ANTI-BRIBERY AND CORRUPTION POLICY

1. Purpose

General and Travel Investigations Limited (GTI) ("the Company") is committed to conducting business with integrity, transparency, and accountability.

This Anti-Bribery and Corruption Policy ("Policy") sets out the Company’s stance on bribery and corruption and provides guidance to employees, contractors, and business partners on how we uphold our ethical standards.

2. Scope

This Policy applies to all employees, contractors, consultants, agents, and any other individuals or entities acting on behalf of the Company, regardless of location.

3. Definition of Bribery and Corruption

Bribery refers to offering, giving, receiving, or soliciting anything of value to improperly influence a business outcome or gain an unfair advantage.

Corruption refers to dishonest or fraudulent conduct by those in power, typically involving bribery.

4. Prohibited Conduct

The Company strictly prohibits:

  • Offering, promising, or giving a bribe to any person or entity, including government officials, clients, or suppliers.

  • Soliciting, accepting, or receiving a bribe.

  • Making facilitation payments (small, unofficial payments to expedite routine actions).

  • Engaging in corrupt practices, including fraud, embezzlement, or misuse of assets.

5. Gifts, Hospitality, and Entertainment

Employees and representatives of the Company must:

  • Ensure that any gifts, hospitality, or entertainment provided or received are reasonable, proportionate, and transparent.

  • Not offer or accept gifts intended to improperly influence a business decision.

  • Seek approval for gifts, hospitality, or entertainment exceeding a reasonable threshold as defined in Company guidelines.

6. Third-Party Relationships

The Company requires due diligence when engaging third parties, including suppliers and business partners. 

7. Reporting and Whistleblowing

Employees and business partners must report any suspected or actual breaches of this Policy.

Reports can be made confidentially via Privacy@GTI.co.nz  

Please provide details of the matter and supporting evidence.

The Company prohibits retaliation against individuals who report in good faith.

8. Compliance and Training

All employees must complete anti-bribery and corruption training as required by the Company.

Compliance with this Policy is mandatory, and breaches may result in disciplinary action, including termination of employment or contract.

9. Consequences of Non-Compliance

Non-compliance with this Policy may result in severe legal and reputational consequences, including criminal liability for individuals and the Company.

The Company reserves the right to take disciplinary action, up to and including termination and legal action, for any violations.

10. Review and Amendments

This Policy will be reviewed periodically to ensure effectiveness and compliance with relevant laws and regulations.

Amendments may be made as necessary.

For any questions or concerns regarding this Policy, please contact Privacy@GTI.co.nz  

Approved by: Brook Ballantyne
Published: 1st Feb 2025