ChangePlan Anti-Corruption Policy

Updated January 2025

1. Purpose

ChangePlan Pty Ltd is committed to conducting business with integrity, transparency, and in compliance with all applicable anti-corruption laws, including the Australian Criminal Code Act 1995 (Cth) and relevant international regulations, such as the UK Bribery Act and the US Foreign Corrupt Practices Act.

2. Scope

This policy applies to all ChangePlan employees, contractors, agents, and third parties acting on behalf of the company.

3. Prohibited Conduct

ChangePlan strictly prohibits:

  • Offering, giving, or accepting bribes, kickbacks, or other improper payments to secure business advantages.
  • Facilitation payments, regardless of local customs or practices.
  • Any form of corruption, fraud, or unethical behavior in business dealings.

4. Gifts, Hospitality, and Expenses

Reasonable and proportionate gifts and hospitality are allowed if they:

  • Serve a legitimate business purpose.
  • Do not influence or appear to influence business decisions.

All gifts or hospitality above AUD 200 must be approved by management and recorded.

5. Conflicts of Interest

All employees and contractors must disclose any personal, financial, or other interests that could influence their decision-making or create an appearance of impropriety.

6. Third-Party Due Diligence

ChangePlan requires appropriate due diligence to be conducted on all third parties, including suppliers, agents, and contractors, to ensure compliance with anti-corruption laws. Agreements with third parties must include provisions to uphold anti-corruption standards.

7. Record-Keeping

ChangePlan will maintain accurate records of all financial transactions, including gifts, hospitality, and expenses, to ensure transparency and compliance with anti-corruption laws.

8. Reporting Violations

ChangePlan encourages the reporting of suspected corruption or unethical behavior. Reports can be made anonymously to compliance@changeplan.co. Retaliation against whistleblowers is strictly prohibited.

9. Risk Assessments

ChangePlan will regularly assess corruption risks in its operations and implement measures to mitigate identified risks.

10. Oversight and Responsibility

The responsibility for overseeing this policy lies with ChangePlan's Compliance Officer, who will ensure it is effectively implemented and regularly reviewed.

11. Jurisdictional Compliance

ChangePlan complies with anti-corruption laws in all jurisdictions where it operates. In case of conflict between local laws and this policy, the stricter standard will apply.

12. Training and Monitoring

ChangePlan will provide anti-corruption training and ensure regular monitoring of compliance with this policy.

13. Periodic Review

This policy will be reviewed annually or as required to ensure continued effectiveness and alignment with evolving legal and regulatory requirements.

14. Consequences of Non-Compliance

Violations of this policy may result in disciplinary action, including termination of employment or contracts, and may be reported to relevant authorities where required.

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