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:

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:

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:

This prohibition applies regardless of:

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:

Where multiple legal requirements apply, the highest standard shall be adopted.

4.3 Zero Tolerance

New Venture Wealth has zero tolerance for:

No commercial opportunity justifies unethical conduct.

4.4 Transparency

Business dealings must be:

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:

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:

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:

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:

Third Party

A Third Party includes any external individual or organisation acting for or representing New Venture Wealth, including:

7. Roles and Responsibilities

Board of Directors

The Board is responsible for:

Managing Director

The Managing Director is responsible for:

Managers

Managers are responsible for:

Employees and Representatives

Every employee and representative must:

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:

Risk assessments should consider:

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:

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:

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:

Acceptance remains subject to management discretion.

10.3 Prohibited Gifts

The following are prohibited unless expressly approved by the Board in exceptional circumstances:

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:

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:

Facilitation payments remain prohibited regardless of:

Where an employee is subjected to threats involving immediate personal safety, preservation of life takes priority.

Any payment made under genuine duress must:

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:

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:

Due diligence should be undertaken where appropriate to confirm the legitimacy of the recipient organisation.

14. Sponsorships

Corporate sponsorships must:

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:

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:

Engagement should consider:

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:

Employees involved in procurement must:

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:

No employee may:

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:

The Company prohibits:

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:

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:

Employees should report concerns even where they are uncertain whether a breach has occurred.

21.3 Reporting Channels

Reports may be made to:

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:

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:

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:

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:

Records must:

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:

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:

27. Monitoring and Compliance

Compliance with this Policy will be monitored on an ongoing basis.

Monitoring activities may include:

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:

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:

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:

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:

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:

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:

The Board retains ultimate accountability for oversight of bribery and corruption risk.

34. Policy Review

This Policy shall be reviewed:

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:

Exceptions must never undermine the intent of this Policy.

36. Policy Compliance Declaration

All Directors, employees, contractors and representatives are expected to:

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.

New Venture Wealth are SMSF Specialists and Chartered accountants. We are not financial advisors, and no content on this website should be considered as financial advice. Monthly tax and compliance fees are based on tax and compliance services for SMSF assets.

*  Free SMSF offer excludes ASIC fees. Must take up first year accounting services on direct debit to qualify for the free SMSF

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You agree that no principal or any staff member of New Venture Wealth Pty Ltd trading as “New Venture Wealth”:

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