Andean Mining recognises that bribery and corruption has an adverse effect on communities wherever they occur. Bribery and corruption has the ability to impede economic growth and undermine accountability, threaten laws, democratic processes and basic human freedoms, impoverishing states and distorting free trade and competition. Corruption is often associated with organised crime, money laundering and, on occasions, the financing of terrorism.
Andean Mining have zero tolerance for bribery and corruption and are committed to identifying and preventing bribery and corruption through the implementation of an education program.
Our Anti-bribery and corruption Policy supports our zero tolerance towards bribery, corruption and facilitation payments.
Our Policy is designed to comply with the Australian Criminal Code Act 1995 and all other related laws relevant to the locations in which the Group operates.
Amongst the key principles of the Policy, it should be noted that:
- The Group has zero tolerance towards bribery, corruption and facilitation payments
- The giving, receiving, offering, promising, requesting or authorising of a bribe is expressly prohibited
- Business activities must be transparent, sufficiently documented and above suspicion
- The Group has a whistleblower policy which provides for a safe environment in which concerns can be raised
The Company will conduct due diligence on employees and on those who are doing business with, or on behalf of, the Group. Our Policy principles extend to all employees, Directors, temporary staff, contractors, suppliers, service providers, agents and other third parties acting for or on behalf of the Group.
This policy applies to all employees and contractors engaged by the Group, collectively referred to as personnel.
This policy covers the following;
Personnel must not engage in any form of bribery, either directly or indirectly.
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 the Managing Director or in his absence the Chairman of Andean Mining.
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. All contributions must be authorized by the Managing Director or in his absence the Chairman of Andean Mining.
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 working for Andean Mining.
All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your manager 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. If your manager believes that a material breach of this policy has occurred, then they must report this fact to the Company Secretary who, in turn, is responsible for notifying the Board (or the relevant Board committee).
Personnel who breach this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy.
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 your manager.
Training on this policy forms part of the induction process for all new employees. All existing employees 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.
The Managing Director 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.
Andean Mining says ‘no’ to all forms of bribery and corruption in any form. The Company’s position on bribery and corruption is ‘zero tolerance’. The Company obeys the law in whatever jurisdiction it operates and does not condone bribery or corruption in any form.
At Andean Mining we:
- conduct all business in an honest and ethical manner;
- are committed to acting professionally, fairly and with integrity in all business dealings and relationships;
- do not permit the making of any inappropriate promises, gifts or excessive hospitality to Foreign Public Officials in order to achieve unfair advantage or benefit; and
- resist any efforts made by others (including suppliers, customers or clients) to unfairly affect any official decision making process in order to achieve unfair advantage or benefit.
Andean Mining’s employees and Agents must:
- conduct all business in an honest and ethical manner.
- be committed to acting professionally, fairly and with integrity in all business dealings and relationships;
- not permit the making of any inappropriate promises, gifts or excessive hospitality to Foreign Public Officials in order to achieve unfair advantage or benefit; and
- resist any efforts made by others (including existing or potential suppliers, customers or clients) to unfairly affect any official decision making process in order to achieve unfair advantage or benefit.
We encourage [charitable donations/sponsorships] only when they are ethical and legal under local laws and practices. We will not tolerate or condone contributions to political parties. We do not condone facilitation payments as a means of doing business.
We expect our business partners and agents to implement and enforce effective systems to counter bribery. We will always report and document any breach of the law that is brought to our attention through the reporting mechanism provided by authorities in the jurisdictions in which we operate.
