Anti Bribery & Corruption Policy
1. Purpose
New Venture Wealth Pty Ltd ("New Venture Wealth" or "the Company") is committed to conducting all business activities honestly, ethically and in accordance with all applicable Australian laws and regulatory obligations.
The Company maintains a zero-tolerance approach to bribery, corruption, fraud and improper influence in every aspect of its operations.
This Policy establishes the principles, governance framework, responsibilities and minimum standards that apply to all directors, officers, employees, contractors, consultants, authorised representatives and any third party acting on behalf of New Venture Wealth.
The objectives of this Policy are to:
- protect the integrity and reputation of New Venture Wealth;
- ensure compliance with Australian anti-bribery and anti-corruption legislation;
- promote an ethical culture throughout the organisation;
- prevent bribery, corruption and improper conduct;
- ensure business decisions are made solely on legitimate commercial considerations;
- protect clients, regulators, financial institutions and business partners from unethical practices;
- establish reporting obligations where suspected misconduct arises;
- ensure the Board exercises effective oversight of bribery and corruption risks.
This Policy forms part of New Venture Wealth's Corporate Governance Framework and should be read in conjunction with all related governance, compliance and risk management policies.
2. Scope
This Policy applies to:
- every Director of New Venture Wealth;
- all permanent, temporary and casual employees;
- contractors and consultants;
- outsourced service providers;
- authorised representatives;
- agents and intermediaries;
- referral partners acting on behalf of New Venture Wealth;
- suppliers;
- vendors;
- business partners;
- any individual or entity representing or acting for New Venture Wealth in Australia or overseas.
Compliance with this Policy is mandatory.
Failure to comply may result in disciplinary action, termination of employment or engagement, reporting to regulators and, where appropriate, referral to law enforcement agencies.
3. Policy Statement
New Venture Wealth prohibits all forms of bribery and corruption.
No person acting on behalf of the Company may:
- offer a bribe;
- request a bribe;
- authorise a bribe;
- promise a bribe;
- facilitate a bribe;
- receive a bribe;
- conceal a bribe;
- knowingly ignore corrupt conduct;
- make improper payments designed to influence a business outcome.
This prohibition applies regardless of:
- monetary value;
- whether the payment is made directly or indirectly;
- whether the recipient is a government official or private individual;
- whether the payment occurs within Australia or overseas;
- whether the payment is described as a commission, consulting fee, gift, facilitation payment, donation, reimbursement or any other label.
New Venture Wealth expects every person acting on its behalf to act lawfully, fairly, transparently and ethically.
Commercial success must never be achieved through improper influence.
4. Guiding Principles
The Company's Anti-Bribery and Anti-Corruption Framework is built upon the following principles.
4.1 Integrity
Business decisions must always be made honestly, fairly and independently.
No employee may compromise ethical standards to obtain commercial advantage.
4.2 Compliance with Law
All activities undertaken by New Venture Wealth must comply with:
- Commonwealth legislation;
- State and Territory legislation;
- applicable regulatory requirements;
- contractual obligations;
- industry standards;
- professional ethical obligations.
Where multiple legal requirements apply, the highest standard shall be adopted.
4.3 Zero Tolerance
New Venture Wealth has zero tolerance for:
- bribery;
- corruption;
- kickbacks;
- secret commissions;
- improper gifts;
- undisclosed conflicts of interest;
- facilitation payments;
- fraudulent inducements;
- dishonest business conduct.
No commercial opportunity justifies unethical conduct.
4.4 Transparency
Business dealings must be:
- properly documented;
- accurately recorded;
- capable of independent verification;
- supported by legitimate business purposes.
False invoices, misleading accounting records or concealed payments are strictly prohibited.
4.5 Accountability
Every individual is personally responsible for complying with this Policy.
Managers are responsible for promoting ethical behaviour and ensuring appropriate oversight within their areas of responsibility.
The Board remains ultimately accountable for governance of bribery and corruption risk.
