Anti Bribery and Corruption Policy

1. Introduction

   This Privacy Policy describes the manner in which Exposure Pty Ltd and its affiliates (collectively “Exposure”) collect, use, maintain, and disclose information from users of our websites (e.g., https://www.exposure.com.au and from the use of the customer support, development, and training portals linked to our website (the “Portals”). For purposes of this Policy, the terms “user,” “customer”, “you” and “your” are meant to refer to the individuals about whom we may collect data, and at times may be used within the Policy interchangeably. Being an Australian organisation, Exposure is committed to adhere to Australian Privacy Act 1988.

2. Scope

   This policy applies to all individuals who work for or on behalf of the Company, including but not limited to employees, contractors, consultants, agents, intermediaries, and business partners. It covers all our business operations, both within Australia and internationally, and includes interactions with government officials, customers, suppliers, and other third parties.

3. Definitions

   For the purposes of this Policy, the following definitions apply:
   Bribery: The offering, promising, giving, accepting, or soliciting of a benefit or business advantage (financial or otherwise) as an inducement or reward for an individual or entity to act improperly or to secure an improper advantage.
   Compliance Officer: A person appointed by the Company to oversee compliance with this policy.
   Corruption: The abuse of entrusted power for private gain, which includes bribery and other forms of unethical or unlawful conduct.

4. Prohibited Conduct

   The Company strictly prohibits any form of bribery, corruption, or facilitation payments, whether direct or indirect, in any business activity or relationship. This includes but is not limited to:

   1. Offering, promising, giving, or accepting bribes, kickbacks, or improper payments, in cash or any other form, to anyone, including domestic or foreign government officials, customers, suppliers, or any other third party, to influence or obtain improper business advantages.
   2. Making or receiving facilitation payments, which are small payments made to expedite routine actions or processes that are otherwise part of an official's duties.
   3. Creating or using slush funds, off-books accounts, or any other form of undisclosed or unrecorded payments or transactions.
   4. Using third parties, such as agents, intermediaries, or consultants, to facilitate or conceal bribery or corruption.
   5. Conspiracy, aiding and abetting, or complicity in bribery or corruption.
   6. Money laundering.
   7. Engaging in any other conduct that may violate anti-bribery and corruption laws or the principles of fairness, integrity, and transparency.
5. Responsibilities
   1. Management
      1. The senior management of the Company is responsible for setting the tone at the top and promoting a culture of integrity and compliance.
      2. Working with the Compliance Officer, they are accountable for ensuring that all employees, contractors, and stakeholders are aware of and comply with this policy and applicable anti-bribery and corruption laws.
      3. They will also periodically conduct a risk assessment of the Company's operations, activities, and transactions to identify and address potential areas of vulnerability to bribery and corruption.
   2. Employees and Contractors
      1. All employees and contractors are expected to understand and comply with this policy, as well as relevant laws and regulations.
      2. They must avoid engaging in any conduct that may be perceived as bribery or corruption and report any suspected or actual violations to their supervisor, manager, or the designated Compliance Officer
      3. They must avoid situations where they could be influenced, or could be perceived to be influenced, by a personal interest in carrying out otherwise legitimate transactions on behalf of the Company. For more information, see the Company's Conflict of Interest Policy.
   3. Third Parties
      1. The Company expects all third parties, such as agents, intermediaries, and business partners, to comply with this policy and applicable laws.
      2. The Company will conduct due diligence on third parties before engaging in any business relationship, and include anti-bribery and corruption clauses in contracts and agreements.
6. Gifts, Hospitality, and Expenses
   1. Gifts and Hospitality

      The Company acknowledges that giving and receiving gifts, hospitality, and entertainment may be a legitimate part of business relationships, but they should not be used to influence or obtain improper business advantages.

   2. Expenses

      All expense claims must be accurate, supported by valid receipts, and incurred for legitimate business purposes. Falsifying expense claims or using them to cover up bribes or other improper payments is strictly prohibited. The Company's Expense Policy governs the making of claims and expenses to the Company

7. Record-Keeping and Transparency

   The Company maintains accurate records of all financial transactions and business activities and ensures that they are transparent, verifiable, and auditable. All employees and contractors must accurately record all business transactions in the Company's books and records and report any irregularities or suspicions to their supervisor, manager, or the Compliance Officer

8. Reporting, Investigation, and Whistleblower Protection
   1. Reporting Channels

      All employees, contractors, and external business partners are encouraged to report any suspected or actual violations of this policy or applicable anti-bribery and corruption laws. Reports can be made through the following channels:

      Internal Reporting (Employees and Contractors): Report any concerns to your immediate supervisor, manager, or the Compliance Officer. If the supervisor is involved or unavailable, the report should be made directly to the Compliance Officer or the HR department.

      External Reporting (Business Partners and Third Parties): External stakeholders, including suppliers, customers, and other business partners, can report bribery or corruption concerns by contacting the Compliance Officer via email at **compliance@exposuregroup.com.au** or through the dedicated external hotline number **+61 2 9519 7444**.

