Policy

Anti-bribery and corruption.

Austera Global operates in international resource procurement. Corruption risk in this sector is real, and a policy that does not say anything specific is not a policy.

Draft: pending legal review. Published in draft while Austera Global is being established. It reflects how we operate from the outset and will be reissued once reviewed by an Australian legal adviser.

Reference
AUS-TRC-STA-010
Derived from
AUS-CMP-POL-001
Status
Draft, legal review pending
Applies to
All engagements

Our position

Absolute

  • We do not offer, promise, give, request or accept a bribe, in any form, to or from anyone, whether a public official or a private individual.
  • We do not make facilitation payments. We will accept the delay instead.
  • We do not pay secret commissions. We make no payment and give no benefit to any individual on a buyer's side of a transaction, disclosed or otherwise.
  • We disclose how we are paid. We are remunerated by the supplier and we tell every buyer so, in writing, in our first substantive communication.
  • We do not use an intermediary to do what we would not do ourselves.

Intermediaries

Australian law creates a corporate offence of failing to prevent foreign bribery by an associate acting for a corporation’s benefit, with a defence where the corporation had adequate procedures in place. An overseas distributor, agent or local partner engaged in connection with our work can be such an associate. We treat that as our problem, not someone else’s.

  1. 1

    Risk assessment

    By destination market and by the role the intermediary would play.

  2. 2

    Due diligence

    Entity, ownership, beneficial owners, adverse media, sanctions and restricted-party screening.

  3. 3

    Written terms

    Anti-bribery warranties, audit and information rights, and a right to terminate immediately for breach.

  4. 4

    Payment discipline

    Fees proportionate to services actually performed, paid to the contracting entity's own account in its own jurisdiction, against an invoice. No cash, no third-party payees, no unexplained jurisdictions.

  5. 5

    Records

    Of the diligence, the terms and every payment.

Red flags that stop a transaction

If any of these appear, we stop and escalate. We do not manage them commercially

  • A request for a payment, fee or benefit to an individual
  • An intermediary appearing with no clear function
  • A demand that a specific agent or consultant be used
  • A request to pay a third party or an unrelated jurisdiction
  • A request for cash
  • A request to misstate value or description on documents
  • Fees disproportionate to services performed
  • Resistance to written terms or invoicing
  • A counterparty declining to be named
  • Unexplained urgency around a payment

We would rather lose a transaction than complete one on these terms, and we will say so plainly to the party that raised it.

Gifts and hospitality

Modest, occasional, transparent and never around a live decision. A meal at a meeting is normal; travel, accommodation, entertainment or anything of material value is not accepted and not offered. Anything beyond nominal value is recorded.

Raising a concern

If you believe someone has sought or offered an improper payment in connection with anything Austera Global is involved in, contact us directly. We will respond, we will record it, and we will not retaliate against anyone who raises a concern in good faith. If the concern is about the principal, it should be raised with our external legal adviser, and we will provide those details on request. The full escalation process, including timeframes and where to go if you are not satisfied, is set out on complaints and escalation.

This position sits alongside our other published standards in the trust centre, including the details you can check about the company itself on company verification.