Anti-Bribery and Corruption Policy
1. Policy Statement
1.1 It is NPA's objective and policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to Bribery and Corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.
1.2 We will not engage in Bribery and Corruption in any of the jurisdictions in which we operate. We remain bound by local and national laws, and our own ethical standards. To the extent we operate in the jurisdictions of other countries, we will comply with applicable laws.
2.1 This policy applies to all Employees and relevant Third Parties of NPA and shall be communicated to them at the outset of our business relationship and/or as appropriate thereafter.
2.2 This policy applies in all countries or territories where NPA operates. Where local customs, standards, laws or other local policies apply that are stricter than the provision of this policy, the stricter rules must be complied with. However, if this policy stipulates stricter rules than local customs, standards, laws or other local policies, the stricter provisions of this policy shall apply.
"Agent": Any individual acting as an agent, paid by the company, acting on the company's behalf in negotiating with Third Parties.
"Bribery" / "Corruption": Bribery occurs when one person offers, pays, seeks or accepts a payment, gift, favour, or a financial or other advantage from another to influence a business outcome improperly, to induce or reward improper conduct or to gain any improper commercial, contractual, regulatory or personal advantage. It can be direct or indirect through Third Parties.
"Conflict of Interest": Occurs when an individual's private or personal interests have the potential of influencing the way they perform their duties at work, or where an organisation is involved in multiple interests, one of which could possibly corrupt, or be perceived to corrupt, the motivation for an act in another. A conflict of interest may be financial or non-financial in nature.
"Donation": A Donation is a voluntary contribution in the form of monetary or non-monetary gifts to a fund or cause for which no return service or payment is expected or made. Contributions to industry associations or fees for memberships in organisations that serve business interests are not necessarily considered Donations.
"Employee": For the purposes of this policy this includes all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term, casual or temporary), consultants, contractors, trainees, seconded staff, home-workers, volunteers, interns, agents, sponsors, or any other person associated with NPA.
"Facilitation Payments": A form of Bribery in which small payments are made with the purpose of expediting or facilitating the performance by a Public Official of a routine governmental action and not to obtain or retain business or any other undue advantage. Facilitation payments are typically demanded by low level and low income Public Officials in exchange for providing services to which one is legally entitled without such payments.
"Gifts, Invitations and Hospitality": Invitations given or received to social functions, sporting events, meals and entertainment, gifts or customary tokens of appreciation.
"Intermediary": Includes but is not limited to Agents, distributors, consultants, sales representatives (who are not employees of NPA), implementation partners, sales partners.
"Kickback": A form of Bribery to obtain an undue advantage, where a portion of the undue advantage is 'kicked backed' to the person who gave, or is supposed to give, the undue advantage.
"Public Official": Officials or employees of any government or other public body, agency or legal entity, at any level, including officers or employees of state-owned enterprises and officers or employees of enterprises which are mandated by a public body or a state-owned enterprise to administrate public functions.
"Sponsorship": Sponsorship is about partnering with external organisations to deliver mutual benefits through an exchange of monies, products, services, content or other intellectual property.
"Third Party": Any individual or organisation you come into contact with during the course of your work for NPA. This includes actual and potential customers, suppliers, business contacts, Intermediaries, government and public bodies, including their advisors, representatives and officials, politicians and political parties.
4. Gifts, Invitations and Hospitality
4.1 The provision and/or receipt of gifts and/or hospitality to/from Third Parties is a common business practice. NPA's Gifts, Invitations and Hospitality Policy provides the detailed guidelines under which such can be offered and/or received.
4.2 In summary you are prohibited from accepting a gift or giving a gift to a third party in the following situations:
(a) it is made with the intention of influencing a Third Party to obtain or retain business, to gain a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
(b) it is given in your name and not in the name of NPA;
(c) it includes cash or a cash equivalent (such as gift certificates or vouchers, travel or accommodation);
(d) it is of an inappropriate type and value and given at an inappropriate time (e.g. during a tender process or contract negotiations); and
(e) it is given secretly and not openly.
4.3 The practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable, justifiable and is proportionate. The intention behind the gift should always be considered.
5. Facilitation Payments and Kickbacks
5.1 In many jurisdictions, making Facilitation Payments is illegal. NPA will not make, and will not accept, Facilitation Payments or Kickbacks of any kind anywhere in the world.
5.2 Where the facilitation payment is being extorted or you are being coerced to pay it and your safety or liberty is under threat or you feel you have no alternative but to pay for personal or family peace of mind, then pay the Facilitation Payment and report this to your line manager as soon as possible.
6. Employee Responsibilities
6.1 It is unacceptable for an employee (or someone on the employees behalf) to:
(a) give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
(b) give, promise to give, or offer, a payment, gift or hospitality to a Public Official or Third Party to 'facilitate' or expedite a routine procedure;
(c) accept payment from a Third Party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;
(d) accept a gift or hospitality from a Third Party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;
(e) threaten or retaliate against another Employee who has refused to commit a bribery offence or who has raised concerns under this policy; or
(f) engage in any activity that might lead to a breach of this policy or perceived breach of this policy.