   2. Anonymous Reporting

      Both internal and external reports can be made anonymously. For more information on how to make an anonymous report, see the Company's Whistleblower Policy

   3. Investigation

      All reported violations will be promptly and thoroughly investigated by the Company's designated investigation team, which will follow established investigation protocols and ensure confidentiality to the extent possible. Employees and contractors are expected to cooperate fully with any investigation and provide accurate and truthful information.

   4. Whistleblower Protection

      The Company is committed to ensuring that no person who reports any actual or suspected violation of this Policy or any applicable anti-bribery and corruption laws in good faith suffers any form of retaliation, discrimination, or adverse employment consequence. Any employee who engages in such retaliation, discrimination, or adverse employment consequence will be subject to disciplinary action, up to and including termination of employment. For more information, see the Company's Whistleblower Policy

9. Consequences of Violations

   Violations of this policy or applicable anti-bribery and corruption laws may result in disciplinary action, up to and including termination of employment or contract, as well as civil or criminal liability. The Company will take appropriate remedial measures to address any confirmed violations, including implementing corrective actions, improving controls, and reporting to relevant authorities as required.

10. Compliance with Laws and Regulations

    The Company is committed to full compliance with all applicable laws and regulations, including anti-bribery and corruption laws in Australia and other countries where we operate. Failure to comply with this policy or applicable laws may result in severe legal consequences for both the individual and the Company.

11. Monitoring and Review

    The Company will periodically review and update this policy to ensure its effectiveness and compliance with changing laws, regulations, and best practices. The Compliance Officer will monitor and assess the Company's compliance with this policy and report to senior management and the board of directors as appropriate.

12. Further Information and Advice

    For further information, contact the Compliance Officer at **ben@exposuregroup.com.au**.

13. Procedures for Handling Attempted Bribery
    1. Purpose

       This section outlines the procedures that employees of Exposure Group must follow if they encounter or suspect any attempt of bribery. The goal is to ensure that all instances are promptly reported, investigated, and addressed in a manner that upholds the company's commitment to ethical conduct and compliance with anti-bribery laws.

    2. Definition of Attempted Bribery

       Attempted Bribery: Any situation where an individual, whether internal or external to the company, offers, promises, or attempts to provide an employee with a bribe. A bribe is defined as any gift, payment, favor, or advantage offered to influence an employee’s actions or decisions in their professional capacity.

    3. Employee Responsibilities

       Rejection: Employees must immediately reject any attempt of bribery. This rejection should be firm and clear, without ambiguity, and the employee should not engage in any further discussion or negotiation with the individual attempting the bribe. Documentation: After rejecting the attempted bribe, the employee must document the incident in detail, including

       1. Date, time, and location of the incident.
       2. The identity of the individual(s) involved, if known.
       3. A description of the bribe offered (e.g., type of gift, amount of money, favor requested).
       4. The specific actions taken by the employee to reject the bribe.
       5. Any witnesses to the incident.
    4. Reporting Procedures

       Immediate Reporting: The employee must report the attempted bribery to their immediate supervisor and the Compliance Officer as soon as possible. If the supervisor is involved or unavailable, the report should be made directly to the Compliance Officer or the HR department.

       Incident Report Form: The employee must complete an Incident Report Form, providing all relevant details about the attempted bribery. This form will be submitted to the Compliance Officer for review and further action.

    5. Investigation Process

       Internal Investigation: Upon receiving a report of attempted bribery, the Compliance Officer will initiate an internal investigation to determine the facts and assess the situation. The investigation may include interviews with the reporting employee, witnesses, and any other relevant parties.

       Confidentiality: The investigation will be conducted with the highest level of confidentiality to protect the integrity of the process and the privacy of all involved parties

       Documentation: All findings from the investigation will be documented, and a report will be compiled detailing the nature of the attempted bribery, the parties involved, and the outcome of the investigation.

    6. Disciplinary Actions and Legal Considerations

       Internal Actions: If the investigation confirms an attempted bribery, the company will take appropriate actions. This may include:

       1. Internal disciplinary actions if an employee was involved in any way
       2. Immediate termination of any business relationship with external parties attempting bribery

       Legal Reporting: Depending on the severity and context of the attempted bribery, the Compliance Officer may recommend reporting the incident to relevant law enforcement authorities. This decision will be made in consultation with legal counsel.

       Follow-Up: The company will implement any necessary corrective actions to prevent future attempts of bribery and may conduct additional training or revise company policies if needed.

    7. Non-Retaliation

       Protection for Reporters: Exposure Group is committed to protecting employees who report attempted bribery in good faith. Any form of retaliation against employees who report such incidents will not be tolerated and will result in disciplinary action.

    8. Training and Awareness

       Employee Training: Regular training sessions will be conducted to ensure that all employees are aware of the procedures for handling attempted bribery and understand the importance of reporting such incidents.

       Ongoing Awareness: The company will periodically reinforce the importance of anti-bribery measures through internal communications and updates to relevant policies.

Approved by:
Date: 15/01/25

This section of the Anti-Bribery Policy ensures that all employees are equipped to handle situations involving attempted bribery with integrity and that the company remains vigilant in maintaining its ethical standards.