ASC Pty Ltd

Based on public information, there is no readily available evidence that the company publishes a statement from the Chief Executive Officer or the Chair of the Board, supporting the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of business conduct, including reference to honesty, trust, openness, and integrity.

Based on public information, there is no readily available evidence that the company belongs to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption.

Based on public information, there is no readily available evidence that the company has appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda. TI notes that the Board has responsibility for monitoring and verifying compliance with ethical standards, and the Business Assurance and Security Committee is responsible for compliance. However, it is not clear where overall responsibility for the ethics and anti-corruption agenda lies.

Based on public information, there is no readily available evidence that the company has appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda.

Based on public information, there is evidence that there is regular Board level monitoring of the performance of the company’s ethics and anti-corruption agenda. The Board monitors and verifies compliance with ethical standards on a regular basis. However, it is not clear that it undertakes major periodic reviews of the agenda. The company therefore scores 1.

Based on public information, there is no readily available evidence that there is a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, and no evidence of improvement plans being implemented when issues are identified.

Based on public information, there is no readily available evidence that the company has a formal process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. TI notes that the company has a Risk Management Framework, but it is unclear if it includes an anti-corruption risk assessment.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents.

Based on public information, there is no readily available evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption.

Based on public information, there is some evidence that the company makes clear to suppliers, through policy and contractual terms, its business standards. However, it is not clear that the company’s ethical standards specifically, and the consequences of breaching these standards, are made clear.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is no readily available evidence that the company has an anti-corruption policy that prohibits corruption in its various forms. TI notes that the company has a Code of Conduct for Directors and Executives, but this is not publicly available.

Based on public information, there is no readily available evidence of a zero-tolerance anti-corruption policy.

Based on public information, there is no readily available evidence that the company’s anti-corruption policy is easily accessible to Board members, employees and contracted staff. TI notes that the company has a Code of Conduct for Directors and Executives. However, this is not publicly available and it is not clear how easily accessible this is for Directors.

Based on public information, there is no readily available evidence that the company’s anti-corruption policy is easily understandable to Board members, employees and third parties. It does not provide a comprehensive overview of the Company’s stance on anti-corruption and applicable employee regulations.

Based on public information, there is no readily available evidence that the company’s anti-corruption policy explicitly applies to all employees and members of the Board.

Based on public information, there is no readily available evidence that the company has a policy on potential conflicts of interest for employees. TI notes that the company has a conflict of interest policy pertaining to Board members, as found in the Board Charter. However, this is not considered to be a comprehensive policy.

Based on public information, there is no readily available evidence that the company has a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery.

Based on public information, there is no readily available evidence of a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery.

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments.

Based on public information, there is no readily available evidence that the company prohibits political contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, or discloses the issues on which the company lobbies.

Based on public information, there is no readily available evidence that the company prohibits charitable contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent.

Based on public information, there is no readily available evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence that the company has a training programme that explicitly covers anti-corruption. TI notes the company’s commitment to training as outlined in the 2013 Annual Report.

Based on public information, there is no readily available evidence that anti-corruption training is provided in all countries where the company operates or has company sites.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions.

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest.

Based on public information, there is no readily available evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.

Based on public information, there is no readily available evidence that the company has multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity.

Based on public information, there is no readily available evidence that the company’s whistleblowing channels are available to all employees in all geographies.

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively.

Based on public information, there is no readily available evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues.

Based on public information, there is no readily available evidence that there is a commitment to non-retaliation for bona fide reporting of corruption.