LAST UPDATED 4 APRIL2025

ANTI-BRIBERY POLICY

This policy reflects the company’s commitment to ethical conduct and compliance with applicable anti-bribery laws, including but not limited to the Foreign Corrupt Practices Act (FCPA) in the United States, the UK Bribery Act, and any local laws relevant to the jurisdictions in which Bale Capital Pty Ltd operates being the Commonwealth of Australia. This document is intended to guide the company’s employees, contractors, and business partners in upholding integrity and transparency in all business dealings.

1. Introduction

Bale Capital Pty Ltd (hereafter referred to as “the Company”) is committed to conducting its business fairly, honestly, and with integrity. This policy outlines the Company’s stance against bribery and corruption in all its forms, whether direct or indirect, and sets forth the procedures to ensure compliance with anti-bribery laws and regulations.

2. Policy Statement

The Company prohibits bribery in any form. This includes offering, promising, giving, accepting, or soliciting an advantage as an inducement for action that is illegal, unethical, or a breach of trust. The Company is committed to acting professionally, fairly, and with the utmost integrity in all business dealings and relationships.

3. Scope

This policy applies to:

1. All employees at every level and grade, including senior managers, officers, directors, employees (whether permanent, fixed-term, or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers, and agency staff.
2. Business partners, suppliers, contractors, agents, advisors, and any other people or bodies associated with the Company, domestically and internationally.

4. Compliance with Laws

The Company will comply with all laws, regulations, and guidelines regarding anti-bribery and anti-corruption, including but not limited to the FCPA, the UK Bribery Act, and applicable local laws in every jurisdiction in which it operates.

5. Bribery

Bribery involves offering, promising, giving, accepting, or soliciting something of value as an inducement for an action which is illegal, unethical, or a breach of trust. This policy prohibits:

1. Bribes to influence the actions of someone in business or government.
2. Kickbacks in any form.
3. Any other means of obtaining unfair or unethical advantages.

6. Gifts and Hospitality

The Company acknowledges that the giving and receiving of gifts and hospitality as part of building business relationships is a normal practice. However, it is crucial that such gestures are not used to influence business decisions. Therefore:

1. Gifts and hospitality may be given or received provided they are customary, reasonable, and do not have the intention of influencing a business decision.
2. Employees must declare any gifts or hospitality offered or received that exceeds a specified threshold, as detailed in the Company’s Gifts and Hospitality Guidelines.

7. Responsibilities of Employees and Management

1. Employees are required to understand and comply with this policy, seek guidance when in doubt, and report any suspected bribery or corruption through the specified channels.
2. Management has a special responsibility to lead by example and ensure those reporting to them are made aware of and understand this policy.

8. Reporting Violations

Employees and others are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. The Company assures that it will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

9. Record Keeping

The Company will keep detailed and accurate financial records and have appropriate internal controls in place to act as evidence for all payments made.

10. Policy Review and Enforcement

1. Review: This policy will be reviewed regularly and updated as necessary to ensure it meets legal requirements and reflects the highest standards of ethical conduct.
2. Enforcement: Violation of this policy will result in disciplinary action, which could result in dismissal for gross misconduct. The Company will not hesitate to terminate its relationship with any individual or organization acting on the Company’s behalf if they breach this policy.
   
   

Bale Capital Pty Ltd is committed to upholding all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. We are committed to doing business with integrity, transparency, and fairness. This policy is crucial for maintaining the Company’s reputation and the trust of our clients, partners, and the public.

This policy serves as a guideline for Bale Capital Pty Ltd’s stance against bribery and corruption. It should be communicated to all employees and business partners and incorporated into the Company’s training programs. Compliance with this policy is mandatory for all individuals working for or with the Company, ensuring Bale Capital Pty Ltd’s business practices are conducted in a lawful and ethical manner.