Anti-bribery policy

Policy Summary

1. Purpose
The purpose of this policy is to establish controls to ensure compliance with all applicable
anti-bribery and corruption regulations, and to ensure that the Company’s business is
conducted in a socially responsible manner.

Details of policy

 2. Policy statement
Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. It is our policy to conduct all of our business in an honest and ethical manner. We take a zero tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships by implementing and enforcing effective systems to counter bribery. We will uphold all laws relevant to countering bribery and corruption in Australia.

3. Scope
Who is covered by the policy?
In this policy, third party means any individual or organisation we come into contact with during the course of our activities, and includes actual and potential clients, business contacts, agents, and government and public bodies. This policy applies to all officers, members andpartners engaged by Save Ethiopia, collectively referred to as personnel.

This policy covers:

 Bribes
 Gifts and hospitality
 Charitable contributions

Bribes
Personnel must not engage in any form of bribery, either directly or indirectly.
Gifts and hospitality
Personnel must not offer or give any gift or hospitality:

 which could be regarded as illegal or improper, or which violates the recipient’s policies or
 to any public employee or government officials or representatives.
Employees may not accept any gift or hospitality from any business associates unless previously authorised by one of the directors.
Charitable contributions
Charitable support and donations are acceptable (and indeed are encouraged), whether of knowledge, time, or direct financial contributions. However, personnel must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery.

4. Your responsibilities
You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those associated with Save Ethiopia as officers, members, partners and donors. All members of Save Ethiopia are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify office holders of Save Ethiopia as soon as
possible if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future. Personnel who breaches this policy will face disciplinary action, which could result in sanction for gross misconduct in accordance with the constitution of Save Ethiopia. We
reserve our right to terminate our contractual relationship with our partners if they breach this policy.

5. How to raise a concern
You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries or concerns, these should be raised with an office holder of Save Ethiopia.

6. What to do if you are a victim of bribery or corruption
It is important that you tell an office holder of Save Ethiopia as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.

7. Protection
Personnel who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under
this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of refusing
to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future.

8. Training and communication
Training on this policy forms part of the induction process for all new officers and relevant members. All existing officers and responsible members will receive regular, relevant training on how to implement and adhere to this policy. In addition, all employees will be asked to formally accept conformance to this policy on an annual basis. Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.

9. Who is responsible for the policy?
The directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all personnel comply with it.
The board members have primary and day-to-day responsibility for implementing this policy, and for monitoring its use and effectiveness and dealing with any queries on its interpretation.

10. Monitoring and review
The board of directors Manager will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption. All personnel are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.

Personnel are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Board of Directors of Save Ethiopia Ltd.

.