Anti-corruption

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At Efic we have a zero tolerance approach to corruption. Our anti-corruption initiatives are designed to ensure we do not support transactions involving bribery.

Anti-corruption framework

Our comprehensive framework of anti-corruption policies and procedures promotes an active understanding of our anti-corruption obligations at every level of the organisation.

Policy / procedure

Purpose

Anti-Corruption Policy

Outlines to staff their principal obligations in deterring and preventing bribery and corruption

Anti-Bribery and Corruption Procedure

Outlines the procedures that staff should follow to ensure we comply with our obligations under the OECD Council Recommendation on Bribery and Officially Supported Export Credits

Anti-Money Laundering and Counter Terrorism Financing (AML/CTF) Program

This program is designed to ensure we can detect and prevent money laundering and terrorism financing. From a transaction perspective, it requires detailed due diligence of each new transaction, including ‘knowing your customer’ review. We conduct ongoing customer due diligence on an annual basis, or more frequently if circumstances warrant. The program also provides a framework for identifying and reporting suspicious activities to AUSTRAC

Fraud Control Policy

Outlines controls for minimizing and preventing fraud and procedures for detecting and dealing with fraud

Incident and Breach Escalation Policy

Establishes an internal reporting and escalation process for staff members to alert the Executive and relevant Government authorities of possible criminal conduct

Public Interest Disclosure Policy and Procedure 

Provide mechanisms for Commonwealth public officials to bring wrongdoing to Efic’s attention

Code of Conduct

Includes a Gifts Policy that defines the circumstances in which it is appropriate for Efic employees to give and receive gifts and sets out a system for the disclosure and monitoring of such decisions.

Compliance training

Annual, mandatory training for staff, which includes anti-corruption, fraud awareness, anti-money laundering and counter-terrorism financing training

We continually review and improve our anti-corruption framework to ensure it remains relevant and effective.

OECD Anti-bribery recommendations

As a member of the Export Credits Group (ECG) of the OECD, we comply with the OCED Council Recommendation on Bribery and Officially Supported Export Credits. The OECD Anti-bribery Recommendation outlines measures to be taken by ECG members to deter and combat bribery in connection with officially supported export credits. We go beyond these obligations by applying these disciplines to a broader range of products.

One of our obligations under the OECD Anti-bribery Recommendations is to raise awareness among our clients of the legal consequences of engaging in bribery in international business transactions. Bribing a foreign public official is a serious criminal offence that carries heavy penalties.

In 2014, the Australian Government introduced a foreign bribery online learning module. The module is for industry and government, and provides advice on Australia’s anti-bribery policy, relevant laws and how they apply, and steps that business can take to help promote compliance. To access the module, and for more information, visit the Attorney-General’s Department

Whole-of-government initiatives

We have been an active participant in the Australian Government’s consultation process to develop a National Anti-Corruption Plan. This plan is a whole-of-government policy designed to position Australia to deliver a coordinated approach to fighting corruption.

We contribute to other related whole-of-government initiatives, including the Parliamentary Committee inquiry into the integrity of overseas Commonwealth law enforcement operations.

Transparency International Australia

We are a member of Transparency International Australia (TIA), the local chapter of Transparency International. Transparency International is a global not-for-profit, non-government organisation focused on curbing corruption. We regularly engage with TIA, at informal meetings and at TIA events.