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Anti-bribery & Corruption Policy 

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1. Purpose & Objective

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At Global Tech Partners, we are committed to conducting business with integrity, transparency, and accountability.

This policy establishes our zero-tolerance approach to bribery and corruption and ensures compliance with applicable laws in Australia and New Zealand, including:

  • The Criminal Code Act 1995 (Cth)

  • The Crimes Act 1961

  • The Secret Commissions Act 1910

We also align with international best practices, including expectations under the OECD Anti-Bribery Convention.

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2. Scope
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This policy applies to:

  • All employees, officers, and directors

  • Contractors, consultants, and advisors

  • Third parties acting on behalf of the company (including partners, resellers, and agents)

It applies across all jurisdictions in which we operate.

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3. Policy Statement
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We prohibit all forms of bribery and corruption, including:

  • Offering, promising, or giving a bribe

  • Requesting, agreeing to receive, or accepting a bribe

  • Facilitation payments (even if customary in some jurisdictions)

  • Secret commissions, kickbacks, or undisclosed conflicts

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This applies to dealings with:

  • Government officials (including public servants and regulators)

  • Private sector organisations

  • Suppliers and partners

No commercial objective justifies unethical or unlawful conduct.

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4. What Constitutes Bribery?
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Bribery occurs when anything of value is offered, given, or received to improperly influence a decision or gain a business advantage.

This may include:

  • Cash or cash equivalents

  • Gifts, entertainment, or hospitality

  • Travel, accommodation, or event invitations

  • Employment opportunities or internships

  • Political or charitable donations intended to influence outcomes

Under Australian and New Zealand law, bribery can occur even if the benefit is not ultimately accepted or the outcome is not achieved.

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5. Gifts, Hospitality & Entertainment
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We recognise that legitimate business relationships may involve reasonable hospitality. However:

Permitted hospitality must be:

  • Modest, infrequent, and proportionate

  • For a legitimate business purpose

  • Not intended to influence decision-making

  • Compliant with applicable laws and client policies

The following are prohibited:

  • Cash or cash-equivalent gifts

  • Excessive or lavish entertainment

  • Any benefit offered during a tender or procurement process that could influence outcomes

All gifts and hospitality must be transparently recorded.

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6. Dealings with Government Officials
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Extra caution must be exercised when interacting with government officials in Australia, New Zealand, or internationally.

  • Any benefit offered to a public official may constitute a criminal offence

  • Prior approval is required for any gifts, hospitality, or sponsorship involving government representatives

  • Facilitation payments are strictly prohibited

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7. Third-Party Risk Management
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We recognise that third parties can pose bribery and corruption risks.

Accordingly, we will:

  • Conduct appropriate due diligence before engagement

  • Assess reputation, ownership, and integrity risks

  • Include anti-bribery and audit clauses in contracts

  • Monitor activities where appropriate

We reserve the right to terminate relationships where misconduct or elevated risk is identified.

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8. Books and Records
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We maintain accurate, complete, and transparent financial records.

We strictly prohibit:

  • False, misleading, or incomplete accounting entries

  • Off-the-books transactions or undisclosed accounts

  • Mischaracterising payments (e.g. disguising bribes as “consulting fees”)

All expenses must be properly documented, approved, and auditable.

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9. Reporting & Whistleblower Protection
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We encourage all personnel and stakeholders to report concerns, including:

  • Suspected bribery or corruption

  • Unusual or suspicious payments

  • Conflicts of interest

Reports can be made via: info@globaltechpartners.com.au

We support a speak-up culture and prohibit retaliation against anyone who raises concerns in good faith.

Where applicable, we align with protections under the Corporations Act 2001 whistleblower provisions.

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10. Training & Awareness
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We provide ongoing training to ensure employees understand:

  • Their obligations under this policy

  • Relevant Australian and New Zealand legal requirements

  • How to identify and manage bribery risks

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11. Breaches & Consequences
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Breaches of this policy may result in:

  • Disciplinary action, including termination

  • Termination of contracts or partnerships

  • Referral to law enforcement or regulatory authorities

Serious breaches may expose individuals and the company to criminal penalties in Australia and New Zealand.

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12. Review
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This policy is reviewed periodically to ensure it remains effective and aligned with evolving regulatory requirements in Australia and New Zealand. Last review 5th of May 2026.

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13. Contact
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For questions regarding this policy, please contact:

info@globaltechpartners.com.au​​

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