OSH Form 138 – Anti-Corruption and Ethical Business Practices Policy

Professional Anti-Corruption, Anti-Bribery, Fraud, Money Laundering & Ethical Business Practices Policy – Word Format – Instant Download

Protect your business with a professionally structured Anti-Corruption and Ethical Business Practices Policy designed to help Australian businesses establish clear standards for ethical conduct, bribery prevention, fraud control, money laundering awareness and responsible business practices.

OSH Form 138 provides a practical, ready-to-use policy that can be downloaded immediately in Microsoft Word format, allowing you to add your company details, logo, approval information and internal procedures.

What Does This Policy Cover?

The OSH Form 138 Anti-Corruption and Ethical Business Practices Policy establishes clear expectations for employees, managers, contractors and other representatives of your business.

The policy addresses:

Anti-corruption and corrupt conduct
Bribery and improper payments
Fraud and dishonest conduct
Money laundering and suspicious transactions
Facilitation payments
Gifts, entertainment and hospitality
Conflicts of interest
Ethical business practices
Procurement and tendering
Political and charitable contributions
Third-party business relationships
Accurate financial and business records
Reporting suspected misconduct
Protection against retaliation
Investigation procedures
Disciplinary consequences
Management and employee responsibilities
Training and awareness
Record keeping
Policy review and approval

Third-Party Sanctions Screening

The policy also provides a framework for screening relevant third-party business partners against applicable sanctions and restricted-party information.

This includes consideration of internationally recognised sanctions sources such as:

Australian Department of Foreign Affairs and Trade (DFAT) Consolidated List
New Zealand Ministry of Foreign Affairs and Trade (MFAT) sanctions information
U.S. Department of the Treasury – OFAC Specially Designated Nationals and Blocked Persons List (SDN List)
United Nations Security Council Consolidated List

The policy includes procedures for identifying potential matches, placing transactions on hold, escalating concerns, investigating potential matches and maintaining appropriate screening records.

Practical Policy & Procedure

This is more than a statement of intent.

The document provides a practical procedure for businesses to follow when dealing with customers, suppliers, contractors, consultants, agents, distributors and other third parties.

It includes provisions covering:

Third-Party Identification
Guidance on obtaining sufficient information to identify customers, suppliers and other business partners.

Sanctions Screening
A structured process for checking relevant parties against applicable sanctions and restricted-party lists.

Potential Matches
Guidance for determining whether a potential sanctions match is a false positive, requires further investigation or represents a confirmed match.

Transaction Holds
Procedures for placing transactions or business relationships on hold when a potential sanctions issue cannot be resolved.

Escalation
Clear requirements for referring suspected sanctions, bribery, corruption, fraud or other compliance concerns to management.

Record Keeping
Requirements for maintaining evidence of screening, investigations, decisions and actions taken.

Ongoing Screening
Guidance on when existing customers and business partners should be re-screened.

Ready-to-Customise Microsoft Word Document

OSH Form 138 is supplied as an editable Microsoft Word document (.docx).

Simply download the document, open it in Microsoft Word and customise it for your business.

You can add:

Company name
Company logo
Document number
Document owner
Effective date
Review date
Responsible personnel
Reporting contact details
Approval details
Internal procedures

The document includes clearly defined sections and approval fields so it can be incorporated into your company’s existing OSH and management system.

Who Should Use This Policy?

This policy is suitable for businesses of all sizes and industries, particularly businesses that:

deal with multiple suppliers or contractors;
engage third-party service providers;
conduct interstate or international business;
participate in tendering or procurement;
deal with government organisations;
have employees responsible for purchasing or financial transactions;
need documented ethical business practices; or
have been asked by a customer, principal contractor or business partner to provide evidence of anti-corruption and ethical business controls.

It can also be useful when completing supplier prequalification, contractor onboarding, corporate compliance questionnaires and procurement requirements.

Why Have an Anti-Corruption Policy?

Businesses can be exposed to significant legal, financial and reputational. Australia has a robust legal framework to combat bribery and corruption, both domestically and internationally. As a director of an Australian company, it is a fundamental responsibility to understand these laws and ensure that you and your organisation complies with them. Failure to do so can result in severe legal and reputational consequences risks through bribery, fraud, corruption, money laundering and other unethical conduct.

A documented policy helps demonstrate that your business has established expectations and procedures for preventing, identifying and responding to inappropriate conduct.

It also provides employees with a clear framework for dealing with situations such as:

being offered inappropriate gifts or benefits;
suspected fraudulent transactions;
conflicts of interest;
unusual payment requests;
suspicious third-party arrangements;
potential sanctions matches; and
suspected bribery or corrupt conduct.

What’s Included?

OSH Form 138 – Anti-Corruption and Ethical Business Practices Policy

File format: Microsoft Word (.docx)

Delivery: Instant digital download

Editable: Yes

Suitable for: Australian businesses

Document type: Policy & Procedure

No physical product will be supplied.

Instant Download

Purchase OSH Form 138 and download your editable Microsoft Word document immediately.

Add your company details, customise the policy to suit your operations and implement it within your existing OSH and business management system.

Important Information

This document is provided as a general business policy template and is intended to assist businesses in establishing documented procedures and expectations.

It should be reviewed and customised to suit your business operations, risk profile and applicable legal obligations. It does not constitute legal advice and does not guarantee compliance with any particular legislation, contract, tender or prequalification requirement.

JSEAsy recommends that businesses obtain appropriate professional or legal advice where specific compliance requirements apply.