Anti-Bribery and Corruption (ABC) Policy
First Contact Pty Ltd – Governance Document
Document Control
Policy Title | Anti-Bribery and Corruption (ABC) Policy |
Policy ID | FC-GOV-ETH-001 |
Policy Owner | Head of Governance and Risk |
Executive Sponsor | John Ortner, Managing Director |
Approval Authority | Executive Steering Committee (ESC) |
Effective Date | 2025-02-01 |
Next Review Due | 2025-02-01 + 12 months |
Applies To | All employees, executives, contractors, suppliers and third-party partners |
Distribution | Internal (Mandatory) – External (Policy Summary Available on Website) |
Storage Location | FC Hub → Governance & Compliance → Policy Register |
Version History
Version | Date | Author | Approved By | Change Description |
V1.0 | 2025-02-01 | Governance & Strategy | John Ortner | Initial policy aligned to ABC Act, ISO 37001, ESG risk frameworks |
Related Policies and Documents
Reference Code | Document Name |
FC-GOV-ESG-002 | ESG and Sustainability Policy |
FC-GOV-WHISTLE-001 | Whistleblower Protection Policy |
FC-HR-CODE-001 | Code of Conduct |
FC-GOV-PROC-003 | Procurement and Ethical Sourcing Policy |
FC-GOV-ML-004 | Anti-Money Laundering Policy |
1. Purpose
This policy outlines First Contact’s zero-tolerance approach to bribery, corruption and unethical conduct in all forms. It ensures compliance with local and international laws, protects the integrity of our operations, and upholds the ethical standards expected by our people, clients, and stakeholders.
2. Scope
This policy applies to all:
- Directors, executives, employees (permanent and temporary).
- Contractors, consultants, and agency workers.
- Vendors, suppliers, and business partners acting on First Contact’s behalf.
- Geographies in which we operate (including Australia, Singapore, United States).
It applies to all business activities including client engagements, procurement, recruitment, vendor management, contract negotiation, and government or regulatory interactions.
3. Legal and Regulatory Compliance
First Contact complies with all applicable anti-bribery and corruption legislation in the jurisdictions we operate, including but not limited to:
- Australia: Criminal Code Act 1995 (Cth), Corporations Act 2001 (Cth).
- Singapore: Prevention of Corruption Act.
- United States: Foreign Corrupt Practices Act (FCPA).
- United Kingdom (where relevant): UK Bribery Act 2010.
- ISO 37001: Anti-Bribery Management Systems standard (referenced for best practice).
We are committed to upholding our obligations under ESG, modern slavery and ethical governance frameworks relevant to our clients and across industries we serve.
4. Prohibited Conduct
The following activities are strictly prohibited:
- Offering, giving, receiving or soliciting anything of value (financial or non-financial) to improperly influence a decision or secure a business advantage.
- “Facilitation payments” or “grease payments” — unofficial payments to secure routine government actions.
- Kickbacks, secret commissions or improper rebates.
- Bribes to public officials, clients, or commercial partners.
- Use of third parties to make prohibited payments or engage in corrupt behaviour.
- Falsifying records, misrepresenting expenses or disguising improper payments.
5. Gifts, Hospitality and Entertainment
First Contact recognises that modest, transparent business hospitality may be appropriate in certain contexts. However:
- All gifts, hospitality or entertainment must be reasonable, proportionate, and transparent.
- Anything valued over AUD $250 must be declared and recorded in the Gifts and Hospitality Register.
- Under no circumstances may gifts or hospitality be used to influence a decision or create an obligation.
- Special caution must be exercised with public officials and government contracts.
Further guidance is available in the FC Conflict of Interest and Ethics Guidelines.
6. Due Diligence and Third Parties
We apply a risk-based approach to third-party relationships, including:
- Screening new suppliers, intermediaries and agents for ABC risk factors.
- Including ABC clauses in contracts and tenders.
- Requiring high-risk partners to complete conflict-of-interest and anti-corruption declarations.
- Monitoring compliance and performance during the term of the engagement
7. Roles and Responsibilities
Role | Responsibility |
All Employees | Comply with this policy and report concerns |
Line Managers | Promote a culture of ethics and transparency |
Procurement & Commercial Leads | Conduct due diligence on third parties |
Executive Team | Set the tone and lead by example |
Governance Team | Maintain registers, training and compliance checks |
ESC | Oversight and governance reporting |
8. Reporting and Whistleblowing
Suspected breaches of this policy must be reported immediately.
- Internal reports can be made to the Head of Governance, the Managing Director, or your manager
- Anonymous reports may be submitted via the Whistleblower Hotline or FC Integrity Form.
- All reports will be investigated confidentially and without retaliation.
