Anti Bribery and Corruption

Policy
Australia

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 Anti Bribery and Corruption Policy

1. ANTI-BRIBERY

1.1 CROSSMARK is committed to fair and equitable business practices and expects compliant
and ethical behavior by all its employees and associated parties (whether natural persons
or incorporated) acting for and on behalf of CROSSMARK, as outlined in our Code of
Conduct. CROSSMARK prohibits any form of bribery. Bribery in short refers to giving or
receiving a financial or other advantage in connection with the improper performance of a
position of trust or a function that is expected to be performed impartially or in good faith.
This policy (“Policy”) is intended to outline clear principles and rules for the prevention of
bribery and corruption, thereby providing employees with guidance on proper standards
of behavior.

1.2 When referencing CROSSMARK throughout this Policy, this is inclusive of all
companies under The DKSH Smollan Group; CROSSMARK, RDAS, STP and Host.

2. COMMENCEMENT OF POLICY

2.1 This Policy will commence from 01/08/2023. It replaces all other policies (whether
written or not).

3. SCOPE
3.1 This policy applies to all employees, agents and contractors (including temporary
contractors) of CROSSMARK, collectively referred to as ‘workplace participants´.
3.2 This Policy is aligned with applicable laws and regulations and, in certain parts of our
business, industry codes of practice.

4. PURPOSE
4.1 CROSSMARK has zero tolerance for any form of bribery. Employees shall not, directly,
for or through an external party, promise, offer, make, authorize, solicit or accept any
financial or other advantage, to obtain or retain business or secure an improper
advantage in the conduct of business.
4.2 The prohibition of bribery applies to both the public sector (public officials) as well as
private sector businesses. CROSSMARK applies a range of procedures for the
prevention of bribery and corruption. These include risk assessment, implementation
of risk mitigation measures and appropriate controls, managing of third-party risks,
training and communication, as well as monitoring and reviews.
4.3 CROSSMARK restricts hiring and ongoing employment to individuals who
demonstrate their commitment to the highest standards of integrity and prohibits the
offering of employment as a favor to facilitate business.
4.4 It is the responsibility of every Employee to comply with this Policy, to prevent any
instances of bribery and corruption and to report any corresponding concerns or
suspicions.

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4.5 CROSSMARK commits to protecting employees who in good faith raise genuine bribery
concerns or suspicions.
4.6 Failure to prevent bribery can have major consequences at both an organizational and
individual level, including reputational damage and financial loss.
4.7 Payment of a bribe may result in the individual/department being liable for
prosecution under Australian or foreign law.
4.8 This policy provides instructions and guidance on the prevention of and response to
bribery across the organization.

5. WHAT IS A BRIBE?
5.1 A Bribe is a benefit given or offer sought or made with the intension of influencing a
person to take or not take a specific action.
5.2 Bribery is an offence and carries penalty of fines and imprisonment in Australia. To
corruptly receive commissions is an offence if you corruptly receive, solicit, give, or
offer a benefit as an inducement to do or not do something or to show or not show
favor of disfavour to someone.
5.3 Bribery of a foreign official is a serious crime under Australian law, punishable by fines
and imprisonment. Australian criminal law has extraterritorial effect and may apply to
this conduct. Bribery can occur when a Departmental employee is acting on behalf of
a client or working with an agent of the client.
5.4 A person is guilty of committing an offence of bribing a foreign official if:
5.5 The person provides a benefit to another person, or offers or promises to provide a
benefit to another person, or causes a benefit to be provided, offered, or promised to
another person; and
5.6 The benefit is not legitimately due to the other person; and
5.7 Step 1 was carried out with the intention of influencing a foreign public official (who
may or may not be the other person) in the exercise of the official’s duties as a foreign
public official, to obtain or retain any business or business advantage, which is not
legitimately due.

