Fraud, Bribery & Corruption Policy

Status: v1.0
Tier: Tier 1 – Core Corporate & Platform Policy
Owner: Governance and Compliance Function
Approval Authority: Board of Directors
Effective Date: 5 January 2026
Next Review: 12 months from approval

1. Purpose

This policy sets out Global Talent Pathway’s approach to preventing, detecting, and responding to fraud, bribery, corruption, and related misconduct.

Its purpose is to:

  • protect the integrity of Global Talent Pathway’s operations,

  • ensure lawful and ethical conduct,

  • manage financial, legal, and reputational risk, and

  • meet expectations of government, enterprise clients, and regulators.

2. Scope

This policy applies to:

  • Global Talent Pathway staff and officers,

  • Board and Advisory Board members,

  • contractors, consultants, and agents,

  • suppliers and service providers,

  • employers and recruiters engaging with Global Talent Pathway,

  • any other parties acting on behalf of Global Talent Pathway.

This policy applies across all jurisdictions in which Global Talent Pathway operates.

3. Policy Statement

Global Talent Pathway has zero tolerance for fraud, bribery, corruption, or dishonest conduct.

We are committed to taking reasonable, proportionate, and risk-based steps to prevent, detect, and respond to such conduct.

4. Definitions

For the purposes of this policy:

  • Fraud includes any dishonest act or omission intended to gain an improper benefit or cause loss, including misrepresentation, falsification of records, or misuse of assets.

  • Bribery includes offering, giving, receiving, or soliciting anything of value to improperly influence a decision or action.

  • Corruption includes abuse of position or power for personal or organisational gain.

  • Improper benefit includes financial or non-financial advantages.

5. Prohibited Conduct

The following conduct is prohibited:

  • falsifying records, documents, or information,

  • misappropriating funds or assets,

  • offering or accepting bribes, kickbacks, or facilitation payments,

  • providing gifts or hospitality intended to improperly influence decisions,

  • manipulating recruitment, placement, or supplier processes for improper benefit,

  • concealing or enabling fraudulent or corrupt conduct.

6. Gifts, Benefits and Hospitality

Gifts, benefits, or hospitality must:

  • be modest, infrequent, and reasonable,

  • not influence or appear to influence decision-making,

  • not be offered or accepted during procurement, recruitment, or decision-sensitive processes.

High-risk gifts or benefits must be declared and may be refused.

7. Responsibilities

Global Talent Pathway

  • Maintain and enforce this policy.

  • Implement controls proportionate to risk.

  • Investigate suspected breaches.

  • Take appropriate corrective action.

Staff and Representatives

  • Act honestly and ethically.

  • Comply with this policy and applicable law.

  • Declare conflicts of interest.

  • Report suspected misconduct promptly.

Suppliers, Employers and Recruiters

  • Comply with this policy.

  • Not engage in prohibited conduct.

  • Cooperate with investigations and controls.

8. Risk Management Controls

Controls may include:

  • segregation of duties,

  • approval and authorisation requirements,

  • monitoring and audits,

  • due diligence on third parties,

  • contractual prohibitions.

The absence of a control does not authorise misconduct.

9. Reporting and Investigation

Suspected fraud, bribery, or corruption must be reported through the Complaints & Disclosures Gateway.

Reports may be made confidentially or anonymously.

Investigations will be:

  • conducted fairly and independently,

  • proportionate to the risk and complexity,

  • documented appropriately.

10. Consequences of Breach

Breaches of this policy may result in:

  • disciplinary action,

  • termination of employment or contracts,

  • termination of supplier or employer relationships,

  • referral to law enforcement or regulators where required by law.

11. No Retaliation

Retaliation against individuals who report concerns in good faith is prohibited and may result in serious consequences.

12. Recordkeeping

All reports and investigations are:

  • recorded securely,

  • access-restricted,

  • retained in accordance with the Records Management & Retention Policy.

13. Relationship to Other Policies

This policy operates alongside:

  • Whistleblower Policy,

  • Complaints Policy,

  • Conflict of Interest Policy,

  • Modern Slavery & Human Trafficking Policy,

  • Ethical Recruitment & Fair Work Policy.

In the event of inconsistency, Tier 1 policies prevail.

14. Review

This policy will be reviewed annually and updated as required.