5. Legislative Framework
This Policy has been developed having regard to, including but not limited to:
- Criminal Code Act 1995 (Cth)
- Corporations Act 2001 (Cth)
- Australian Securities and Investments Commission Act 2001
- Competition and Consumer Act 2010
- Fair Work Act 2009
- Tax Agent Services Act 2009
- Treasury Laws Amendment (Enhancing Whistleblower Protections) Act 2019
- Anti-Money Laundering and Counter-Terrorism Financing legislation (where applicable)
- State and Territory criminal legislation relating to bribery and corruption
- applicable professional accounting and taxation ethical standards.
Where this Policy imposes a higher standard than legislation, the requirements of this Policy must be followed.
5,1– International Standards
6. Definitions
For the purposes of this Policy:
Bribery
Bribery means offering, giving, promising, requesting, authorising or receiving any financial or non-financial benefit intended to improperly influence a decision or secure an improper advantage.
A benefit may include:
- cash;
- loans;
- gifts;
- entertainment;
- travel;
- employment opportunities;
- discounts;
- commissions;
- rebates;
- services;
- hospitality;
- confidential information;
- preferential treatment;
- political support;
- charitable donations;
- sponsorships;
- anything else of value.
Corruption
Corruption is the misuse of entrusted power, position or authority for private benefit or to improperly advantage another person or organisation.
Corruption may involve:
- abuse of authority;
- conflicts of interest;
- secret commissions;
- kickbacks;
- fraudulent procurement;
- favouritism;
- manipulation of commercial decisions;
- concealment of improper payments.
Facilitation Payment
A facilitation payment is a payment made to secure or expedite a routine government action or administrative process.
New Venture Wealth prohibits facilitation payments regardless of whether they may be permitted in another jurisdiction.
Government Official
A Government Official includes any person acting on behalf of:
- Commonwealth Government;
- State Government;
- Local Government;
- foreign governments;
- regulators;
- public authorities;
- government-owned corporations;
- political parties;
- political candidates;
- international organisations.
Third Party
A Third Party includes any external individual or organisation acting for or representing New Venture Wealth, including:
- consultants;
- contractors;
- suppliers;
- referral partners;
- introducers;
- intermediaries;
- outsourced service providers;
- agents.
7. Roles and Responsibilities
Board of Directors
The Board is responsible for:
- approving this Policy;
- setting the ethical culture of the organisation;
- overseeing bribery and corruption risk;
- ensuring appropriate governance arrangements exist;
- reviewing material breaches;
- ensuring adequate compliance resources are maintained;
- reviewing the effectiveness of this Policy at least every two years.
Managing Director
The Managing Director is responsible for:
- implementing this Policy;
- promoting an ethical culture;
- ensuring adequate controls exist;
- ensuring investigations are conducted where appropriate;
- reporting material incidents to the Board;
- ensuring corrective action is implemented.
Managers
Managers are responsible for:
- leading by example;
- ensuring staff understand this Policy;
- monitoring compliance;
- identifying bribery and corruption risks;
- escalating suspected breaches immediately.
Employees and Representatives
Every employee and representative must:
- comply with this Policy;
- refuse any improper payment or benefit;
- immediately disclose suspected bribery;
- cooperate with investigations;
- complete required compliance training;
- act honestly in all dealings.
Ignorance of this Policy is not a defence for non-compliance.
8. Risk-Based Approach
New Venture Wealth adopts a risk-based approach to preventing bribery and corruption.
Bribery and corruption risks will be considered when:
- engaging suppliers;
- appointing consultants;
- appointing referral partners;
- entering commercial agreements;
- onboarding third parties;
- making charitable contributions;
- engaging with government agencies;
- procuring services;
- approving significant expenditure;
- expanding into new markets or service offerings.
Risk assessments should consider:
- jurisdiction;
- industry sector;
- transaction value;
- government interaction;
- complexity of ownership structures;
- payment methods;
- reputation risks;
- previous compliance history.
Where elevated risks are identified, enhanced due diligence and management approval shall be required before proceeding.
