and
lawful manner at all times
5. KEY PRINCIPLES OF ANTI BRIBERY AND CORRUPTION
• Do not offer or accept bribes TFS prohibit the offering, accepting or demanding of improper payments or other
rewards • Document all financial issues Financial Documentation kept by all individuals should be accurate and complete. • Monitor financial records Financial records should be subject to approval and scrutiny by every employee’s line
manager, and above a certain level appropriate checks need to be conducted by the manager’s manager
There should be periodic financial audits to identify any areas of non-compliance with this policy
• Report concerns of bribery Everyone at TFS has an obligation to comply with this policy. If you suspect
inappropriate behaviour by any individual within TFS or with third parties, you have an obligation to report your concerns at the earliest possible opportunity to the Chief Financial Officer (CFO) or the Director Global Quality Assurance.
6. RESPONSIBILITIES
6.1 The Board of Directors and the CEO Will:
• Act to discourage bribery by persons associated with them, both within and outside TFS
• Foster a culture within TFS in which bribery is seen to be unacceptable
6.2 The Financial Department Will:
• Keep appropriate records that demonstrate the reasons for any payments made to employees, associated persons and third parties
• Monitor and review procedures designed to prevent bribery and corruption • Audit financial records to investigate any potential bribery or corruption • Encourage employees to raise concerns about any suspicion of bribery at the earliest
stage, and provide a system for doing this that ensures that anyone raising such concerns will not suffer any detriment as a result, even if they turn out to be mistaken
Anti-Bribery and Corruption (ABAC)
Version: 1.0
Number: POL01
Effective date: 15 November 2012
Page 5 (7)
The contents of this document are confidential. Unauthorised use, disclosure or reproduction without prior
written permission from TFS is prohibited.
• Report to/liaise with the CFO and QA department about any reports of bribery or corruption
6.3 The Financial Department Will not:
• Make significant contributions of any kind to any third party with the purpose of gaining and commercial advantage for TFS
• Accept any contributions made with the purpose of influencing the conduct of TFS business
6.4 The Quality Assurance Department Will:
• Monitor and review procedures designed to prevent bribery and corruption • Report to/liaise with Financial department about any reports of bribery or corruption • Keep a record of all cases of bribery reported, including any actions taken. This
record should include cases where no wrong doing is found
6.5 All TFS Employees Will:
• Take whatever reasonable steps are necessary to ensure compliance with this Policy • Prevent/discourage bribery wherever possible • Report any suspected bribery or corruption at the earliest possible time to the QA
Department and/or the CFO, reporting any knowledge or suspicion they may have that any employee, has plans to offer, promise or give a bribe or to request, agree to receive or accept a bribe in connection with the business of TFS
6.6 TFS Employees Will not:
• Accept any financial or other reward from any person or organisation in return for providing favourable treatment in any way
• Request any financial or other reward from any person or organisation in return for providing favourable treatment in any way
• Offer any financial or other reward from any person or organisation in return for receiving favourable treatment in any way
Anti-Bribery and Corruption (ABAC)
Version: 1.0
Number: POL01
Effective date: 15 November 2012
Page 6 (7)
The contents of this document are confidential. Unauthorised use, disclosure or reproduction without prior
written permission from TFS is prohibited.
7. RECORD KEEPING All accounts, receipts, invoices and other documents and records relating to dealings with third parties must be kept. No accounts must be kept “off the record” to facilitate or conceal improper payments which may constitute bribery or corruption.
8. TRAINING TFS will provide training to all employees to help them understand their duties and responsibilities under this Policy. The TFS zero tolerance approach to bribery will be communicated to all business partners at the outset of the business relationship with them and as appropriate thereafter.
Anti-Bribery and Corruption (ABAC)
Version: 1.0
Number: POL01
Effective date: 15 November 2012
Page 7 (7)
The contents of this document are confidential. Unauthorised use, disclosure or reproduction without prior
written permission from TFS is prohibited.
Document History
Version No Effective Date Brief Description of Change
01 15 November 2012 New policy