Corporate Integrity Policy

1. Introduction:

This document sets out the procedures for promoting integrity within the workplace. To ensure that the practices of ITM’s employees are carried out within the scope of Domestic and International Law and Conventions.

2. Purpose:

The purpose of this policy is to provide guidance to Managers and staff of their responsibilities when dealing with both Domestic and International Transactions. By understanding these conventions employees will be able to identify corruption risk exposure relating to their operational responsibilities.

3. References:

Criminal Code Act 1995 – Division 12 & 70

Independent Commission Against Corruption (ICAC)

Australian Government – Foreign Bribery

OECD Anti-Bribery Convention.

Department Of Agriculture

Australian Customs and Border Protection Services

Contract Review (MS04)

Purchasing (MS07)

Control of Systems Records (MS11)

Company Policy (HR18)

4. Definitions:

4.1. Bribery:

A bribe is an inducement or reward offered, promised or provided in order to bring about improper performance by another person of a relevant function or activity.

4.2. Gifts

ITM employees may give or receive a gift that is meant to show friendship, appreciation or thanks to or from someone who does business with ITM. The giving or accepting gifts of low value such as corporate giveaways, consumables or other items of normal value is acceptable providing you do not ask for the gift and as long as it does not influence, or have the appearance of influencing, your objectivity or decision making. As a general rule, if accepting a gift could cause you (or a reasonable person in your position) to feel an obligation, do not accept it.



4.3.  Hospitality:

Corporate hospitality, such as business lunches, dinners, drinks, hospitality at sports or social event or other meetings in a social context are not considered to be gifts if a significant purpose of the meeting is business related and your participation is in ordinary course of business and is usual and customary. ITM understands that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.

5. Policy

Under this policy no one at ITM will:

  • Offer, promise, give, request, agree to receive or accept a bribe (including a facilitation payment)

  • Offer or receive gifts or entertainment that could affect, or be perceived to affect the outcome of business transactions and are not reasonable and justified

  • Make a donation as a way of obtaining or retaining an advantage for the benefit of ITM or any other person

  • Either into, or continue, a business relationship (with, for example, suppliers, third party agents and other intermediaries, joint venture partners or proposed merger and acquisition targets) if it cannot be satisfied that the entity will behave in a manner consistent with this policy.

6. Management Review

Management in conjunction with the CEO will monitor the effectiveness and review the implementation of this policy regularly, and will report to ITM’s board on its suitability, adequacy and effectiveness. Any improvements identified by the board will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.