9. Prohibited Conduct
New Venture Wealth strictly prohibits any conduct that could constitute bribery, corruption or an improper business practice.
Without limitation, no Director, employee, contractor or representative of the Company may, directly or indirectly:
- offer or provide a bribe;
- request or accept a bribe;
- authorise another person to pay a bribe;
- conceal or facilitate corrupt conduct;
- make payments intended to improperly influence a decision;
- offer anything of value to obtain an improper commercial advantage;
- falsify accounting or financial records to disguise improper payments;
- use third parties to circumvent this Policy;
- create false invoices or fictitious service arrangements;
- accept secret commissions or undisclosed incentives;
- misuse Company funds for personal benefit;
- deliberately ignore or fail to report suspected bribery or corruption.
Attempts to engage in bribery or corruption are treated as seriously as completed acts.
No employee will be disadvantaged for refusing to participate in conduct that breaches this Policy, even where refusal results in the loss of business.
10. Gifts, Benefits and Hospitality
10.1 Principle
New Venture Wealth recognises that reasonable business hospitality and modest gifts may form part of legitimate commercial relationships.
However, gifts, benefits and hospitality must never:
- influence business decisions;
- create an actual or perceived conflict of interest;
- compromise professional judgement;
- create an obligation;
- influence procurement decisions;
- influence financial advice or accounting services;
- influence referrals;
- influence regulatory outcomes.
All gifts and hospitality must be reasonable, transparent and capable of public scrutiny.
If the gift would cause embarrassment if reported publicly, it should not be accepted or offered.
10.2 Acceptable Gifts
Examples of gifts that may be acceptable include:
- modest promotional items;
- calendars;
- diaries;
- pens;
- flowers;
- chocolates;
- occasional working lunches;
- modest refreshments during meetings;
- low-value seasonal gifts.
Acceptance remains subject to management discretion.
10.3 Prohibited Gifts
The following are prohibited unless expressly approved by the Board in exceptional circumstances:
- cash;
- cash equivalents;
- gift cards;
- prepaid debit cards;
- cryptocurrency;
- personal loans;
- expensive travel;
- luxury accommodation;
- excessive entertainment;
- personal services;
- private holidays;
- gifts during procurement or tender processes;
- gifts intended to influence a commercial outcome.
Under no circumstances may gifts be requested.
10.4 Government Officials
Extra care must be exercised when dealing with Government Officials.
Unless specifically approved under Company procedures, gifts, entertainment or hospitality must not be offered to Government Officials where there is any possibility the benefit could influence, or appear to influence, official decision making.
10.5 Recording Gifts
All reportable gifts and hospitality must be accurately recorded within the Company's Gifts and Hospitality Register.
The register should include:
- date;
- recipient;
- provider;
- estimated value;
- business purpose;
- approving manager;
- whether accepted or declined.
The register forms part of the Company's governance records and may be reviewed by auditors, regulators or clients during due diligence.
11. Facilitation Payments
New Venture Wealth prohibits facilitation payments.
Facilitation payments are unofficial payments made to secure or accelerate routine administrative actions.
Examples include payments intended to:
- accelerate licence approvals;
- obtain permits;
- expedite customs clearances;
- speed up regulatory processing;
- secure routine inspections;
- obtain certificates.
Facilitation payments remain prohibited regardless of:
- amount;
- local custom;
- commercial pressure;
- overseas business practice.
Where an employee is subjected to threats involving immediate personal safety, preservation of life takes priority.
Any payment made under genuine duress must:
- be reported immediately;
- be accurately recorded;
- be investigated;
- be reviewed by senior management.
12. Political Contributions
New Venture Wealth does not make political contributions designed to obtain or retain business or influence regulatory decisions.
Any political contribution made on behalf of the Company must:
- comply with Australian law;
- be transparent;
- receive prior Board approval;
- be accurately recorded in Company records;
- never be linked to business opportunities.
Employees remain free to participate in political activities in a personal capacity, provided they do not represent those activities as being undertaken on behalf of New Venture Wealth.
