Anti-Bribery and Corruption Policy

Ledge Finance Ltd ACN 009 138 868 (Company)

1. Scope and Purpose of Policy

Company’s Commitment

The purpose of this Policy is to establish controls to ensure compliance by the Company and its related bodies corporate (Group Members) with all applicable anti-bribery and corruption laws and to ensure that the Company and the Group Members conduct its business within the scope of the Company’s core values and commitments with honesty and integrity and in a socially responsible manner.

The Company and the Group Members have a “zero tolerance” approach to acts of bribery and corruption by any of Our People. As well as being morally wrong and harmful to the reputations of the Company and the Group Members (as applicable), bribery and corruption are criminal offences that expose the Company and the Group Members and individuals to the risk of prosecution, fines and imprisonment.

This Policy sets out the requirements of the Company and the Group Members regarding the management of gifts and benefits. Our People must not give or accept gifts and benefits that will compromise, or appear to compromise, their integrity and objectivity in performing their duties, or cause, or appear to cause a conflict of interest.

This Policy applies globally. Our People are advised that the Australian Criminal Code, the US Foreign Corrupt Practices Act and the UK Bribery Act have extra-territorial reach. As such, for example, an Australian citizen may be prosecuted under the Australian Criminal Code Act 1995 (Cth) (Code) for a violation of the Code that occurs outside of Australia.

Any breach of this Policy may result in disciplinary action, including termination of employment or contract. If the matter involves a breach of law or other regulation, the matter may also be referred to an appropriate law enforcement authority.

This Policy should be read together with the Whistleblower Policy.

2. Definitions

General terms and abbreviations used in this Policy have the meanings set out below:

DRC means the Company’s Director of Risk & Compliance and includes, where appropriate, the DRC Nominee.

DRC Nominee means, if the DRC is unavailable, any other person from time to time nominated as the contact on the Company’s Gift Register.

Company means Ledge Finance Ltd ACN 009 138 868      .

Gift and Entertainment Register means the Register described as such and provided on the Company’s intranet from time to time.

Group Members has the meaning set out in section 1.

Our People means our officers, employees, contractors and consultants and Group Members.

Policy means this anti-bribery and corruption policy.

Secretary means the secretary of the Company.

Whistleblower Policy means the Company’s whistleblower policy.

3. What is Bribery and Corruption

3.1          Bribery

Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal, unethical or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage and can take the form of gifts, donations, loans, fees, rewards or other advantages.

3.2          Corruption

Corruption is the abuse of entrusted power for private gain.

4. Policy

4.1          Bribery and Corruption

Our People are not permitted to give, offer, promise, accept, request or authorise a bribe or engage in any form of corruption, whether directly or indirectly.


An employee will be in breach of this Policy if their family member or business associate accepts a benefit that is offered with the intention of influencing the employee to act to the advantage of some person.

4.2          Gifts and Hospitality

Any gifts and genuine hospitality and entertainment expenditure that is reasonable and proportionate is allowable provided it does not place the recipient under any obligation or create any expectation that the giver will receive any special benefit or favour.

Our People must declare and report gifts and/or benefits, either offered or accepted and valued at $500 or more, in the Gift and Entertainment Register within 5 working days of receiving or being offered the gift or benefit to safeguard and make transparent their relationships and dealings with individuals, organisations and client groups. Gifts should not be accepted on a re-occurring basis or broken down into parts of less than $500.

Our People may declare and report gifts and/or benefits of less than $500 in the Gift and Entertainment Register and are encouraged to do so if they want to.


A breach of this Policy and potential corrupt behaviour may occur where Employee X is taken out to lunch over several weeks by a Big Bank executive seeking confidential financial information about a number of high net worth clients of the Company and the employee does not disclose this hospitality. (Assume that the value of the employee’s hospitality costs between $200 and $300 on each occasion and there are 5 lunches).

If it is known in advance, the receipt of the gift or benefit should be discussed with the relevant DRC prior to acceptance.