6. GIFTS, HOSPITALITY AND ENTERTAINMENT

6.1 Gifts are benefits of various kinds (including objects, gratuities, rewards, favors, or
other incentives) offered or given to Public Officials or people who have or may have
facilitated, or who may facilitate the creation or maintenance of a business and/or
regulatory relationship with CROSSMARK.
6.2 Hospitality refers to meals, drinks, as well as lodging and travel expenses (such as air
tickets, etc.) given to or received from Public Officials or people who have or may have
facilitated, or who may facilitate the creation or maintenance of a business and/or
regulatory relationship with CROSSMARK.
6.3 Entertainment refers to attendance at social, cultural, or sporting events or similar
with Public Officials or people who have or may have facilitated, or who may facilitate
the creation or maintenance of a business and/or regulatory relationship with
CROSSMARK.

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6.4 Entertainment shall not be offered to participants in any events, such as business
meetings, conferences or similar unless reasonable and an incidental part of an event.
Furthermore, CROSSMARK prohibits the provision of any benefits to persons not
directly related to the purpose of such events.
6.5 Cash or cash equivalents (such as vouchers, coupons, etc.) shall never be offered, given
or accepted. Any deviations from this principle require approval by Group GRC. GHE
offered to CROSSMARK Employees exceeding a certain monetary threshold require
reporting and meaningful and feasible pre-approval before acceptance.

7. PROMOTIONAL ACTIVITIES AND INCENTIVES

7.1 Promotional Activities in our business generally refer to the marketing (e.g.
advertising, demonstrating, sampling) of our products or services offering to potential
buyers.
7.2 Incentives generally refer to benefits provided conditional on certain outcomes, e.g. a
bonus for meeting of a sales target.
7.3 CROSSMARK promotes its products and services in a proportionate, transparent, fair,
equitable and ethical manner and only permits reasonable expenditure relating to
demonstrating products and services, including related Hospitality expenses, or
promotional expenses in relation to performance of a contractual obligation, such as
training.
7.4 CROSSMARK does not allow the offering of incentives or incentive schemes to external
parties unless done in a legal, ethical, commercially justifiable, and fully transparent
manner and permissible under our rules. Equally, CROSSMARK employees shall not
accept any incentives from external parties (for exceptions refer to Group Limits of
Authority policy).
7.5 CROSSMARK prohibits any forms of Promotional Activities and Incentives which are
unethical and may give rise to suspicions of bribery, such as excessive discounting or
similar, or personalized incentives in the form of GHE, kickbacks or other.

8. SPONSORSHIPS, GRANTS AND DONATIONS

8.1 Sponsoring in the context of our business means the provision of monetary funds or
in-kind contributions for specific projects, events or activities in exchange for
recognition.
8.2 Grants generally refers to the provision of monetary benefits to an eligible person,
typically in combination with restrictions for their usage or application.
8.3 Donations refers to the provisions of monies or in-kind contributions to a specific
cause or for a specific purpose, generally related to charity or humanitarian needs, but
also social investment or sustainability.
8.4 Incentives generally refer to benefits provided conditional on certain outcomes, e.g. a
bonus for meeting of a sales target.
8.5 Sponsorships, grants, donations or similar contributions shall never be provided with
the intent of recipients or beneficiaries obtaining favors or improper advantages, or
for retaining or obtaining business.

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9. IMPLEMENTATION, COMMUNICATION AND TRAINING
9.1 Workplace participants are responsible and accountable for adhering to this Policy.
9.2 CROSSMARK Management is responsible for ensuring compliance with this Policy in
their Department.
9.3 Each manager shall ensure that all their Employees are aware of the significance and
the critical role of this Policy and the principles and standards contained therein.
9.4 Country Management is responsible for introducing and maintaining adequate
processes and procedures, including controls, to ensure compliance with this Policy by
all their Employees and associated parties (TPI and Vendors). Also, the Country
Management Team (CMT) shall ensure that mandatory ABAC training for Employees
is regularly provided, including specific training to groups of Employees and
associated parties in view of their roles and responsibilities and specific risks they face.
9.5 Group GRC shall coordinate and provide support on Policy implementation and
execution to Country Management in line with the role, responsibilities, and
authorities of the function.