13. Charitable Donations and Community Support
New Venture Wealth supports responsible community engagement.
Charitable donations, sponsorships and community initiatives must:
- support legitimate charitable purposes;
- be transparent;
- be appropriately authorised;
- be accurately recorded;
- not provide an improper business advantage;
- never be used as a disguised form of bribery.
Due diligence should be undertaken where appropriate to confirm the legitimacy of the recipient organisation.
14. Sponsorships
Corporate sponsorships must:
- support legitimate commercial or community objectives;
- be supported by documented agreements;
- provide demonstrable business or community benefit;
- not influence procurement decisions;
- not influence government decision making;
- not improperly influence clients.
All sponsorship expenditure must receive appropriate management approval.
15. Conflicts of Interest
Every person acting on behalf of New Venture Wealth must avoid situations where personal interests conflict, or appear to conflict, with Company interests.
Conflicts may arise through:
- financial interests;
- family relationships;
- outside employment;
- directorships;
- investments;
- referral arrangements;
- supplier relationships;
- gifts and hospitality.
Employees must disclose actual, potential or perceived conflicts as soon as reasonably practicable.
Failure to disclose a conflict may constitute misconduct.
Managers are responsible for ensuring conflicts are appropriately managed, documented and monitored.
16. Third Parties
New Venture Wealth recognises that bribery risks frequently arise through third parties.
The Company may be held responsible for improper conduct undertaken by third parties acting on its behalf.
Accordingly, reasonable due diligence must be undertaken before engaging:
- consultants;
- contractors;
- referral partners;
- introducers;
- suppliers;
- outsourced service providers;
- business representatives;
- agents.
Engagement should consider:
- ownership structure;
- reputation;
- regulatory history;
- litigation history;
- sanctions exposure;
- conflicts of interest;
- financial integrity;
- qualifications and capability.
Where elevated risks are identified, additional due diligence shall be undertaken before engagement proceeds.
17. Procurement and Supplier Integrity
Procurement decisions must be based upon:
- capability;
- quality;
- price;
- service;
- experience;
- commercial merit;
- risk.
Employees involved in procurement must:
- avoid conflicts of interest;
- treat suppliers fairly;
- maintain confidentiality;
- avoid preferential treatment;
- document significant procurement decisions;
- refuse inducements.
Suppliers are expected to conduct business ethically and comply with applicable anti-bribery laws.
New Venture Wealth reserves the right to terminate supplier relationships where bribery or corruption concerns arise.
18. Client Relationships
Employees must maintain professional independence when providing:
- accounting services;
- SMSF document preparation;
- compliance services;
- taxation services;
- business advisory services;
- corporate administration services.
No employee may:
- favour one client because of gifts or hospitality;
- provide preferential treatment in exchange for personal benefits;
- manipulate professional advice to secure commercial gain;
- accept undisclosed incentives from clients.
Professional advice must always remain objective, independent and in the best interests of the client.
19. Books, Records and Financial Controls
New Venture Wealth is committed to maintaining complete, accurate and transparent financial records.
All transactions must:
- be properly authorised;
- be supported by legitimate documentation;
- accurately reflect the underlying transaction;
- comply with accounting standards;
- comply with taxation requirements;
- comply with Company financial policies.
The Company prohibits:
- off-book accounts;
- false invoices;
- misleading expense claims;
- concealed payments;
- undisclosed commissions;
- fictitious suppliers;
- inaccurate financial reporting.
No payment may be processed without appropriate supporting documentation.
Employees must never intentionally record false or misleading information in Company systems.
20. Approval Authorities
Appropriate financial approval controls assist in preventing bribery and corruption.
The Company shall maintain documented approval authorities appropriate to the size and complexity of its operations.
Approval requirements should include consideration of:
- expenditure thresholds;
- procurement authority;
- contract approvals;
- sponsorship approvals;
- charitable donations;
- gifts and hospitality;
- engagement of third parties.
