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Anti-Bribery & Corruption Policy


Ascend GRC is committed to maintaining the highest standards of integrity, transparency, and ethical conduct. This policy establishes a zero-tolerance approach to bribery and corruption, ensuring compliance with Australian laws and international anti-corruption standards.
Ascend GRC Anti-Bribery & Corruption Policy

Anti-Bribery & Corruption Policy

1. Purpose

Ascend GRC is committed to maintaining the highest standards of integrity, transparency, and ethical conduct. This policy establishes a zero-tolerance approach to bribery and corruption, ensuring compliance with Australian laws and international anti-corruption standards.


2. Scope

This policy applies to all employees, board members, contractors, consultants, volunteers, and any third parties acting on behalf of Ascend GRC.


3. Definitions

  • Bribery: Offering, giving, receiving, or soliciting something of value to influence a business decision.

  • Corruption: Any dishonest or unethical conduct that abuses entrusted power for personal or organisational gain.

  • Facilitation Payments: Small, unofficial payments made to expedite routine government actions, which are prohibited under this policy.

  • Gifts & Hospitality: Items of value, entertainment, or favours that could improperly influence decision-making.


4. Policy Statement

Ascend GRC is committed to:

  • Prohibiting all forms of bribery, corruption, and facilitation payments.

  • Ensuring compliance with the Criminal Code Act 1995 (Cth) and global anti-corruption laws.

  • Promoting ethical business practices and transparency.

  • Encouraging reporting of suspected bribery or corruption.


5. Prohibited Conduct

  • Offering, accepting, or requesting bribes, kickbacks, or illegal commissions.

  • Making facilitation payments, regardless of local business practices.

  • Engaging in or allowing conflicts of interest that may lead to corrupt behaviour.

  • Failing to disclose gifts or hospitality that could influence decision-making.


6. Gifts & Hospitality

  • Gifts or hospitality must be modest, infrequent, and not influence business decisions.

  • Any gift or benefit exceeding AUD $100 must be disclosed to management.

  • Cash gifts or personal benefits are strictly prohibited.


7. Reporting & Whistleblower Protection

  • Employees must report any suspected bribery or corruption via:

  • Reports will be treated confidentially, and whistleblowers will be protected from retaliation.


8. Compliance & Consequences

  • Violations of this policy may result in disciplinary action, including termination and legal prosecution.

  • Regular training and risk assessments will be conducted to ensure compliance.

  • The Board will oversee adherence to anti-bribery obligations.


9. Related Legislation & Standards

  • Criminal Code Act 1995 (Cth) – Bribery of Foreign Public Officials.

  • Australian Bribery & Corruption Laws.

  • ISO 37001: Anti-Bribery Management Systems.

  • OECD Anti-Bribery Convention.


10. Review & Approval

This policy will be reviewed annually by the Board of Directors to ensure compliance and effectiveness.


11. Contact Information

For queries regarding this policy, please contact:

Ascend GRC Compliance Team


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