6.2 It is the employee's responsibility to ensure that all accounts, invoices, memoranda and other documents and records relating to dealings with Third Parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept 'off-book'.
6.3 In accordance with the NPA Gifts, Invitations and Hospitality Policy you must declare and keep a written record of all Gifts, Invitations and Hospitality accepted or offered, and ensure all expense claims relating to Gifts, Invitations and Hospitality or expenses incurred to Third Parties specifically record the reason for the expenditure.
6.4 The prevention, detection and reporting of any form of Bribery and Corruption are the responsibility of all Employees. You must notify the Head of Risk Management and Security as soon as possible if you are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.
6.5 All Employees have the responsibility to read, understand and comply with this policy. You should at all times, avoid any activity that might lead to, or suggest, a breach of this policy.
6.6 Any Employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct.
6.7 This policy should be read in conjunction with the Company's Gifts, Invitations and Hospitality policy, Dealing with Overseas Customers Policy and Code of Conduct.
6.8 Employees are encouraged to raise concerns about any instance, or suspicion, of malpractice at the earliest possible stage through their manager, or the Head of Risk Management and Security or if appropriate via the Faircall Hotline, in accordance with the Reporting Fraud and Improper Conduct Policy.
FURTHER 'RED FLAGS' THAT MAY INDICATE BRIBERY OR CORRUPTION ARE SET OUT IN APPENDIX 1.
7.1 Employees who refuse to take part in bribery or corruption, or report in good faith under this policy their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future will be protected from detrimental treatment/retaliation. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
8.1 The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
8.2 The Head of Risk and Compliance has primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it. This training shall also be given to Intermediaries where possible.
9. Monitoring and Review
9.1 The Head of Risk and Compliance will review this policy on an annual basis, considering its suitability, adequacy and effectiveness.
The following is a list of potential breaches of policy or "red flags" that may arise during the course of your work and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.
If you encounter any of these red flags while working for NPA, you must report them promptly to your direct manager or the Head of Risk Management and Security.
(a) you become aware that a Third Party engages in, or has been accused of engaging in, improper business practices;
(b) if the Third Party refuses to divulge adequate information during due diligence procedure;
(c) you learn that a Third Party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a 'special relationship' with foreign Public Officials;
(d) a Third Party insists on receiving a commission or fee payment before committing to sign up to a contract with NPA, or carrying out a government function or process for NPA;
(e) a Third Party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;
(f) a Third Party requests that payment is made to a country or geographic location different from where the Third Party resides or conducts business;
(g) a Third Party requests an unexpected additional fee or commission to 'facilitate' a service;
(h) a Third Party demands lavish Gifts, Invitations or Hospitality before commencing or continuing contractual negotiations or provision of services;
(i) a Third Party requests that a payment is made to 'overlook' potential legal violations;
(j) a Third Party requests that you provide employment or some other advantage to a friend or relative;
(k) a Third Party requests that you make a political contribution or donation to the party or charity of their choice before agreeing to undertake a business relationship with the Company
(l) you receive an invoice from a Third Party that appears to be non-standard or customised;
(m) a Third Party refuses to put terms agreed in writing;
(n) you notice that NPA has been invoiced for a commission or fee payment that appears large given the service stated to have been provided;
(o) a Third Party requests or requires the use of an Agent, intermediary, consultant, distributor or supplier that is not typically used by or known to NPA; or
(p) you are offered an unusually generous gift or offered lavish hospitality by a Third Party.
The FairCall service, run by KPMG, provides Note Printing Australia employees with an independently monitored, external, anonymous service to report their concerns of possible fraudulent or unethical conduct.
There is a toll-free hotline service which will be monitored by trained and experienced professionals.
The phone number is 1800 500 965.
Calls will be received on recognised business days between 7:00 am and 6:00 pm (EST).
Note Printing Australia employees are able to utilise the email address email@example.com
Obviously this may restrict the ability of the caller to remain anonymous, however the independent service provider will ensure all details are kept confidential.
Note Printing Australia employees are able to mail reports or additional information to a secure mailbox at the following address:
The FairCall Manager
PO Box H67
Australia Square, Sydney NSW 1213
Compliance - Competition and Consumer Act 2010
The Compliance - Competition and Consumer Act 2010 (CCA) policy seeks to ensure that Note Printing Australia (NPA) complies with its legislative obligations, including obligations arising from the Competition and Consumer Act 2010 (CCA).
Compliance to the CCA involves NPA complying with the law and behaving as a responsible corporate citizen and makes good business sense as well. On the other hand, failing to behave in accordance with the law is bad business. We cannot ignore the significant penalties that apply to both companies and their representatives personally for breaches of the CCA.