No individual should approve a payment or transaction from which they may personally benefit.
Segregation of duties should be maintained wherever reasonably practicable to reduce the risk of fraud, bribery and improper conduct.
21. Reporting Suspected Bribery and Corruption
21.1 Obligation to Report
Every Director, employee, contractor and representative has an obligation to promptly report any suspected or actual bribery, corruption, fraud, unethical conduct or breach of this Policy.
Reports should be made as soon as practicable after becoming aware of the matter.
Failure to report known or suspected misconduct may itself constitute a breach of this Policy.
21.2 Matters That Must Be Reported
Reportable matters include, but are not limited to:
- suspected bribery;
- suspected corruption;
- requests for improper payments;
- offers of gifts intended to influence decisions;
- conflicts of interest that have not been disclosed;
- inaccurate accounting records;
- false invoices;
- procurement irregularities;
- secret commissions;
- kickbacks;
- facilitation payments;
- suspected fraud;
- unethical conduct by suppliers or third parties;
- retaliation against whistleblowers.
Employees should report concerns even where they are uncertain whether a breach has occurred.
21.3 Reporting Channels
Reports may be made to:
- the Managing Director;
- the Board Chair;
- the Company's Responsible Manager (where applicable);
- the Company's external legal adviser;
- any other reporting mechanism established under the Company's Whistleblower Policy.
Where a report involves senior management, the report should be made directly to the Chair of the Board.
22. Protection of Whistleblowers
New Venture Wealth encourages the reporting of genuine concerns and is committed to protecting individuals who report suspected misconduct in good faith.
No person will be subject to:
- dismissal;
- demotion;
- discrimination;
- intimidation;
- harassment;
- victimisation;
- threats;
- adverse treatment
because they have made a genuine report under this Policy.
Knowingly making false or malicious allegations may result in disciplinary action.
This Policy should be read in conjunction with the Company's Whistleblower Policy and applicable Australian whistleblower protection legislation.
23. Investigations
All reports of suspected bribery or corruption will be assessed promptly and, where appropriate, investigated fairly, independently and confidentially.
Investigations may be conducted internally or by appropriately qualified external advisers.
Investigations will seek to determine:
- the relevant facts;
- whether this Policy has been breached;
- whether any laws have been breached;
- whether internal control weaknesses exist;
- whether corrective actions are required.
All persons are expected to cooperate fully with any investigation.
Confidentiality will be maintained to the greatest extent reasonably possible, subject to legal obligations and the requirements of a fair investigation.
24. Cooperation with Regulators and Law Enforcement
Where required by law, New Venture Wealth will cooperate fully with:
- law enforcement agencies;
- ASIC;
- AUSTRAC (where applicable);
- the Australian Federal Police;
- State and Territory police;
- courts;
- regulatory authorities;
- government agencies.
Nothing in this Policy prevents the Company from voluntarily reporting serious misconduct where appropriate.
25. Record Keeping
Accurate records are essential to preventing bribery and corruption.
The Company will maintain appropriate records relating to:
- gifts and hospitality;
- charitable donations;
- sponsorships;
- procurement decisions;
- supplier due diligence;
- conflict of interest declarations;
- investigations;
- employee training;
- Board approvals;
- policy reviews;
- disciplinary actions.
Records must:
- be complete;
- be accurate;
- be retained in accordance with legislative requirements and Company record retention policies;
- be readily available for authorised review.
No person may intentionally destroy or alter records to conceal misconduct.
26. Training and Awareness
New Venture Wealth is committed to ensuring that all personnel understand their obligations under this Policy.
Training may include:
- employee induction;
- periodic refresher training;
- director training;
- manager training;
- compliance updates;
- risk awareness sessions.
Training should be proportionate to the level of bribery and corruption risk associated with each role.
Employees may be required to confirm annually that they have:
- read this Policy;
- understood this Policy;
- complied with this Policy.
27. Monitoring and Compliance
Compliance with this Policy will be monitored on an ongoing basis.
