Anti-Bribery, Anti-Corruption, and Trade Compliance Policy

Upholding Ethical Standards in Every Interaction.

At Intuit Technologies, integrity is non-negotiable. We are committed to conducting our business lawfully, transparently and ethically. This policy outlines our strict stance against bribery and corruption and our compliance with global trade laws, ensuring that every action we take is in line with the highest standards of legal and professional conduct. Below, you’ll find the full details of our Anti-Bribery, Anti-Corruption, and Trade Compliance obligations and expectations.

Intuit Technologies is committed to conducting its business ethically and in compliance with all applicable laws and regulations, including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act (UKBA). This policy outlines our commitment to preventing bribery and corruption and ensuring trade compliance.

Intuit Technologies strictly prohibits bribery or other improper payments in any of its business operations. This prohibition applies to all business activities, anywhere in the world, whether involving government officials or other commercial enterprises. A bribe or other improper payment to secure a business advantage is never acceptable and can expose individuals and Intuit Technologies to possible criminal prosecution, reputational harm, or other serious consequences.

This policy applies to all employees, directors, agents, consultants, and any other third-party representatives acting on behalf of Intuit Technologies.

  • Bribery: Offering, giving, receiving, or soliciting anything of value to influence the actions of an official or other person in discharge of a public or legal duty.
  • Corruption: Abuse of entrusted power for private gain.
  • Trade Compliance: Adherence to all US and global trade laws and regulations, including export controls and sanctions.
  • Gift, Benefit, or Hospitality: Any good or service of value or personal benefit that is over and above employment or engagement entitlements, including promotional items, discounts, tickets to events, and sponsored travel.
  • S. Foreign Corrupt Practices Act (FCPA): A U.S. law that prohibits bribing foreign government officials to gain business advantages and requires accurate financial record-keeping.
  • UK Bribery Act (UKBA): A UK law that prohibits all forms of bribery, including bribing foreign officials, and requires companies to implement procedures to prevent bribery.
  • Consolidated Screening List (CSL): A U.S. government database used to check if individuals or entities are subject to trade sanctions.
  • Sanctioned Customer: A customer identified through the Consolidated Screening List (CSL) or other relevant lists as being subject to trade sanctions or restrictions.
    • Embargoed Countries: North Korea, Cuba, Iran, Sudan, Syria, Crimea, Russia, Belarus and Ukraine (Donetsk & Luhansk regions).

5.1 Offering, promising, or giving a bribe.

5.2 Requesting, agreeing to receive, or accepting a bribe.

5.3 Making facilitation payments to expedite routine governmental actions.

5.4 Offering or accepting excessive gifts, hospitality, or entertainment that could influence business decisions.

5.5 Soliciting gifts or benefits in relation to the performance of duties.

5.6 Accepting monetary gifts such as cash, cheques, or direct deposits.

Intuit Technologies will conduct regular risk assessments to identify and address potential points of vulnerability to bribery and corruption.

Intuit Technologies will conduct quarterly reviews against the International Trade Administration Consolidated Screening List.

Process

All new customers will be reviewed as per the above under Intuit Technologies’ Credit Application Process. The following steps will be undertaken as a part of this process.

  1. New customer to provide BAU details (name, ABN, etc).
  2. Conduct internet search to check if the new customer has any negative media like fraud or bribery.
  3. Conduct internet search to check if owners/directors are PEP (Politically Exposed Person).
  4. Search via the Consolidated Screening List (CSL) Search Register (https://legacy.export.gov/csl-search) to check if the new customer is under sanctions.
  5. Document/screenshot the findings for audit purposes.

Actions if a Customer is Found to be Under Sanctions

If a customer is found to be under sanctions, the following actions will be taken:

  1. Immediately cease all business activities and transactions with the sanctioned customer.
  2. Notify the Compliance Officer and the Senior Leadership Team of the findings.
  3. Conduct a thorough review of any past transactions with the sanctioned customer to ensure compliance with all applicable laws and regulations.
  4. Report the findings to the relevant regulatory authorities as required by law.
  5. Document all actions taken and maintain records for audit purposes.

All employees will receive regular training on an annual basis on anti-bribery and corruption laws and this policy. The policy will be communicated to all third-party representatives.

Employees are encouraged to report any concerns or suspicions of bribery or corruption. Reports can be made confidentially to the Compliance Officer. All reports will be investigated promptly and thoroughly.

Failure to comply with this policy may result in disciplinary action, up to and including termination of employment, and may also result in criminal prosecution.

This policy will be reviewed annually and updated as necessary to ensure its effectiveness.

For any questions or concerns regarding this policy, please contact the Compliance Officer at hr@itechnologies.com.au.