As a result, the board of NPA wants to ensure that a culture of compliance exists.
This policy applies to all NPA staff and its agents.
Staff are required to read this manual carefully and raise any issue of concern with any one of the following:
their direct manager;
the Head of Human Resources;
the Head of Risk and Compliance; or
1. NPA Compliance Program
This policy is part of NPA's compliance program. The Australian Competition and Consumer Commission (ACCC) website states that a competition and consumer compliance program is designed to:
'identify and reduce the risk of breaching the Competition and Consumer Act 2010 (the Act) and to remedy any breach that may occur. A successful compliance program will facilitate compliance within the organisation and help the company to become or remain a good corporate citizen.'
Penalties for breaches of the CCA are very substantial. The involvement in litigation under the CCA is also very costly and demanding for those directly involved and for management.
The existence of a compliance program is important in reducing corporate and personal risk for at least three reasons:
If all personnel at NPA are aware of the requirements of the legislation we are less likely to find ourselves in a situation where a breach is alleged.
In some situations the existence of a compliance policy and implementation of a program might assist in establishing a defence to an alleged breach.
The existence of a compliance policy and implementation of a program will almost always be very relevant to any penalty imposed. The Courts are more likely to impose a greater or maximum penalty when there is no compliance regime or a poor or ineffective one.
2. Compliance with the Legislation
All NPA personnel are expected to comply with the CCA at all times.
A failure to do so will lead to serious consequences. Inadvertent breaches may result in disciplinary action. Wilful or reckless breaches will usually involve dismissal.
The CCA prevents the company from covering civil penalties for breaching the CCA or the associated legal costs awarded against staff who have breached the CCA.
The Corporations Act prevents the company from indemnifying a person against liabilities owed to the company or a related body corporate or to some other person that did not arise out of conduct in good faith, or for criminal penalties and legal costs when the person is found liable.
3. Getting help
If staff have a query about the CCA or its application to a particular situation that arises in relation to their work, they can raise it with one of the persons listed in paragraph 1 above. That person will then answer the query or seek assistance from senior management and/or NPA's legal advisers.
This requirement is not only designed to ensure that NPA minimises its risk but also to allow the burden of handling a difficult situation to pass to those who are best able to deal with it.
Section A: Competition and Consumer Act
4.1 Purpose of the CCA
The object of the CCA "is to enhance the welfare of Australians through the promotion of competition and fair trading and provision for consumer protection".
Thus, the CCA is designed principally to achieve two objectives. First, to ensure that corporations operate competitively, without collusion and without unfairly using their power, whether that power is acquired by size or otherwise. Secondly, the CCA is designed to ensure that companies behave fairly in transactions (particularly with consumers).
Generally, in determining whether there has been a breach of the CCA, the intention of a party is irrelevant. Thus, the courts will generally only look at the effect of the behaviour of a company and its representatives in determining liability irrespective of whether the prohibited behaviour is intentional.
4.3 Record keeping
The ACCC has very wide powers to require companies and individuals to furnish information and produce financial and other records. This will include computers, file notes, letters, emails and diary entries. As a separate exercise the ACCC can require individuals to attend to be examined orally about such documents and any other matters relating to a possible contravention of the Act.
NPA staff must never destroy documents with a view to concealing a possible contravention of the CCA. First, NPA would regard that as a very serious breach of duty and would take swift disciplinary action in respect of it. Secondly, it is rare for there not to be copies of documents destroyed or references to them and the fact of destruction will almost always be discovered and adverse inferences drawn. Thirdly, the destruction or concealment of evidence, where it is reasonably likely to be required in evidence in a legal proceeding that is in existence or may be commenced in the future, will likely be a criminal offence in itself.
Not only should staff be careful to avoid situations which might lead to a contravention of the CCA, they should also take great care about matters that are recorded in writing so that, as far as possible, they cannot be misconstrued. If staff are in any doubt at all they should consult one of the persons listed above.
4.4 Dealing with the ACCC
It is the policy of NPA to co-operate fully with the ACCC. However, it is important that any communications with the ACCC be handled through appropriate channels, either by involving one of the persons listed above or NPA's legal advisers.
If NPA staff are approached by the ACCC they should advise that it is company policy to co-operate but that they are obliged to first notify one of the persons listed above. That person will then investigate the matter and arrange for an appropriate response to be made promptly to the ACCC.
4.5 Dealing with suppliers and customers
There is nothing wrong with being tough in negotiations but it is important to behave fairly when dealing with suppliers and customers. This will reduce the risk of disputes with them and will also reduce the risk of interest from regulators like the ACCC.
4.6 Dealing with competitors
Generally it is wise to avoid communication with competitors. This will be unavoidable at times, for example, when attending currency conferences. However, NPA staff must avoid discussions about prices and potential future sales matters.
