Business Ethics, Anti-Bribery & Professional Conduct Policy

Last updated: May 2026

1. Purpose

Liberty Test & Tag is committed to conducting business ethically, lawfully, professionally, and transparently at all times. As a small family-operated business, the company recognises that its reputation, client relationships, and long-term success depend on maintaining high standards of integrity and accountability in all business activities.

This policy establishes the minimum standards expected of all directors, employees, contractors, subcontractors, and any person acting on behalf of the company. It is intended to support ethical decision-making, prevent improper conduct, and ensure the company operates in accordance with applicable Australian laws, industry standards, and client expectations.

The company does not tolerate bribery, corruption, dishonest conduct, undisclosed commissions, improper inducements, or any activity that may compromise professional integrity or public trust.

2. Scope

This policy applies to:

  • Directors and owners of the company
  • Employees
  • Contractors and subcontractors
  • Consultants and labour hire personnel
  • Any individual representing the company in a professional capacity

Compliance with this policy is a condition of engagement with the company.

3. Core Principles

All persons acting on behalf of Liberty Test & Tag are expected to:

  • Act honestly, fairly, and professionally
  • Comply with all applicable laws, regulations, and contractual obligations
  • Avoid conduct that may damage the reputation of the company or its clients
  • Maintain transparency and accountability in business dealings
  • Treat clients, suppliers, regulators, and members of the public with respect and professionalism
  • Use company resources responsibly and only for legitimate business purposes
  • Avoid situations that create actual, perceived, or potential conflicts of interest

The company expects all personnel to exercise sound judgment and act in a manner consistent with the values of integrity, fairness, safety, and professional responsibility.

4. Anti-Bribery and Anti-Corruption

Liberty Test & Tag prohibits all forms of bribery, corruption, secret commissions, kickbacks, facilitation payments, or improper inducements.

No person acting on behalf of the company may:

  • Offer, provide, request, or accept bribes or improper payments
  • Provide gifts, hospitality, or benefits intended to improperly influence a decision
  • Accept undisclosed commissions or referral payments
  • Attempt to improperly influence procurement, contract awards, inspections, approvals, or regulatory outcomes
  • Use third parties to engage in conduct prohibited under this policy

Any suspected corrupt or dishonest conduct must be reported immediately to company management.

The company is committed to maintaining ethical and transparent dealings with clients, suppliers, government agencies, and all external stakeholders.

5. Gifts, Hospitality and Entertainment

The company recognises that modest business hospitality may occasionally occur as part of normal professional relationships. However, gifts, hospitality, or entertainment must never compromise, or appear to compromise, professional judgment or impartiality.

Personnel must not:

  • Solicit gifts, benefits, or hospitality
  • Accept gifts or entertainment intended to influence business decisions
  • Offer excessive hospitality or benefits to clients, suppliers, or public officials
  • Accept cash gifts or equivalent benefits

Any gift, hospitality, or benefit offered must remain modest, infrequent, lawful, and professionally appropriate. As a mandatory requirement, gifts or hospitality with an estimated value exceeding AUD $50 must be disclosed to a Director and appropriately recorded.

Personnel should also apply a Reasonable Public Scrutiny Test before accepting any benefit. If the arrangement could reasonably appear inappropriate or capable of influencing a business decision if disclosed publicly or reviewed by a client, regulator, procurement body, or reported in the media, it must be declined.

Additional caution must be exercised when dealing with government agencies, schools, public sector organisations, defence-related environments, or regulated industries.

6. Government and Public Sector Engagement

The company acknowledges that work involving government departments, schools, councils, defence-related sites, regulated environments, and public sector organisations requires a heightened standard of probity and professional conduct.

Personnel representing the company in these environments must:

  • Act transparently and professionally at all times
  • Comply with client site rules, procurement requirements, and confidentiality obligations
  • Avoid any conduct that may create a perception of improper influence or preferential treatment
  • Maintain accurate and honest reporting, documentation, and record keeping

The company does not tolerate attempts to improperly influence procurement decisions, inspections, audits, approvals, or contract outcomes.

