Who it applies to
This policy applies to the directors, employees and contractors of Cactive Pty Ltd, and to anyone who acts for Cactive. It reflects the Criminal Code Act 1995 (Cth), including its foreign bribery offences and the offence of failing to prevent foreign bribery, and the laws of the other countries we deal with.
What we don’t do
- Offer, promise, give, ask for or accept anything of value to improperly influence a decision, in government or in business.
- Make facilitation payments to speed up routine government action, whatever their size.
- Make political donations on Cactive’s behalf.
- Hide a payment, or record it as something it isn’t.
Gifts and hospitality
Gifts and hospitality must be modest, infrequent and openly given, and never offered or accepted while a decision involving the other party is pending. Anything more than a token needs a director’s approval first; anything offered to a public official needs it in every case.
Working with others
We expect the suppliers, resellers and advisers who act for us to follow the same rules, and we won’t work with anyone we have reason to believe pays bribes.
Raising a concern
If you’re asked for a bribe, or suspect one, tell a director or email legal@cactive.com.au. Our Whistleblower Policy protects people who speak up in good faith. Breaking this policy can lead to dismissal or the end of a contract, and we report crimes to the authorities.