5. CCA Provisions
5.1 Misleading or deceptive conduct (Sch.2 - s 18)
A corporation must not, in trade or commerce, engage in conduct that is misleading or deceptive or is likely to mislead or deceive.
Intention to mislead or deceive is not necessary; an accidental or mistaken statement or conduct will be a breach of the CCA if it in fact misleads and deceives.
In some cases, silence can constitute misleading or deceptive conduct.
An example of a breach of this provision might occur where, to obtain a new customer, NPA representatives state that NPA will supply on a particular or preferential pricing basis but they know that NPA is unlikely to be able to supply on that basis.
5.2 False or misleading representations (Sch.2 - s 29)
It is unlawful to falsely represent goods or services as having particular qualities, or as being of a certain standard, grade, composition, value, etc.
If the ACCC takes action against a company under Section 29 a Court can fix penalties of up to $1.1 million for a company and up to $220,000 for any individual involved in the breach.
For example, it would be a breach of Section 29 for a NPA representative, in order to win new work/customers, to make representations about the features of a product that are not correct. Thus, if it was represented to a prospective customer that banknotes produced by NPA had particular security features that did not exist or if NPA provides a breakdown of its costs of producing the banknotes which is inflated or otherwise incorrect, it is likely that there would be a breach of Section 29.
The affected customer could sue NPA, and the NPA representative concerned, for damages. Further, the ACCC could take action to impose pecuniary penalties on both.
5.3 Restrictive Trade Practices - Part IV
A corporation must not make, or give effect to, a contract, arrangement or understanding that contains a cartel provision.
A cartel provision is a provision relating to:
price-fixing (a provision in a contract, arrangement or understanding between competitors that has the purpose or effect of fixing, controlling or maintaining the price of goods or services on a discount or rebate etc); or
restricting outputs in the production and supply chain (a provision in a contract, arrangement or understanding between competitors having the purpose of preventing, restricting or limiting the production or supply of goods or services); or
allocating customers, suppliers or territories (a provision in a contract, arrangement or understanding between competitors having the purpose of allocating between the parties to the contract etc the persons who supply to or acquire from such parties' goods or services or the geographical areas in which they operate); or
bid-rigging (a provision in a contract, arrangement or understanding between competitors having the purpose of, for example, one or more of the parties bidding but others not doing so or not doing so competitively), by parties that are, or would otherwise be, in competition with each other.
Maximum penalties for cartel conduct:
For a corporation - the greater of $10 million, or 3 times the value of the benefit from the cartel, or (where the value cannot be determined) 10% of the annual turnover of the corporate group.
For individuals - $500,000.
A corporation or individual who makes a contract, arrangement or understanding that contains a cartel provision with the intention of dishonestly obtaining a benefit would be guilty of a criminal offence.
For a corporation - as above.
For individuals - imprisonment of 10 years, and/or $220,000 fine.
5.4 Other provisions
There are other restrictive trade practices provisions such as:
Misuse of market power
A corporation that has a substantial degree of power in a market shall not take advantage of that power for the purpose of eliminating or damaging a competitor or preventing a person from entering the market.
A corporation shall not in trade or commerce engage in the practice of exclusive dealing. Exclusive dealings include providing goods and services on the condition the customer does not:
acquire goods and services from a competitor;
re-supply the goods and services from a competitor; or
re-supply the goods or services to particular persons or in particular places.
Similar provisions apply to the supply of goods and services by a corporation.
Resale Price Maintenance
A supplier may not impose a minimum resale price on a person and the person must not enter into an agreement to maintain a minimum resale price.
International Anti-Cartel Conduct
Whilst the nature of NPA's business is such that the restrictive trade practices provisions of the CCA are unlikely to be of day-to-day concern, it is important to understand the principles because similar provisions are contained in legislation in other countries.
For example, in Canada there is the Competition Act 1985 and in New Zealand there is the Commerce Act 1986.
The ACCC has set up working relationships with its counterpart agencies in other countries that have similar anti-cartel laws.
Penalties can be even more severe in other countries. For example, in Canada penalties can range up to 14 years in prison and $25 million.
1. Your rights in relation to privacy
NPA understands the importance of protecting the privacy of an individual's personal information. This statement sets out how NPA aims to protect the privacy of your personal information, your rights in relation to your personal information managed by NPA and the way NPA collects, holds, uses and discloses your personal information.
In handling your personal information, NPA will comply with the Privacy Act 1988 (Cth) (Privacy Act) and with the 13 Australian Privacy Principles in the Privacy Act. This policy statement may be updated from time to time.
2. What kinds of personal information does NPA collect?
Personal information is information or an opinion about an identified, or reasonably identifiable, individual. As part of conducting business and in the provision of its goods and/or services, NPA may collect your personal information.
Generally, the kinds of personal information NPA collects are contact and identification information such as your name, address, telephone number and email address. In some circumstances, NPA may also hold other personal information provided by you.
