Fraud, Bribery and Corruption Control Policy

1. Policy statement

Axiom Data does not tolerate fraud, bribery or corruption, whether committed by its own people, its candidates, its partners or anyone acting on its behalf. We prevent it by design, detect it through routine checks, and respond to it promptly and transparently, including by reporting to clients and authorities where required.

2. Scope and application

This policy applies to Ontology Analytics Pty Ltd, trading as Axiom Data (Axiom Data) and to every director, employee, labour-hire worker, contractor and agent engaged by Axiom Data, whether working at Axiom Data's premises, remotely, or on placement at a client site. Where a worker is placed with a client, this policy applies alongside the client's own policies; where the two differ, the worker follows the stricter requirement and raises the difference with Axiom Data.

3. Definitions

• Fraud: dishonestly obtaining a benefit, or causing a loss, by deception or other means. In our business the most likely forms are false or inflated timesheets, misrepresented qualifications, experience, citizenship or security clearances, falsified referees, and invoices for services not delivered.
• Bribery: offering, promising, giving, requesting or accepting anything of value to influence a person in the performance of their duties, including facilitation payments.
• Corruption: the abuse of a position of trust for personal gain, including collusion to distort a procurement and the misuse of official information.

4. Fraud risk assessment

The Director conducts and documents a fraud and corruption risk assessment at least every two years, and after any incident or material change in the business. The assessment identifies the fraud risks in each process (sourcing, candidate verification, submission, timesheeting, invoicing, payroll, partner payments and procurement), rates their likelihood and consequence, and records the controls in place and any action required.

5. Preventive controls

6. Detection

• Monthly reconciliation of approved timesheets, invoices and payroll by the Director.
• Quarterly superannuation and entitlement reconciliation with the external bookkeeper.
• Annual review of candidate verification records for a sample of placements.
• Open channels for workers, clients and partners to report concerns, including anonymously.

7. Response

1. A suspected fraud or corruption matter is reported to the Director (or, if it concerns the Director, to the company's external adviser) and recorded under the Incident Reporting Procedure (POL-05).
2. The matter is assessed within two business days to decide whether an investigation is required and whether any immediate step (such as suspending a worker from a placement or withholding an invoice) is needed to prevent further loss.
3. An investigation is conducted by a person independent of the matter, with findings documented. Evidence is preserved.
4. Affected clients are informed promptly of any matter touching their contract. Matters involving Commonwealth officials, funds or contracts are referred to the client agency and, where required, to the National Anti-Corruption Commission or the Australian Federal Police.
5. Losses are recovered where possible, disciplinary or contractual action is taken, and the controls that failed are corrected.

8. Training and awareness

This policy, with the Code of Conduct, is part of induction for every employee and placed worker, and is refreshed annually. Workers on placement are reminded that their client's fraud and corruption policies also apply to them.

9. Breaches of this policy

A breach of this policy is a serious matter. Depending on the circumstances it may result in counselling, a written warning, removal from a client placement, termination of employment or engagement, and, where the law requires, referral to the relevant authority. Axiom Data will not take adverse action against anyone for raising a genuine concern in good faith.

10. Review

This policy is owned by the Director and is reviewed at least annually, and sooner if legislation, a client requirement or an incident shows the need. The current version, effective date and next review date are recorded in the policy register on the Employee Resources page.