Our survey of the Top 150 publicly listed companies provides an insight into corporate Australia’s approach to business ethics, codes of conduct and anti-bribery policies. That approach clearly resonates with global trends, with many of the companies surveyed having an international footprint.  

In surveying these policies across the top 150 ASX companies we identified a strong commitment to integrity in business dealings among Australia’s market leaders. Including for the sectors with a large global footprint, we also observed some interesting trends on how anti-bribery policies are evolving, and how approaches to facilitation payments and cash gifts differ among market leaders. 

Facilitation payments

The impact of the UK Bribery Act on corporate Australia’s approach to facilitation payments was seen clearly. While facilitation payments presently remain permitted under Australian law, around 45% of companies elect to publicly ban facilitation payments, in line with international trends. 

Sector variation

In looking at sectors with the widest international reach, it was notable that the top resources companies demonstrated the strongest commitment of all sectors to addressing ethics and integrity in their published materials. Companies in this sector have a very strong tendency to ‘set the tone from the top’, with a higher proportion of companies having values statements referring to integrity/ethics and including a message from senior personnel in their published materials as compared to the average. The proportion of these companies expressly banning facilitation payments and cash gifts was also higher than the average. 

The large Australian banks have also significantly increased their offshore activity in recent years. Against the backdrop of this growth into Asia and beyond, it was interesting to observe that while the vast majority of companies in the banks, financial services and insurance sector publish a code of conduct on their website and over 55% have updated their code in the last two years, they are less likely to publish an anti-bribery policy on their website, and their policies tended to be shorter than average. Companies in this sector are also slightly less likely to expressly ban facilitation payments and cash gifts in their published materials as compared to the average. 

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