3. How does NPA collect personal information?
Generally, NPA collects your personal information directly from you, through completion of a hard copy or online form, an interaction or exchange in person or by way of telephone, facsimile, email or post or through the use of the NPA website. There may be other occasions when NPA collects your personal information from other sources such as from an information services provider or a publicly maintained record. Generally, NPA will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you.
4. Why does NPA need your personal information?
NPA collects, holds, uses and discloses your personal information where it is reasonably necessary for the purposes of:
designing and providing banknotes and passports or otherwise providing design and operational services in connection with the production of security products and related services;
accounting, billing and other internal administrative purposes;
business management purposes, including the provision to NPA of third party advisory/professional services;
identifying and informing you of products and services that may be of interest to you from NPA; and
any legal requirements.
Where personal information is used or disclosed, NPA takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to NPA. However, without certain information from you, NPA may not be able to provide its products and/or services to you.
5. To whom does NPA disclose your personal information?
NPA discloses your personal information for the purpose for which NPA collects it. That is, generally, NPA will only disclose your personal information for a purpose set out at paragraph 4 or a secondary purpose related to the purpose of collection. NPA may also disclose your personal information with your consent or if disclosure is required or authorised by law. This may include disclosing your personal information where reasonably necessary for the enforcement of the criminal law or of a law imposing a pecuniary penalty, or for the protection of the public revenue.
6. Overseas Disclosure
NPA may disclose personal information to overseas recipients in order to provide its services and/or products and for administrative or other business management purposes. It is impracticable to list the countries in which recipients of personal information may be located, however, before disclosing any personal information to an overseas recipient, NPA takes steps reasonable in the circumstances to ensure the overseas recipient complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme unless you consent to the overseas disclosure or it is otherwise required or permitted by law.
7. Security of your personal information
NPA takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. In particular, only those employees (for example, managers) with a lawful and legitimate business reason for accessing personal information held by NPA will be granted access. NPA has controls and procedures in place to ensure that personal information is kept confidentially.
NPA will destroy or de-identify personal information in circumstances where it is no longer required, unless NPA is otherwise required or authorised by law to retain the information.
8. Can you access and correct the personal information that NPA holds about you?
NPA takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and seek correction of your personal information that is collected and held by NPA. If at any time you would like to access or correct the personal information that NPA holds about you, or you would like more information on NPA's approach to privacy, please contact NPA via the contact details set out in paragraph 9 below. NPA will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information:
you will have to provide proof of identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
NPA requests that you be reasonably specific about the information you require; and
NPA may charge you a reasonable administration fee, which reflects the cost to NPA, for the retrieval and supply of information in accordance with your request.
If NPA refuses your request to access or correct your personal information, NPA will provide you with written reasons for the refusal and details of complaint mechanisms. NPA will also take steps, reasonable in the circumstances, to provide you with access in a manner that meets your needs and the needs of NPA.
NPA will endeavour to respond to your request to access or correct your personal information within 30 days from your request.
9. How to contact us
For further information or enquiries regarding your personal information, please contact NPA's Privacy Compliance Officer at firstname.lastname@example.org or on 03 9303 0227.
10. Privacy complaints
Please direct all privacy complaints to NPA's Privacy Compliance Officer. At all times, privacy complaints:
will be treated seriously;
will be dealt with promptly;
will be dealt with in a confidential manner; and
will not affect your existing obligations or affect the commercial arrangements between you and NPA.
NPA's Privacy Compliance Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Federal Office of the Australian Information Commissioner.
Quality, Environment and Work Health Safety Policy
Note Printing Australia Limited (NPA) designs, manufactures and markets banknotes, passports and security solutions for Australia and other strategic customers.
The purpose of this policy is to outline the commitment of NPA to deliver high quality banknotes, passports and security solutions for Australia and other strategic customers while promoting a workplace that reduces the environmental impacts of NPA’s activities, and seeks to protect the health, safety and welfare of our workers and visitors to NPA, striving to provide a zero harm environment.
This policy applies to all workers. For the purposes of this policy 'workers' includes all individuals working at NPA, these being: senior managers, officers, directors, employees (whether permanent, fixed-term, casual or temporary), consultants, contractors, trainees, seconded staff, home-workers, volunteers and interns.
NPA is committed to maintaining and integrating its quality, environmental and work health and safety management systems (based on ISO 9001:2015, ISO 14001:2015, ISO 45001:2018 and other relevant customer requirements, environmental and work health and safety legislation and standards) in order to assist NPA to:
· Fulfill applicable compliance obligations;
· Strive for continual improvement in its performance;
· Provide safe and healthy working conditions for the prevention of work-related injury and ill health;
· Protect the environment and prevent pollution of air, land and water by maintaining effective controls to minimise environmental discharges and prevent inadvertent environmental impacts;
· Set and review measurable objectives and targets;
· Eliminate hazards and /or risks arising from work, damage to property, and the environmental aspects and impacts of NPA’s business associated with Quality, Environment & Work Health and Safety so far as is reasonably practicable, or if it is not reasonably practicable to eliminate risks, minimise those risks so far as is reasonably practicable;
· Maintain monitoring programs and, where necessary, implement corrective or preventive actions;
· Conduct regular management reviews to ensure NPA’s objectives and improvement targets are met;
· Ensure consultation and participation of workers and their representatives;
· Educate our workers about the quality, environmental and work health and safety aspects of the work they perform.