This policy works in conjunction with the FC Whistleblower Protection Policy.
9. Training and Awareness
All employees will complete mandatory anti-bribery and corruption training during onboarding and annually thereafter. Specialised training is provided to procurement, sales, executive and offshore teams.
Training completion will be tracked via the FC Hub and reported as part of ESG compliance.
10. Breaches and Consequences
Breaches of this policy are taken seriously and may result in:
- Disciplinary action (including termination).
- Contract termination for third parties.
- Regulatory reporting.
- Legal prosecution under local or international law.
11. Review and Continuous Improvement
This policy will be reviewed annually or sooner if:
- Legal or regulatory changes occur.
- Operational risks or breaches are identified.
- Required by audit, ESG or board directives.
12. Sign-Off and Approvals
Author:
Governance & Strategy
Date: 2025-02-01
Policy Owner:
Helen Kostakos, Group Administration Manager | Governance and Risk
Signature: ______________________
Approved by:
John Ortner, Managing Director
Signature: ______________________
Date Approved: 2025-03-01
Anti-Bribery and Corruption Statement (Website)
First Contact
Our Commitment to Integrity
At First Contact, we are committed to conducting business honestly, transparently and lawfully. We maintain a zero-tolerance stance on bribery, corruption and unethical conduct — in every region where we operate, and across every level of our organisation.
As a provider of workplace experience, recruitment and advisory services, trust is the foundation of our business. That’s why we embed ethical standards in how we engage clients, manage suppliers, and lead our teams — across Australia, Singapore, the United States and beyond.
What We Stand Against
We strictly prohibit:
- Bribery of public officials, clients or commercial partners.
- Facilitation payments, kickbacks, or secret commissions.
- Undisclosed conflicts of interest or improper influence.
- Misrepresentation of expenses or financial records.
This applies to all First Contact employees, contractors, agents, suppliers and representatives.
Our Governance Practices
To protect our people, clients and business, we have:
- A formal Anti-Bribery and Corruption Policy, aligned with global legislation and ISO 37001 standards.
- Annual employee training on ethics and anti-corruption.
- Screening processes for suppliers and third parties.
- Declaration of all gifts, hospitality and entertainment.
- An independent Whistleblower reporting channel, available to staff, clients and the public.
Raising Concerns
If you suspect any form of unethical or corrupt conduct relating to First Contact:
- Submit a confidential report via our [Integrity Reporting Form].
- Or review our [Whistleblower Protection Policy] for more information.
All reports are treated seriously and investigated confidentially.
Doing Business with Integrity
We know that ethical conduct is essential to building long-term partnerships and delivering exceptional outcomes. We invite our clients, suppliers and stakeholders to uphold these same standards — so that together, we foster workplaces built on trust, transparency and integrity.
For more information, please contact our Governance and Risk team at:
[Insert Contact Form Link or Internal Routing Page]
Anit-Bribery and Corruption Policy – Summary (Tenders)
First Contact Pty Ltd
Our Commitment
First Contact Pty Ltd maintains a strict zero-tolerance approach to bribery, corruption, facilitation payments and unethical conduct in all forms. We are committed to upholding the highest standards of integrity, transparency and lawful behaviour in every market and service area we operate in — across Australia, Singapore, the United States and beyond.
Scope
This policy applies to all:
- Employees, contractors, directors and executives.
- Agents, suppliers, consultants and third-party representatives.
- Business activities including recruitment, procurement, sales, contract negotiation and public sector engagement.
What Is Prohibited
- Offering, giving, requesting or receiving bribes or “kickbacks”.
- Facilitation payments to expedite approvals or decisions.
- Undisclosed conflicts of interest or preferential treatment.
- Manipulation of financial records or misrepresentation of expenses.
- Using third parties to indirectly engage in corrupt conduct.
Our Controls
To ensure compliance and mitigate risk, First Contact has implemented:
- A formal Anti-Bribery and Corruption Policy (FC-GOV-ETH-001).
- ISO 37001–aligned internal governance measures.
- Gifts and Hospitality Register (threshold: AUD $250).
- Supplier and third-party due diligence processes.
- Annual ABC training for all employees via FC Hub.
- A protected Whistleblower channel for confidential reporting.
Reporting and Enforcement
Suspected breaches must be reported immediately to:
- Your manager.
- Head of Governance and Risk.
- The Whistleblower Integrity Form (anonymous available).
All reports are investigated confidentially. Breaches may result in disciplinary action, contract termination, or legal referral.
Key Contacts
- Governance & Risk Team: [Insert internal email or contact form].
- Whistleblower Reporting Portal: [Insert link or internal platform].
First Contact expects every employee, supplier and partner to uphold these principles and take an active role in maintaining a culture of integrity.
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