10. FINANCIAL RECORDS AND DOCUMENTATION

10.1 CROSSMARK must maintain accurate books and records, in line with applicable laws,
regulations as well as accounting and reporting principles. Employees must ensure
that all financial transactions are properly recorded in a complete, true, and fair
manner.
10.2 No accounts must be kept "off-book" to facilitate or conceal improper payments, and
false or deceptive entries into books and records are strictly prohibited.
10.3 All transactions must be properly reviewed, approved and documented, and all
relevant internal controls procedures must be followed, to ensure that all payments
CROSSMARK makes or receives are properly accounted for in reasonable detail,
including the amount of the payment, the recipient, and the purpose for the
expenditure.
10.4 All claims by Employees for expenses incurred to third parties are to be submitted in
accordance with CROSSMARK’s expense claim policies. CROSSMARK will only
reimburse employees for goods, services and other expenditures that are fully and
properly supported by genuine documentation, such as original invoices or receipts.

11. YOUR RESPONSIBILITY AS:

11.1 Managers
• Ensure that all their staff understand this policy and implement it effectively
• notify the Director Governance, Audit and Risk of any concerns that staff may
have breached this policy and ensure a record is completed

11.2 Staff
• are responsible for complying with this policy and related procedures
• must ensure you are familiar with the contents of the policy

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 • must ensure that you act with integrity and demonstrate that you are not
influenced in the performance of your duties
• must always ensure, including when you are acting on behalf of clients (within
and outside of Australia), to avoid any action that would be considered bribery,
including of a foreign official
• must report any information of bribery or other corrupt acts
• must when working outside of Australia familiarise yourself with applicable
local laws in the places you work and travel to for work
•
11.3 Director, Governance, Audit & Risk Management
• maintains this Policy
• reviews any reports of bribery and provides guidance and assistance to
managers and staff on the application of this policy
• maintains a central register of bribery reports
• reports all instances of bribery to General Counsel and Deputy Secretary
Engagement, Operations and Governance
• determines with consideration of General Counsel what referrals need to occur
to the relevant Authorities

12. WHAT DO YOU DO IF YOU SUSPECT A BRIBE MAY OCCUR OR BE OFFERED?

12.1 Should you become aware that a person from a Company is potentially engaging or
considering engaging in a bribery offence whether themselves or with Department
staff, have regard to your own position and obligations and then inform the person
that:
• Australian criminal law has extraterritorial effect and may apply to such
conduct
• The NSW Government cannot condone illegal conduct under any
circumstances
• Department staff are under a duty to report this conduct
• Clients must be made aware at all appropriate opportunities that
Departmental staff will not carry out, condone, or ignore any act that will
breach the law. This is particularly important in countries where local
governance is weak, or there is a history of bribery as a means of doing
business

13. NON-COMPLIANCE OF THIS POLICY

13.1 The solicitation, acceptance or giving of a bribe as a staff member may result in
disciplinary action being taken against the workplace participant including potential
termination.
13.2 Such behaviour can bring individual staff into disrepute, undermine productive
working relationships in the workplace, hinder customer service delivery and damage
public trust in the Department and/or the broader government sector.

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 14. VARIATIONS
14.1 CROSSMARK reserves the right to vary, replace or terminate this policy from time to
time.

15. FURTHER INFORMATION

15.1 If you would like further information or clarification regarding this Policy, please reach out
to the HR team.

MONITORING AND REVIEW

This policy will be monitored annually by CROSSMARK to review its effectiveness and will be
updated in accordance with necessary changes.

Document Date Date of Review Reviewed by Revision Notes Approved

1/08/2023 1/08/2025 Human Policy Review Director, People

Resources and Culture

Associated Documents

• Code of Conduct

Worker acknowledgement

I acknowledge:

• receiving the CROSSMARK Policy

• that I will comply with the Policy and

• that there may be disciplinary consequences if I fail to comply, which may result in the
termination of my employment.

Your name: _______________________________________________________

Signed: ____________________________________________________________

Date: ______________________________________________________________