This policy is communicated to all NPA workers and is available to the public on NPA’s website on: www.noteprinting.com.
This policy is reviewed annually and is developed, implemented and maintained in consultation with our workers and Executive Leadership Team.
whistleblower protection policy
Note Printing Australia Limited (NPA) recognises the value in developing and fostering a culture of corporate compliance and governance, ethical decision-making and protecting eligible whistleblowers who report ‘reportable conduct’ in accordance with this policy from detrimental action.
The purpose of this policy is to assist in the prevention and detection of improper conduct, defined in this policy as ‘reportable conduct’, by establishing the process through which an eligible whistleblower can:
a) report actual or suspected reportable conduct; and
b) be informed of and adequately protected from detrimental action, or any other disadvantage, by any person internal or external to NPA.
This policy will also outline the process in which NPA will investigate reportable conduct, the process of fair treatment of persons to whom the reportable conduct relates or mentions and provide information about how this policy is to be made available.
This policy applies to all employees and officers of, and contractors to, NPA and all eligible whistleblowers.
1. Who is an ‘eligible whistleblower’?
An individual will be an eligible whistleblower if they are, or have been:
(a) an officer of NPA;
(b) an employee of NPA;
(c) an individual who supplies services or goods to NPA;
(d) an employee of a person that supplies services or goods to NPA;
(e) an individual who is an associate of NPA;
(f) a relative of an individual referred to above; or
(g) a dependent of an individual referred to above or such an individual’s spouse.
2. What is ‘Reportable Conduct’?
For the purposes of this policy, ‘reportable conduct’ means conduct that constitutes misconduct, or an improper state of affairs or circumstances, in relation to NPA or its related entities, including but not limited to dishonest conduct, unlawful conduct, unethical conduct, corruption, mismanagement or abuse of power. Such conduct would include conduct on the part of NPA, or an NPA employee or officer, or contractor to NPA that:
(a) adversely affects, or could adversely affect, the honest performance of their duties and responsibilities or NPA’s functions;
(b) amounts to performing their duties and responsibilities dishonestly;
(c) is fraudulent. Fraud is described in NPA’s Fraud Policy as follows:
‘Dishonestly obtaining a benefit, or causing a loss, by deception or other means.’
NPA regards fraud as any practice which results in an employee, consultant, vendor, contractor or any other party having a business relationship with NPA dishonestly obtaining a benefit (financial or otherwise), or causing a loss to NPA, by deception or other means. This includes, but is not limited to:
obtaining property, a financial advantage or any other benefit by deception;
causing a loss or avoiding or creating a liability by deception or deceit;
providing false or misleading information to NPA or failing to provide information to NPA where there is an obligation to do so;
disclosing confidential and proprietary information of NPA to outside parties;
unauthorised emailing or distribution of confidential or proprietary information of NPA;
profiteering as a result of insider knowledge of NPA’s or another company’s activities;
making, using or possessing any forged, altered or falsified documents (including financial documents), instruments or accounts belonging to NPA;
misappropriation of NPA funds, supplies or other NPA assets;
unlawful use of NPA property or assets;
impropriety in the handling or reporting of money or financial transactions;
bribery, corruption or abuse of position;
payment of, or soliciting for, bribes or secret commissions (which includes accepting or seeking anything of material value from contractors, vendors or persons providing services/materials to, or obtaining services from, NPA outside the guidelines of the Gifts, Invitations and Hospitality Policy);
claiming allowances where there is no entitlement;
favouring friends or relatives or anyone else for personal benefit;
destruction, removal or inappropriate use of, or interference with, NPA records and equipment that has not been authorised by NPA (which includes hacking into or interfering with NPA’s computer system);
using NPA’s systems to gain access to other systems without authority;
charging NPA for goods or services that are incomplete or not delivered to NPA;
failure, without adequate explanation, to update NPA’s records to reflect any leave taken; or
any other dishonest or fraudulent act of a like nature to those listed above;
(d) is illegal, including theft, drug sale or use, violence or threats of violence and criminal damage of property;
(e) represents a danger to the public or the financial system (whether or not it is a breach of any law);
(f) constitutes a contravention of any law administered by ASIC and/or APRA (i.e. a contravention of the Corporations Act 2001; ASIC Act 2001; Banking Act 1959; Financial Sector (Collection of Data) Act 2001; Insurance Act 1973; Life Insurance Act 1995; National Consumer Credit Protection Act 2009; Superannuation Industry (Supervision) Act 1993; or an instrument or regulation made under any of these Acts);
(g) is an offence against any other law of the Commonwealth that is punishable by imprisonment for a period of 12 months or more; or
(h) is an attempt to engage in any of the above conduct.
