APG Ecommerce Solutions

Anti-Bribery Policy

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Rationale and Scope

The APG Anti-Bribery and Corruption Policy (the Policy) sets out your obligations in relation to anti-bribery and corruption control.

Our reputation, success and sustainability as an organisation depends on not only what we do, but how we do it. It is important for
this reason that we always act with integrity and comply with applicable laws, regulations, codes policies and procedures relating
to bribery and corruption control.

The Policy applies to APG and all of its Workforce Participants worldwide.

Policy Principles

APG’s anti-bribery and corruption principles expect all our Workforce Participants:

are aware of their obligations relating to anti-bribery and corruption under applicable domestic and international laws.
Will not engage in any conduct that constitutes bribery or corruption (including conduct that could be considered corrupt
under the National Anti-Corruption Commission Act (2022).
take steps to address any potential bribery or corruption issues they are aware of, including taking action and referring
all suspected or alleged criminal behaviour to direct line managers, to Australia Post Group Security or through the
Whistleblower process (as per whistleblower policy) or by making a voluntary referral to the National Anti-Corruption
Commission where serious or systemic corruption issues are suspected
to never offer or accept bribes, pay-offs, facilitation payments (payments to speed up routine government
transactions), secret, unjustified or inflated commissions, kickbacks or any other like payments or improper benefits
to or from any person or entity (including Government Officials). This applies regardless of being offered directly or
indirectly, the amount/value, legality or whether it is a common practice within a specific geographic territory.
to ensure all third parties are aware that this policy applies to them when acting on behalf of the APG and conduct
adequate due diligence on bribery and corruption risks.
to consider bribery and corruption as part of risk and compliance due diligence process for any merger, acquisition or
divestment activity proportionate to the risk posed and consider this as part of the decision- making process.
to only provide donations, grants and other funding to community and other not-for-profit organisations which have
had adequate due diligence providing reasonable assurance that they are not a subterfuge for bribery and corruption
(in addition to your obligations to comply with the Group Political Donations Policy).
to maintain and keep accurate financial records as long as legally required and conduct responsible, ethical financial
management.
to ensure that adequate controls are in place across APG to prevent bribery and corruption risks.
to never oﬀer or accept bribes, pay-oﬀs, facilitation payments (payments to speed up routine government
transactions), secret, unjustified or inflated commissions, kickbacks or any other like payments or improper benefits
to or from any person or entity (including Government Oﬀicials). This applies regardless of being oﬀered directly or
indirectly, the amount/value, legality or whether it is a common practice within a specific geographic territory.

Reporting

Suspected bribery or corrupt activity can be reported using one of the following options:

Notifying your immediate manager or supervisor;
using the whistleblower email (Whistleblowing@apgecommerce.com) or the or using our APG Whistleblower form.
Alternatively, if you would like to report directly to the Australia Post Group, you can do so via the Australia Post Group Our Ethics and Whistleblower Reporting Service portal.
contacting Australia Post Group Security either in their local office or on the national number (as set out in Our Ethics on the Australia Post website), or
directly notifying the Australia Post Group Compliance Manager for Ethical Behaviour at EthicalBehaviour@auspost.com.au
(in the case of corruption issues considered serious or systemic) notifying the Group Chief Executive Officer & Managing Director (or their delegate) or a Public Interest Disclosure Officer;
(in the case of corruption issues considered serious or systemic) notifying the National Anti-Corruption Commission.

All suspected bribery or corruption cases must be escalated immediately and in accordance with the Group Incident Management
Standard to ensure preservation and safeguarding of evidence. Anyone raising concerns or reporting another’s wrongdoing in
relation to suspected bribery or corruption issues will be supported. If concerns are raised in good faith under this policy, no
employee will suffer demotion, penalty or other adverse consequences.
It is important to note that third parties may also refer serious or systemic corruption issues involving Australia Post to the
National Anti-Corruption Commission.

Policy Support and Administration

This Policy is made available on the intranet and to subsidiaries and associated entities.
Training will be provided to all Workforce Participants about your rights and responsibilities, and you will be regularly reminded
about your responsibilities under this Policy.

The Policy will be reviewed at least every three years, or whenever there is a material change to the law or operating environment
to ensure it is up to date.

Policy Sponsor: Global HR, Legal & Compliance Director
Policy Owner: CEO
Approved By: Board
Eﬀective Date: 30/09/2025
Next Review Date: 01/06/2028

Glossary
APG	Means Australia Post Global eCommerce Solutions, all of its associated entities.
The Group	The Group means the Australian Postal Corporation, its domestic and foreign-owned subsidiaries, and all of its associated entities.
Bribery	APG defines bribery as the oﬀering, promising, giving, accepting or soliciting of an advantage (financial or otherwise) to induce an action by another entity which is illegal and/or amounts to a breach of trust and/or seeks to obtain an unfair advantage in business transactions. Examples of bribery could include, but are not limited to: facilitation payments (small payments to secure or expedite legal processes). per diem payments to oﬀicials (daily rates of payment for the services of Government Oﬀicials, domestic or international). receiving or being promised financial or non-financial benefits in return for improper performance of duties or abuse of power. oﬀer and/ or the payment of secret commissions (bribes or gratuities) in money, or some other value, to other businesses, individuals, or Government Oﬀicial.
Corrupt Conduct	A person engages in corrupt conduct if: they are a Public Oﬀicial, and they breach public trust; they are a Public Oﬀicial, and they abuse their oﬀice as a Public Oﬀicial; they are a Public Oﬀicial or former Public Oﬀicial, and they misuse information they have gained in their capacity as a Public Oﬀicial; they do something that adversely aﬀects a Public Oﬀicial’s honest or impartial exercise of powers or performance of oﬀicial duties. (Any person can engage in this type of corrupt conduct, even if they are not a Public Oﬀicial themselves). A person also engages in corrupt conduct if they try or plan to do any of those things. A Public Oﬀicial’s conduct may involve one or more types of corrupt conduct.
Corruption	APG defines corruption as dishonest activity in which a director, executive, manager, employee or contractor of an entity acts contrary to the interests of the entity and abuses his/her position of trust in order to achieve some personal gain or advantage for him or herself or for another person or entity.
Corruption Issue	A corruption issue is an issue of whether a person: has engaged in corrupt conduct; or is engaging in corrupt conduct; or will engage in corrupt conduct.
Facilitation payments	Typically, small unoﬀicial payments made to secure or expedite a routine government action by a government oﬀicial.
Government Oﬀicial	Includes: people who are any of: elected or appointed oﬀicials, employees of state or local government institutions or associated government-owned organisations, representatives of international public organisations, political party oﬀicials or candidates for public oﬀice, members of royal families and any individual acting in an oﬀicial capacity on behalf of a government, government agency or organisation; and a Public Oﬀicial.
Public Official	Each of the following is a Public Official: Members and Senators of the Australian Parliament, including ministers, and the people who work for them; staff members of Commonwealth agencies including employees of Commonwealth government departments, Commonwealth companies and statutory bodies and contracted service providers (including consultants, independent contractors, labour-hire contractors, and others providing contracted services to the government); staff members of the NACC; and any person who is acting for and on behalf of, or as a deputy or delegate of, any person or body set out above.
Workforce Participant	Any employees of any company in the Australia Post Group, including our extended workforce of contractors, consultants, licensees, and agents (and their employees and subcontractors), who perform services for the Australia Post Group; and any other third parties performing services for or on behalf of the Group.

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