Aspen Circle

Anti-bribery policy

Aspen Medical’s Anti-bribery policy sets a zero-tolerance standard for bribery and forms part of a broader compliance program designed to uphold integrity across all operations and projects.
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This Anti-bribery policy will be implemented as part of a broader anti-bribery program that will include:

  • commitment and support from the Board of Aspen Medical
  • formal Risk Assessment of the bribery risks inherent in each project
    - the Risk Assessment will be reviewed annually and more frequently where the risk is rated as ‘High or Extreme’
    - the Risk Assessment results will be reported to the Board.
  • inclusion and maintenance of the anti-bribery principles in the Aspen Medical Code of Conduct. Staff will be required to re-affirm the Code of Conduct annually as part of the Performance Appraisal process
  • on-line education program for those staff identified at risk of bribery.
  • reporting of suspected bribery activity in the incident reporting program.

Scope

This policy applies to all Aspen Medical, and its subsidiaries, staff, officers, agents, and contractors.

Definitions and abbreviations

Bribery means any advantage and is not limited to property, and includes facilitation payments.

Business advantage means an advantage in the conduct of business.

Foreign Public Official is defined very broadly under the Act and includes an employee or official of a foreign government body.

References

  • AMCPP01 Code of Conduct

Implementation

Principles

Aspen Medical will not pay bribes in any circumstances. Aspen Medical, the Board and Managers will forego contracts rather than pay bribes.

Policy

Aspen Medical staff will not offer a bribe to any foreign public official in order to gain a business advantage. No Aspen Medical staff will suffer demotion, penalty, or other adverse consequences for refusing to pay bribes even if such refusal may result in the company losing business. Proven violations of this policy by managers and/or employees will result in sanctions up to and including termination of employment.

Proven violations may also result in criminal sanctions. Aspen Medical staff are required to report any activities in which bribery may be suggested or suspected, including being asked to pay a bribe or the payment of bribes, to their manager. All bribery activities will be reporting using the Aspen Medical incident reporting software (RiskMan).

Training will be provided for Aspen Medical staff.

  • The on-line training module will be developed and administered by ‘In-house Counsel’.
  • Records kept will include:

    - the number of facilitation payments made and the details of these payments
    - the percentage of required staff who have completed the on-line training module
    - other activities as described in 4 above.

Administration and record keeping

The responsible Aspen Medical officer for the implementation of this policy is ‘In-house Counsel’

  • The on-line training module will be developed and administered by ‘In-house Counsel’.
  • Records kept will include:

    - the number of facilitation payments made and the details of these payments
    - the percentage of required staff who have completed the on-line training module
    - other activities as described above.