Reportable conduct does not include conduct that concerns a personal work-related grievance unless it has significant implications for NPA or conduct that is dealt with, and therefore more appropriately raised, under an alternative policy. For example, conduct prohibited by NPA’s Workplace Bullying Prevention Policy, Sexual Harassment Prevention Policy or the EEO, Anti-Discrimination and Harassment Policy should be raised under NPA’s Complaint Resolution Policy.
3. Reporting and Investigating Reportable Conduct
3.1. Internal Reports to, and Investigations by, NPA
An eligible whistleblower may report reportable conduct to an officer or senior manager of NPA.
NPA prefers that reports of reportable conduct be made in the first instance to one of the following officers or senior managers of NPA:
the Chief Executive Officer of NPA (CEO);
the Head of Corporate Services of NPA;
the Head of Human Resources; or
the Chair of the Board (Chair).
If the reportable conduct involves information about an individual occupying one of the positions listed above, the eligible whistleblower is not to inform that individual of the reportable conduct. In these circumstances, the eligible whistleblower should inform another individual in the list above (or another officer or senior manager of NPA) or make an external report to NPA’s FairCall Hotline (details at paragraph 3.2 below).
The CEO, Head of Corporate Services, the Head of Human Resources or Chair, as applicable, may inform the Head of Business Services and Security of a report of reportable conduct, but in doing so must not disclose the identity of the eligible whistleblower, and will decide how an investigation of a report of reportable conduct is to be undertaken, which may include requiring an investigation to be undertaken internally or through the engagement of an external investigator. Where appropriate, an investigation may be undertaken under client legal privilege.
The investigation of a report of reportable conduct will be conducted fully and fairly with a view to gathering relevant evidence to determine whether the nature and substance of the alleged reportable conduct is substantiated or unsubstantiated.
The matter will be dealt with in a private and confidential manner. The CEO, Head of Corporate Services, Head of Human Resources or Chair, as applicable, will only disclose information about the report where necessary in order for the report to be effectively investigated and consistent with their obligations under paragraph 5 below.
3.2. External Reports to, and Investigations by, the FairCall Hotline
NPA, in conjunction with KPMG (chartered accountants), has established the FairCall Hotline, for the reporting of reportable conduct. The FairCall Hotline may be contacted as an alternative to contacting any of the individuals holding the internal NPA positions listed above or any other officer or senior manager of NPA. The FairCall Hotline is an external, independently operated service that will accept contact by eligible whistleblowers on both a confidential and anonymous basis.
Individuals who make a report of reportable conduct to the FairCall Hotline on an anonymous basis will not be required to provide personal details and no attempt will be made to obtain their identity.
The FairCall Hotline can be contacted on the following details:
a) by dialling 1800 500 965 (a toll-free service);
b) via the email address: email@example.com; or
c) by mailing reports or additional information to a secure mailbox at the following address:
The FairCall Manager
PO Box H67
Each eligible whistleblower who makes a report of reportable conduct to the FairCall Hotline will be allocated a confidential identification number by KPMG. KPMG will not ask for or record personal details of the eligible whistleblower unless the eligible whistleblower expresses that they require their details to be retained by KPMG or forwarded to NPA. Where KPMG does collect personal information as part of this service, KPMG has confirmed with NPA that it does so in accordance with KPMG’s Privacy Statement, available at: http://www.kpmg.com/AU/en/Pages/privacy-faircall.aspx.
A detailed report will be prepared by KPMG for each report of reportable conduct made to the FairCall Hotline and KPMG’s report will be directed to the Chair. Each KPMG report will provide details of the report of reportable conduct and any information that may be pertinent to a subsequent investigation of the report.
Upon receiving the KPMG report, the Chair will decide what follow up action is required, and by whom that action is to be taken. NPA undertakes that it will not attempt to ascertain from KPMG the identity of any eligible whistleblower who makes a report of reportable conduct to the FairCall Hotline.
4. Emergency and public interest disclosures
An eligible whistleblower may make an emergency or public interest disclosure of reportable conduct to a member of Parliament or a journalist in accordance with the provisions under the Corporations Act 2001 (Cth).
NPA, and any eligible recipient of a report of reportable conduct, will not disclose to anyone the identity of the eligible whistleblower or any information that is likely to lead to the identification of the eligible whistleblower, except:
(a) to ASIC, APRA or the Australian Federal Police; or
(b) to a legal practitioner for the purpose of obtaining legal advice or legal representation in relation to the operation of the relevant whistleblower protection legislation; or
(c) with the eligible whistleblower’s consent.
