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Anti-bribery and Corruption Policy

1) Policy Purpose
Linfox Armaguard is committed to the highest level of ethical behaviour and standards and has zero tolerance for bribery and corruption in any form. Linfox Armaguard has a reputation built on Loyalty, Integrity, Fairness and Trust (the LIFT values).
Bribery and other types of corrupt conduct set out in this Anti-bribery and Corruption Policy (Policy) are serious criminal and civil offences for both the company and any individuals involved and has the potential to cause significant damage to Linfox Armaguard’s reputation.
This Policy:
a) provides detail of conduct which gives rise to bribery or other corrupt practices, and which is prohibited by Linfox Armaguard;
b) outlines the requirements for reporting and training; and
c) provides a summary of other policies Linfox Armaguard has in place and their role in preventing bribery.

2) Scope
This policy applies to all directors and officers, employees and team members of the Linfox Armaguard Group including Linfox Armaguard Pty Ltd (ACN 099 701 872) and its subsidiaries:
• Point 2 Point Secure Pty Ltd (ACN 149 376 116)
• Integrated Technology Services Pty Ltd (ACN 079 514 917),
• Armaguard Technology Solutions Pty Ltd (ACN 601 253 187)
• ACM New Zealand Limited (NZCN 2194349);
• Integrated Technology Solutions Limited (NZCN 1299587); and
• Global Integrated Solutions Limited (NZCN 2227543) (together Linfox Armaguard).
In addition, Linfox Armaguard expects third parties who perform services for or on behalf of Linfox Armaguard to abide by the standards in this Policy. This includes contractors, agents, advisors, consultants and other types of suppliers (Applicable Third Party).
Armaguard operates in Australia, New Zealand and Thailand and this Policy covers any activity or behaviour undertaken in connection with Linfox Armaguard arising, directly or indirectly, out of its business activities and within its supply chain, both nationally and internationally. 

3) Prohibited Conduct
Linfox Armaguard prohibits all forms of:
a) bribery;
b) facilitation payments;
c) secret commissions or payments; and
d) money laundering, whether involving a Public Official, private company or individual, and whether directly or indirectly through an Applicable Third Party.
Although Linfox Armaguard does not distinguish between Public Officials and private companies or individuals, we recognise that Public Officials are often subject to additional restrictions. Particular care must therefore be taken in dealings with Public Officials.

4) What does prohibited conduct mean?
Bribery
occurs when a person offers, promises, gives, requests or accepts a benefit or something of value with the intention of improperly influencing a person in order to obtain or retain business or an advantage that is not legitimately due.
Bribery can:
a) involve a benefit that is monetary or non-monetary and can include non-cash gifts, cash or cash equivalents (e.g. gift vouchers), political or charitable donations, loans, reciprocal favours, business or employment opportunities, promotional expenditure and corporate hospitality and travel;
b) occur even if the benefit that is given or offered indirectly to the person sought to be influenced, for instance to a business associate or family member;
c) occur irrespective of whether the bribe is accepted or ultimately paid.
Merely offering a bribe will be a contravention of this Policy and will usually be enough for an offence to be committed

Facilitation payments are unofficial payments made to secure or expedite the performance of a routine government action by a Public Official or employee. Secret commissions or payments occur when an agent accepts money or other benefits from a third party in return for showing favour to that party in the conduct of their principal's business without revealing that payment to their principal.
Money laundering occurs when a person or entity conceals the existence of an illegal source of income and then disguises that income to make it appear legitimate.
Public Official refers to any government or public official in Australia or any other country. This can include: 

a) persons holding a legislative, executive, administrative or judicial office;
b) an employee, official or contractor of, or person acting in an official function or capacity for a government or public body (including a military or police force), a government-owned or government-controlled enterprise (including a state-owned enterprise), or a public international organisation;
c) a political party or party official or candidate for political office; persons holding an appointment, position or office created by custom or convention (including potentially some tribal leaders or member of a royal family); or
d) an authorised intermediary or agent of any person covered above.