Monitoring activities may include:
- management reviews;
- internal audits;
- financial reviews;
- procurement reviews;
- supplier reviews;
- compliance testing;
- policy attestations;
- Board reporting.
Monitoring outcomes will be used to strengthen the Company's anti-bribery framework and improve internal controls.
28. Risk Assessment
The Company will periodically assess bribery and corruption risks having regard to:
- changes in legislation;
- changes in services;
- new markets;
- new suppliers;
- mergers or acquisitions;
- outsourcing arrangements;
- emerging fraud risks;
- client expectations;
- regulatory developments.
Risk assessments should be documented and reviewed by senior management.
Material risks should be reported to the Board.
29. Breaches of this Policy
Breaches of this Policy are treated seriously.
Depending upon the circumstances, disciplinary action may include:
- counselling;
- formal warning;
- mandatory retraining;
- removal of delegated authority;
- suspension;
- termination of employment;
- termination of supplier contracts;
- referral to regulators;
- referral to law enforcement;
- civil or criminal proceedings.
Disciplinary action will be proportionate to the seriousness of the breach.
30. Responsibilities of Leaders
Directors and managers are expected to demonstrate ethical leadership.
Leaders should:
- promote integrity;
- encourage open reporting;
- model ethical behaviour;
- ensure staff receive appropriate guidance;
- support employees who raise concerns;
- respond promptly to suspected misconduct;
- ensure decisions are transparent and appropriately documented.
Leadership behaviour is fundamental to maintaining an ethical culture.
31. Continuous Improvement
New Venture Wealth recognises that effective anti-bribery compliance requires ongoing improvement.
The Company will periodically review:
- policies;
- procedures;
- internal controls;
- training;
- governance arrangements;
- risk assessments;
- reporting mechanisms.
Lessons learned from investigations, audits and regulatory developments will be incorporated into future improvements.
32. Interaction with Other Policies
This Policy should be read together with the Company's:
- Code of Conduct;
- Whistleblower Policy;
- Conflict of Interest Policy;
- Fraud Control Policy;
- Risk Management Framework;
- Privacy Policy;
- Information Security Policy;
- Employee Handbook;
- Procurement Policy;
- Delegations of Authority Policy;
- Financial Management Policy.
Where inconsistency exists, the higher standard of ethical conduct shall apply.
33. Policy Governance
This Policy is owned by the Board of Directors.
Responsibility for implementation rests with the Managing Director.
The Managing Director is responsible for ensuring:
- effective implementation;
- appropriate communication;
- periodic review;
- compliance monitoring;
- reporting of significant breaches.
The Board retains ultimate accountability for oversight of bribery and corruption risk.
34. Policy Review
This Policy shall be reviewed:
- at least every two years;
- following any material legislative change;
- following any significant bribery or corruption incident;
- following major changes to the Company's operations;
- whenever directed by the Board.
Earlier reviews may be undertaken where considered appropriate.
35. Policy Exceptions
No exception to this Policy may be granted where doing so would permit conduct that is unlawful or inconsistent with the Company's ethical standards.
Any approved administrative exception must:
- be documented;
- include supporting reasons;
- receive written approval from the Managing Director and, where material, the Board.
Exceptions must never undermine the intent of this Policy.
36. Policy Compliance Declaration
All Directors, employees, contractors and representatives are expected to:
- understand this Policy;
- comply with this Policy;
- complete required training;
- cooperate with investigations;
- report suspected misconduct promptly.
Failure to comply may result in disciplinary action and, where appropriate, referral to regulators or law enforcement.
37. Board Statement
The Board of Directors of New Venture Wealth Pty Ltd is committed to maintaining the highest standards of integrity, professionalism and ethical conduct.
The Board recognises that strong governance and an effective anti-bribery framework are fundamental to protecting the interests of clients, employees, regulators, financial institutions, suppliers and the broader community.
The Board expects every individual associated with New Venture Wealth to uphold the principles contained within this Policy and to contribute to a culture in which ethical conduct is valued above commercial gain.
