Anti‑Bribery & Corruption Policy

1. Purpose

Divergent Edge Strategies ("we", "our", "us") is committed to conducting all business activities ethically, honestly, and in full compliance with applicable anti‑bribery and corruption laws. This policy aims to:

• Prevent bribery, corruption, and unethical business conduct
• Protect our reputation for integrity and transparency
• Ensure compliance with the Criminal Code Act 1995 (Cth), relevant state legislation, and international anti‑bribery frameworks

2. Scope

• All employees, contractors, directors, suppliers, and third parties acting on our behalf, whether in Australia or overseas
• All business dealings, including client engagements, procurement, sponsorships, and partnerships

3. Definitions

• Bribery: Offering, giving, receiving, or soliciting something of value to influence the actions of another person in an improper manner
• Corruption: Abuse of entrusted power for private gain
• Facilitation Payment: A small payment to speed up a routine government action — these are prohibited under Australian law

4. Policy Statement

We have a zero‑tolerance approach to bribery and corruption. This applies to both public and private sector dealings. Employees and contractors must:

• Never offer, give, solicit, or accept bribes
• Never engage in facilitation payments
• Avoid gifts or hospitality that could be perceived as influencing a decision
• Conduct all business dealings transparently and in good faith

5. Gifts, Hospitality & Entertainment

Acceptable:

• Low‑value promotional items (e.g., company‑branded stationery)
• Modest meals or refreshments in a business context

Not acceptable:

• Cash or cash equivalents
• Gifts or hospitality intended to secure favourable treatment

All gifts or hospitality over $150 AUD must be declared to management and recorded in the Gifts & Hospitality Register.

6. Third Parties & Due Diligence

We will perform due diligence on agents, consultants, suppliers, and partners to ensure they meet our ethical standards. Contracts must include clauses prohibiting bribery and corruption.

7. Reporting Suspected Breaches

1. Report immediately to the Director or designated Compliance Officer
2. Reports may be made confidentially and without fear of retaliation
3. All reports will be investigated promptly and discreetly

8. Consequences of Breach

• Disciplinary action, including termination
• Contract termination for suppliers or partners
• Referral to law enforcement authorities

9. Responsibilities

• Management: Promote a culture of integrity and ensure resources are available for compliance
• Employees & Contractors: Comply with this policy and undertake training where required
• Suppliers & Partners: Meet the same standards as Divergent Edge Strategies

10. Review & Updates

This policy will be reviewed annually, or sooner if legislative changes occur.