Business Integrity (Anti-Corruption Standard)

Corruption is viewed as a set of circumstances whereby there is dishonest or fraudulent conduct by people or groups who are in a position of power in regard their capacity for the granting of potential benefit, business opportunity or positive outcome. It implies as per the Work Health Group Conflict of Interest policy that there is a risk that professional judgement or actions regarding a primary interest will be unduly influenced by a secondary interest.

Secondary interests can relate to the perceived potential for benefit by way of financial gain, professional benefit, reputation, personal relationship, securing business or strategic alliances. It is the specific positive or negative inducement to encourage the misuse of power.


This policy and procedures applies to all directors, managers and employees of WorkFocus Australia atWork Australia and Kairros (referred to the Work Health Group) other than casual employees, except ‘eligible’ casual employees.

This policy is without regard to any regional customs, local practices or competitive conditions.

The Group fully supports its employees who comply with this standard and no employee will be disciplined for refusing to engage in conduct that is contrary to this standard in the event that we lose or do not secure business as a result.

Forms of Corruption

The Group prohibits bribery, corruption and extortion in all forms.

Employees are prohibited from directly or indirectly offering, giving, soliciting or receiving any form of bribe, kickback, payment or anything of value to or from any person or organisation including government agencies, individual government officials, private companies or their employees under any circumstances. Gifts, entertainment or travel must not be given or received as a reward or encouragement for preferential treatment.

The Group does not participate in party politics. It does not make payments to political parties or individual politicians

Employees are prohibited from using any funds, assets, resources, time or employees including in-kind contributions of services to make any political contribution, or assist any party or individual politician or candidate.

The Group does not make charitable donations or sponsorships that could be perceived as bribes or payments to gain an improper business advantage

Avoiding and Managing Business Integrity issues

A risk mitigation approach is adopted in managing any potential corruption issues

The following hierarchy is applied in the consideration of any potential issue arising

The Group determines that the CEO, Directors, Divisional Managers and the Group HR Manager are entrusted officers and have the accountability to ensure

  1. A register is held at a Corporate Services level of any gifts, expenditures made or benefits of any kind that are made or provided to any group or individual, or received by an employee or officer of the Group. This register is reviewed and audited by the Risk Management and Compliance Group on a biannual basis.
  2. Employees or officers of the Group are aware that they are required to seek prior approval before accepting any gift, or benefit in kind from a supplier, customer, public or private agency. Approval to be provided in writing by a Divisional Manager 
  3. Disclosure – It is an employees responsibility to notify their Divisional manager at a minimum level of any approach, implied or actual offer of bribe, payment, gift, benefit or threat to themselves or in the event that they suspect any activity involving a third party.
  4. All internal or external allegations or concerns raised regarding a potential issue will be managed at the Divisional manager level with the Group Manager Human resources with reference to this policy, Conflict of Interest Policy and our Code of Conduct policy and performance management. The delegate for any disciplinary action arising will be the CEO.