Company X offers to take the directors of Ledge to the AFL Grand Final (regardless of who is playing) 4 weeks before the big day. The directors of Ledge should register this on the Gift and Entertainment Register immediately.

The DRC must within 5 business days of being notified of an offer or receipt of a gift or benefit in accordance with this Policy provide the recipient of the offer, gift or benefit notice of any action that should be taken by that person in relation to the gift or benefit. Such actions may include declining, donating or returning the gift or benefit.


The DRC learns that some senior staff have also been offered packages to travel to the AFL Grand Final, but Company X is about to negotiate a big finance contract with Ledge’s assistance involving those same senior staff. In these circumstances, Ledge should politely decline the gifts, citing the potential for conflict of interest.

4.3          Secret Commissions

Secret commissions or payments occur where a commission from a party acting in a fiduciary capacity (Fiduciary) is taken or solicited without disclosing that commission to that Fiduciary’s principal. The secret commission is given as an inducement to the Fiduciary to use their position to influence the conduct of their principal’s business. Secret commissions are a form of bribery and are prohibited under this Policy.


A secret commission will occur if the Company charges person A a fee for securing a finance facility with Big Bank. Big Bank secretly pays the Company an additional fee for referring A to Big Bank.

4.4          Facilitation Payments

Facilitation payments are minor unofficial payments made to public officials to expedite or secure the performance of routine government action (for example issuing permits or licences). Facilitation payments are a form of bribery and are prohibited under this Policy.

4.5          Dealings with politicians and government officials

All dealings with politicians and government officials which relate to the Company and its business activities must be conducted at arm’s length and with the utmost professionalism, to avoid any perception of attempts to gain advantage or to improperly influence the outcome of an official decision.

You must not make any donation or other financial contribution to any political party or candidate for an election or sponsor any organisations (other than in a purely personal capacity) without seeking and obtaining prior approval from the Secretary.

4.6          Political Contributions

Our People must not make political contributions on behalf of the Company and the Group Members, other than with the prior written approval of the DRC of the Company.

4.7          Charitable Contributions

The Company and the Group Members are committed to the communities in which they do business and encourage and support Our People participating in local community development initiatives, making donations and undertaking volunteer work.

This Policy does not seek to curtail an individual’s freedom to make donations or undertake volunteer work in their personal capacity.

4.8          Compliance with Local Laws

If an officer, employee, contractor or consultant of the Company or a Group Member travels outside of Australia, that person must comply with local laws, codes of conduct, or other regulations in that jurisdiction relevant to bribery and corruption, even if those local laws are more restrictive than this Policy.

5. Your responsibilities

Our People must:

(a)           ensure that they read, understand and comply with this Policy;
(b)           avoid any activity that might lead to, or suggest a breach of this Policy; and
(c)           notify their DRC as soon as possible if they believe or suspect that a conflict with, or breach of, this Policy has occurred, or may occur in the future. Notifications may also be made pursuant to the Company’s Whistleblower Policy.

6. Responsibility for Policy Compliance, Training and Review

The DRC is responsible for the overall administration of this Policy and must periodically monitor the implementation of this Policy and review on an ongoing basis the Policy’s suitability and effectiveness. Internal control systems and procedures are to be audited regularly to ensure that they are effective in minimising the risk of non-compliance with this Policy.

The DRC must notify the Board of the Company and the Board of any relevant Group Member of any material breach of this Policy.

Our People are required to understand and comply with this Policy and to follow the reporting requirements set out in this Policy. To this end, training on how to comply with this Policy will be provided by the Company.

The prevention, detection and reporting of bribery and other improper conduct addressed by this Policy are the responsibility of all those working for or engaged by the Company and the Group Members. Our People should be vigilant and immediately report any breaches or suspicious activity in accordance with this Policy.

7. Review and publication of this Policy

The Board will review this Policy annually to check that it is operating effectively and whether any changes are required to this Policy. This Policy may be amended by resolution of the Board.

This Policy is available on the Company’s website/intranet only. Key features are published on the Company’s intranet.

Adopted by the Board on 19/02/2020

Noel Smith, DRC – Ledge