Governance

Augmentium is committed to conducting its business with the highest standards of integrity, honesty, and transparency. We recognise that fraud and corruption can severely damage the reputation and financial wellbeing of the Company and its stakeholders. This Prevention of Fraud and Corruption Policy ("Policy") outlines the Company's commitment to preventing and addressing fraudulent and corrupt practices in the course of our business operations, both domestically and internationally.

This Policy applies to all employees, contractors, consultants, and agents of Augmentium and sets out our expectations regarding appropriate conduct in relation to the prevention of fraud and corruption.

The purpose of this policy is to:

Provide clear guidelines on the Company’s commitment to prevent fraud and corruption.
Establish the roles and responsibilities of Personnel in maintaining ethical practices.
Outline the procedures for reporting suspected fraudulent or corrupt activities.
Ensure compliance with relevant Australian laws and international anti-corruption standards, including the Criminal Code Act 1995 (Cth), Foreign Corrupt Practices Act (USA), and the UK Bribery Act 2010, among others.

Definition of Fraud and Corruption

For the purposes of this Policy, the following definitions apply:

Fraud: The intentional act of deception, misrepresentation, or concealment for personal or financial gain. This includes but is not limited to falsification of financial records, misappropriation of assets, and fraudulent billing practices.
Corruption: The abuse of power or position for personal or financial gain, including offering, receiving, or soliciting bribes, kickbacks, or any other forms of improper inducements or favours.

Prohibited Conduct

The Company prohibits any form of fraud or corruption, including but not limited to:

Offering or receiving bribes or kickbacks in exchange for business advantages.
Engaging in fraudulent activities such as embezzling funds, falsifying invoices, or misreporting financial statements.
Offering or accepting gifts or hospitality that could influence business decisions or create a conflict of interest.
Misuse of the Company's assets, resources, or confidential information for personal gain.
Providing or accepting facilitation payments (small bribes to expedite or secure routine government services).

Roles and Responsibilities

All Personnel are expected to:

Act with integrity and honesty in all professional dealings, both within the Company and with clients, suppliers, and business partners.
Be aware of and adhere to the provisions of this Policy in their day-to-day operations.
Report any suspected or actual fraud or corruption in accordance with the procedures outlined below.
Cooperate with any investigations into fraudulent or corrupt activities.
Ensure that their conduct does not create the appearance of impropriety or conflict of interest.

Reporting Mechanism

Personnel are encouraged to report any concerns about fraudulent or corrupt activities, whether witnessed directly or suspected. The Company has established the following procedures for reporting:

Reports should be made in good faith, without fear of retaliation.
Suspected fraud or corruption should be reported to the Managing Director or a designated senior manager.
In the case of a serious concern, Personnel may use the Company’s confidential reporting channels, which may include a whistleblower hotline, email, or external reporting services.
All reports will be treated confidentially, and, where necessary, investigated promptly and thoroughly.

Investigations and Consequences

Any reports of fraud or corruption will be investigated thoroughly and promptly. The Company will take appropriate action in response to confirmed breaches of this Policy, which may include:

Disciplinary action, up to and including termination of employment or contract.
Reporting the matter to relevant law enforcement authorities, regulatory bodies, or external auditors.
Legal action to recover any misappropriated funds or damages caused by fraudulent or corrupt activities.
Reporting the incident to clients or business partners where necessary to mitigate damage to reputation or business relationships.

Environmental Training and Awareness

To ensure effective implementation of our EMS, the Company will:

Provide training to all employees and contractors on environmental issues relevant to their roles, including waste management, energy efficiency, and sustainable practices in infrastructure projects.
Conduct ongoing training and awareness programs to ensure that all Personnel are aware of their environmental responsibilities and the Company’s objectives.
Encourage employee participation in sustainability initiatives and support the adoption of environmentally responsible practices in the workplace.
Offer specialised training for those involved in project management or areas with higher environmental impact, such as construction, to ensure compliance with environmental standards and best practices.

Monitoring, Auditing, and Reporting

The Company will continuously monitor and review its environmental performance, including:

Regular Audits: Conducting internal audits to assess compliance with environmental policies, identify potential risks, and evaluate the effectiveness of environmental controls.
Performance Monitoring: Tracking key environmental indicators, such as energy usage, waste production, emissions, and resource consumption, and assessing whether environmental targets are being met.
Corrective Actions: Taking corrective actions to address any environmental non-conformities or issues identified during audits, monitoring, or from employee/contractor feedback.
Management Review: Conducting periodic management reviews to assess the performance of the EMS, set new environmental objectives, and ensure that the system is aligned with ISO 14001 standards and Company goals.

Training and Awareness

The Company is committed to ensuring that all Personnel understand and comply with this Policy. As such, the Company will:

Provide regular training and awareness programs on fraud and corruption prevention.
Incorporate the principles of this Policy into the Company’s induction programs for new hires.
Maintain accessible resources for Personnel to consult when uncertain about specific situations or actions that may constitute fraud or corruption.

Compliance with Laws and Regulations

The Company will ensure compliance with all applicable anti-fraud and anti-corruption laws, including both Australian and international legislation. All Personnel are expected to:

Be familiar with the relevant laws and regulations that apply to their work.
Comply with the Company’s internal controls, policies, and procedures designed to prevent fraud and corruption.
Avoid engaging in activities that could result in violations of anti-corruption laws, particularly in countries with higher corruption risks.

Policy Review and Approval

This Policy will be reviewed periodically to ensure its effectiveness and to incorporate any updates in applicable laws or best practices. The Company reserves the right to amend this Policy at its discretion.