Anti-Bribery and Corruption Policy (2021)

any other person associated with us, or any of our subsidiaries or their employees,
wherever located (collectively referred to as workers in this policy).
4. Definitions
a. Bribery is offering, promising, giving or accepting any financial or other advantage, to
induce the recipient or any other person to act improperly in the performance of their
functions, or to reward them for acting improperly, or where the recipient would act
improperly by accepting the advantage.
b. Corruption is the abuse of entrusted power or position for private gain. Examples:
i. offering a bribe (eg. you offer a potential business partner tickets to a major
sporting event, but only if they agree to do business with us);
ii.
iii.
receiving a bribe (eg. a supplier gives your nephew a job, but makes it clear that
in return they expect you to use your influence in our organisation to ensure we
continue to do business with them);
bribing a foreign official (eg. you arrange for the organisation to pay an additional
payment to a foreign official to speed up an administrative process, such as
clearing items through customs).
5. Hospitality and Gifts
a. This policy does not prohibit normal and appropriate hospitality (given and received to or
from third parties and the giving or receipt of gifts).
b. Normal and appropriate hospitality and gifts would include where the hospitality or gift:
i. is not made with the intention of influencing a third party to obtain or retain
business or a business advantage, or to reward the provision or retention of
business or a business advantage, or in explicit or implicit exchange for favours
or benefits;
ii.
iii.
iv.
complies with local law;
is given in Society’s name, not your name;
does not include cash or cash equivalent (such as gift certificates or vouchers);
v. is appropriate in the circumstances (for example, in the UK it is customary for
small gifts to be given at Christmas time);
vi.
taking into account the reason for the gift, is of an appropriate type and value and
given at an appropriate time;
vii. is given openly, not secretly; and
viii. is not offered to, or accepted from, government officials or representatives, or
politicians or political parties, without the prior approval of the Compliance
Manager.
c. We appreciate that practice varies between countries and regions and what may be
normal and acceptable in one region may not be in another. The test to be applied is
whether in all the circumstances the gift, hospitality or payment is reasonable and
justifiable. The intention behind it should always be considered.
Society Ltd & Society US Inc – Staff Handbook (Last updated on Wednesday, 23 September 2020) Page 93