However, an eligible recipient may disclose information (other than the actual identity of the eligible whistleblower) if it is reasonably necessary for the purposes of investigating a matter that is relevant to the report of reportable conduct, and if the eligible recipient takes all reasonable steps to reduce the risk that the eligible whistleblower will be identified as a result.
6. Communications with the eligible whistleblower
If a report of reportable conduct is made internally as described in paragraph 3.1 or externally as described in paragraph 3.2, mechanisms will be implemented to keep the eligible whistleblower informed of any follow up actions and the result of those actions, as reasonable, subject to the identity of the eligible whistleblower being known and/or the eligible whistleblower being contactable.
Eligible whistleblowers will be bound by any common law, equitable and contractual duties of confidentiality. Additionally, particularly where the eligible whistleblower is a contractor, NPA may require the eligible whistleblower to sign an undertaking of confidentiality before any information is provided to him or her.
7. Protection of eligible whistleblowers
An eligible whistleblower who believes on reasonable grounds that NPA, an NPA employee or officer, or a contractor of NPA, has engaged or plans to engage, in reportable conduct and reports such matter:
(a) to an individual or the FairCall Hotline in accordance with paragraph 3;
(b) to an auditor (or a member of an audit team conducting an audit) of NPA or its related entities;
(c) to an actuary of NPA or its related entities;
(d) to a person authorised by NPA to receive a report of reportable conduct;
(e) to ASIC, APRA or a prescribed Commonwealth authority; or
(f) to a legal practitioner (for the purpose of obtaining legal advice or legal representation in relation to the operation of the relevant whistleblower protection legislation),
(g) (each an eligible recipient)
will be protected from:
(i) any civil, criminal or administrative liability for making the report of reportable conduct (although this does not prevent the eligible whistleblower from being subject to civil, criminal or administrative liability for conduct of the eligible whistleblower that is revealed by the report of reportable conduct);
(ii) NPA exercising any contractual right, or seeking any contractual remedy against them on the basis that the eligible whistleblower made the report of reportable conduct, including termination of contract; or
(iii) being subjected to any form of detriment or otherwise disadvantaged in reprisal for making the report of reportable conduct.
Detriment includes, but is not limited to:
a. dismissal of an employee;
b. injury of an employee in his or her employment;
c. alteration of an employee’s position or duties to his or her disadvantage;
d. discrimination between an employee and other employees;
e. harassment or intimidation of a person;
f. harm or injury to a person, including psychological harm;
g. damage to a person’s property;
h. damage to a person’s reputation;
i. damage to a person’s business or financial position; or
j. any other damage to a person.
NPA will take all reasonable steps to ensure that all employees and officers of NPA are aware of this policy, and train them on their right to make a report of reportable conduct to an eligible recipient without being subjected to detriment and that they are prohibited from subjecting to detriment an eligible whistleblower who makes a report of reportable conduct to an eligible recipient.
NPA employees, officers or contractors must not subject another person to detriment, or intentional or recklessly threaten to subject another person to detriment, because they believe or suspect that person may have made, proposes to make, or could make a report of reportable conduct to an eligible recipient.
If a person, believes on reasonable grounds that an eligible whistleblower who has made a report of reportable conduct to an eligible recipient has been, or is likely to be, subjected to detriment or any other disadvantage, he or she should report this to an eligible recipient, who will investigate, or arrange the investigation of the matter.
An NPA officer, employee or contractor who is found to have subjected an eligible whistleblower who has made a report of reportable conduct to an eligible recipient to detriment, or any other disadvantage will be subject to disciplinary action (which may include the termination of their employment or engagement) and may be guilty of an offence that is subject to prosecution under legislation.
8. Fair treatment of employees or officers of NPA
If a report of reportable conduct is made to an eligible recipient and it relates to or mentions an employee or officer of NPA, NPA will ensure the fair treatment of the employee or officer by:
a) to the extent possible, given confidentiality requirements, making the employee or officer aware of the nature of the allegations relating to or mentioning them and update the employee or officer on the progress of the investigation into such allegations;
b) giving the employee or officer an opportunity to respond to the allegations relating to or mentioning them; and
c) making the employee or officer aware of EAP services available to them.
9. Malicious Reports
This policy provides employees, officers, and contractors of NPA and others who may fall within the definition of eligible whistleblower, with an avenue to raise legitimate and serious matters of concern (i.e. reportable conduct). It is unacceptable for NPA employees, officers and contractors to make malicious or false reports, or to knowingly provide false or misleading information regarding reportable conduct or allegations of detriment. The making of a malicious or false report, or the provision of knowingly false or misleading information may be considered misconduct or serious misconduct and subject to disciplinary action, up to and including termination of employment, under NPA’s Discipline Policy. In the case of a contractor, this may result in their engagement with NPA being terminated.
10. Review and Amendment
This policy will be reviewed (and, if necessary, amended) by the Board annually or otherwise when the Board considers necessary.