7. Conflicts of Interest

A conflict of interest exists where personal interests, relationships, or outside activities could improperly influence, or reasonably appear to influence, business decisions.

Personnel must:

  • Avoid situations that create actual or perceived conflicts of interest
  • Disclose any conflict of interest to company management as soon as practicable
  • Remove themselves from decision-making processes where impartiality may be compromised

Examples may include:

  • Personal relationships with suppliers or clients
  • Financial interests in competing businesses
  • Undisclosed referral arrangements
  • Outside employment that conflicts with company responsibilities

Failure to disclose a conflict of interest may result in disciplinary action.

8. Procurement, Suppliers and Fair Dealing

The company is committed to fair, transparent, and ethical dealings with suppliers, subcontractors, and service providers.

Personnel involved in purchasing or procurement activities must:

  • Act impartially and in the best interests of the company and client
  • Seek value for money and appropriate quality outcomes
  • Avoid undisclosed commissions or referral arrangements
  • Avoid favouritism, improper influence, or biased decision-making

Suppliers and subcontractors engaged by the company are expected to operate lawfully and ethically.

9. Confidentiality and Information Handling

Personnel must protect confidential company and client information obtained during the course of work.

Confidential information must not be:

  • Improperly disclosed
  • Used for personal advantage
  • Shared without authorisation
  • Retained after engagement where not permitted

This obligation applies to:

  • Client records and reports
  • Site information
  • Security-sensitive environments
  • Pricing and commercial information
  • Internal business information

Personnel must also comply with any site-specific confidentiality or security requirements.

10. Reporting Concerns

All personnel have a responsibility to report suspected unethical, unlawful, fraudulent, or improper conduct.

Reports may include concerns relating to:

  • Bribery or corruption
  • Fraud or dishonest conduct
  • Conflicts of interest
  • Improper payments or inducements
  • Misuse of company resources
  • Serious breaches of company policy

Reports should be made directly to company management or directors.

If a concern involves company management or a Director, personnel may raise the matter with an alternative Director, the company's external accountant, legal representative, or another appropriate independent advisor.

The company encourages early reporting of concerns made in good faith, even where all facts may not yet be known.

The company will treat reports seriously and, where appropriate, confidentially. Retaliation against a person who raises a genuine concern in good faith will not be tolerated.

11. Breaches of Policy

Breaches of this policy may result in:

  • Disciplinary action
  • Termination of employment or contractor engagement
  • Removal from client sites or projects
  • Reporting to relevant authorities where required

Serious misconduct, including bribery, fraud, corruption, or deliberate dishonesty, may result in immediate termination and referral to law enforcement or regulatory bodies.

12. Responsibility and Review

Company directors and management are responsible for implementing and overseeing this policy.

All personnel are expected to:

  • Read and comply with this policy
  • Seek guidance where uncertain
  • Act consistently with the company's ethical and professional standards

This policy will be reviewed annually to ensure it remains appropriate to the company's operations, legal obligations, and client expectations.

Document Control

Policy Name: Business Ethics, Anti-Bribery & Professional Conduct Policy

Version: 1.0

Approved By: Mark Peters, Director

Effective Date: May 2026

Review Period: Annual

Schedule A: Initial Disclosure of Interests

Please list any personal, financial, professional, or business interests that may conflict, or reasonably appear to conflict, with your duties at Liberty Test & Tag.

[ ] I have no conflicts of interest to disclose at this time.

Acknowledgement

I, ________________________________________, acknowledge that I have read, understood, and agree to comply with the Liberty Test & Tag Business Ethics, Anti-Bribery & Professional Conduct Policy.

Contractor / Employee (circle one)

Signature:

________________________________________

Date:

______ / ______ / ______