Canzuki Anti-Bribery and Anti-Corruption Policy

Last Updated: April 2024

1. Introduction

Canzuki Limited is committed to conducting its business with the highest ethical standards. This Anti-Bribery and Anti-Corruption Policy (the “Policy”) prohibits all forms of bribery and corruption by or on behalf of the Company, its employees, contractors, agents, and representatives. We operate globally and are subject to various anti-bribery and anti-corruption laws and regulations, including the New Zealand Crimes Act 1961 and the Secret Commissions Act 1910. This Policy outlines our commitment to complying with these laws and maintaining a culture of integrity.

2. Definitions

• Bribery:
  Offering, promising, giving, authorizing, or soliciting anything of value to someone (including a public official) to influence their actions or obtain an improper advantage.

• Corruption:
  Any act that undermines the integrity of a process or institution, including bribery, abuse of power, and illicit enrichment.

• Facilitation Payment:
  Facilitation payments are unofficial or customary payments made to expedite routine governmental action. While they are generally considered illegal under New Zealand law, there might be limited exceptions.
  This policy prohibits facilitation payments.

• Public Official:
  Any person employed by a government body at a national, regional, or local level or an official of a public international organization.

• Conflict of Interest:
  A situation where a person’s interests conflict with their professional duties.

• Compliance Officer:
  Currently, this role is performed by the Managing Director.
  

3. Prohibited Conduct

The following activities are strictly prohibited under this Policy:

• Offering, promising, giving, authorizing, or soliciting bribes (including facilitation payments) to public officials or any other person in New Zealand or overseas.

• Accepting any bribe or improper advantage.

• Engaging in any activity that could be construed as a bribe, even if not successful.

• Engaging in corrupt practices, such as embezzlement, fraud, or collusion.

• Failing to disclose a potential conflict of interest.
  

4. Gifts and Hospitality

Offering or accepting gifts and hospitality must be done in a reasonable, proportionate way and does not create a perception of improper influence. Consider the following guidelines:

• The value of the gift or hospitality should be modest and not extravagant.

• The timing and context of the gift or hospitality should be appropriate.

• The gift or hospitality should not create an obligation for the recipient.
  

Employees unsure about the appropriateness of a gift or hospitality should seek guidance from their supervisor or the Compliance Officer.

5. Record Keeping

The Company maintains a system in our accounting package for recording all gifts and hospitality received or offered by employees. This includes details about the recipient/giver, the nature of the gift/hospitality, and the business purpose.

6. Reporting

Employees are encouraged to report any suspected violations of this Policy to their supervisor, the Compliance Officer, or anonymously through a designated reporting channel. The Company will not tolerate retaliation against any employee/contractor who reports a potential violation in good faith.

7. Training and Awareness

The Company will train employees/contractors on this Policy and applicable anti-bribery and anti-corruption laws. Employees are responsible for familiarizing themselves with this Policy and seeking clarification when necessary.

8. Consequences of Violations

Violations of this Policy may result in disciplinary action, including termination of employment. The Company may also be subject to legal penalties and reputational damage.

9. Review and Update

This Policy will be reviewed and updated periodically to ensure it remains effective in light of any laws, regulations, or best practices changes.

10. Disclaimer

This Policy is intended to provide general guidance and should not be interpreted as legal advice.