Group Anti-Bribery and Corruption Policy Summary
QBE is committed to ensuring compliance with anti-bribery and corruption laws and regulations in the countries in which it operates.
QBE’s Group Anti-Bribery and Corruption Policy (“Policy”) establishes the approach, principles and requirements essential for managing compliance with those laws and regulations. The Policy applies to all QBE employees, contractors, contingent workers, directors and anyone else who represents QBE.
Under the Policy, all QBE employees are not permitted to:
- Give, offer, promise, accept, request or authorise a bribe, whether directly or indirectly, or engage in or facilitate corruption or corrupt practices.
- Make or support any facilitation payments (payments made directly to a government official or employee for their benefit, to expedite or secure the performance of governmental action by a governmental agency), whether directly or through third parties.
- Offer or receive commissions, payments (indirect or direct), gifts, entertainment, hospitality or promotional activity where these are unreasonable, excessive (whether in frequency and value), disproportionate and not offered or accepted in good faith.
- Make political donations and contributions on behalf of QBE, other than where authority has been specifically delegated to them.
Under the Policy, all QBE employees are required to:
- Attend and participate in relevant training sessions.
- Report actual, potential or suspected issues of bribery, facilitation and corruption to the Compliance Team, Financial Crime Management Team or via the QBE Ethics Hotline.
- Co-operate and assist with any investigation undertaken by QBE.
- Conduct a reasonable investigation (due diligence) into the background, reputation, and business practices of the third party before entering a contract with them.
QBE also requires that third parties who act on its behalf, do not engage in or facilitate any business activity that leads to breach of this Policy or anti-bribery and corruption laws.
The Global Financial Crime Working Group is responsible for evaluation and oversight of QBE’s financial crime management risk approach.