Bribery, Corruption, and Fraud Policy

The Arbinger Institute Pty Ltd is committed to conducting business ethically and honestly. We are committed to acting when bribery, corruption, and fraud are brought to our attention. The Arbinger Institute Pty Ltd has zero tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships. The Arbinger Institute Pty Ltd will constantly uphold laws relating to anti-bribery and corruption.

To whom does this policy apply?

This policy applies to all employees, managers, and owners of The Arbinger Institute Pty (South Africa), including temporary or contract employees. Employees must ensure that they do not become involved in any way in the payment of bribes. This policy sets out the minimum standards (as a basis of any other relevant legislation that might be applicable) to which all The Arbinger Institute Pty Ltd employees must always adhere.

Definitions

Bribery can be described as giving or receiving anything from any person (usually money, a gift, loan, reward, favour, commission, or entertainment) as an improper inducement or reward for obtaining business or employment, or any other benefit.

Company Commitment

All Arbinger Institute Pty Ltd employees must adhere to the company ethos. No employee or manager will be expected to take part or become involved in any form of bribery, corrupt behaviour, or fraud, including the following:

• Attempt to mislead or induce any person to do something illegal or which goes against the company ethos.
• Fraudulent practices against the company ethos or legislation.

The Arbinger Institute Pty Ltd is committed to removing and combatting any inappropriate behaviour immediately (when it becomes known to the company) and will not tolerate such behaviour from employees, managers, or customers/clients in any way or form. This policy binds the company to its commitment to regularly discuss and mitigate factors related to bribery, corruption, or fraudulent behaviour.