5) When are gifts, offers of entertainment, travel, hospitality or donations allowed?
Bribery can sometimes occur when gifts, offers of entertainment, travel, hospitality or donations are given or received. No gifts, entertainment, travel, hospitality, donations or other expenditure may be provided with the intent to obtain an improper advantage.
For this reason, Linfox Armaguard has the following rules in place to protect team members:
a) Linfox Armaguard prohibits the receipt of material gifts from suppliers or third parties to improperly obtain or retain business, secure an improper advantage, influence you to act improperly or for any other improper purpose;
b) Offers from suppliers to attend events or entertainment are permitted only with approval from your line manager;
c) You must never improperly ask a supplier for gifts, entertainment or to support personal fundraising efforts;
Linfox Armaguard prohibits company paid attendance at an event hosted by a political party unless specifically approved by your Executive Team Leader.

6) Dealings with third parties
Applicable Third Party arrangements may pose anti-bribery and corruption risk. Linfox Armaguard may have liability for violations of applicable anti-bribery and corruption laws by some of its Applicable Third Parties.
Linfox Armaguard team members must not engage or pay an Applicable Third Party knowing or suspecting they may use or offer any part of the payment as a bribe, secret commission or other form of improper payment.
Linfox Armaguard must only enter into Applicable Third Party arrangements if:
• there is a legitimate business need;
• compensation does not exceed fair market value, an dthe arrangement is permitted by applicable laws and complies with this Policy and other Armaguard policies referenced below.
Linfox Armaguard team members that engage Applicable Third Parties must maintain oversight of the work conducted, be alert to signs of improper payments and practices, and immediately report any suspected or identified behaviour that breaches the standards in this Policy.
All dealings with Applicable Third Parties must be conducted in accordance with Linfox Armaguard’s Supplier Management Policy.

7) Consequences of a breach
A breach of this Policy could be regarded as serious misconduct, leading to disciplinary action, which may include termination of employment or termination of contractual arrangements. Breaches of this Policy may also expose an individual to criminal and civil liability and could result in imprisonment or in the imposition of a significant financial penalty.

8) Reporting breaches and suspicious behaviour
All Linfox Armaguard team members are expected to immediately report actual or suspected violations of this Policy, including any attempts by third parties to engage in prohibited conduct with Linfox Armaguard. Linfox Armaguard fosters a culture of speaking up to encourage reporting of any breach of this Policy, or other concerns. Linfox Armaguard has a Whistleblower Policy that enables any person who has reasonable grounds to suspect that potential misconduct has occurred or is occurring within or against Linfox Armaguard Group to make a report, without fear of reprisal.

9) Compliance reporting
Material breaches of this Policy must be escalated immediately to the General Counsel, and for serious breaches to the Chair of the Risk and Audit Committee.

10) Access to Policy
A copy of this Policy must be:
a) made available to all directors and team members, and to individuals employed by any entities effectively controlled by Linfox Armaguard, when they commence with Linfox Armaguard; and
b) made available to view and download from Linfox Armaguard’s website and its intranet.

11) Policy implementation and effectiveness
The Chief Executive Officer (CEO) will have the primary day-to-day responsibility for the implementation of this policy, monitoring its use and ensuring that the appropriate processes and procedures are in place and amended as applicable, to ensure it can operate effectively.

The General Counsel and delegate will monitor the implementation of this Policy and will review on an ongoing basis the Policy's suitability and effectiveness.
This Policy will be reviewed annually to:
a) ensure reports or breaches are appropriately recorded, investigated and responded to;
b) ensure that this Policy continues to operate effectively and that adequate internal control systems are in place; and
c) confirm whether any changes are required to the Policy.
Material amendments must be approved by Linfox Armaguard’ Board.


14. Other relevant Armaguard Group Policies
This policy should be read in accordance with the following other Armaguard Group Policies:
a) Code of Conduct Policy;
b) Whistleblower Protection Policy;
c) Modern Slavery Policy;
d) Supplier Management Policy; and
e) Conflict of Interest Policy

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