This policy is in support of LKA’s commitment to a high standard of integrity, maintaining good governance and supporting the confidence of our clients and other stakeholders.
This policy applies equal obligations to all staff and contractors.
- Any gift, act, or benefit, received or offered by an LKA Group representative, which will or will appear to compromise LKA’s integrity and objectivity is to be reported to the LKA Corporate Services manager, and handled as per LKA’s determination
- Any gift, act or benefit, received or offered by an LKA Group representative, which will or will appear to give rise to a conflict of interest is to be reported to the LKA Corporate Services manager, and handled as per LKA’s determination
Benefits not requiring declaration are:
- Work related conferences
- Invitations to speak
- Working lunches
- Token gifts of very low value
- Charitable contributions which are legal, ethical and in relation to an approved charitable effort endorsed or approved by the LKA Corporate Services Manager
Assessment of gifts
Gifts, acts or benefits referred to the Corporate Services Manager for decision will be assessed and acceptability determined based on the circumstances as a whole, including whether the gift, act or benefit:
- Is in accordance with the LKA Group values
- Is reasonable, appropriate and proportionate
- Is free from obligation or expectation held by either the giver or recipient
- Is to be documented, registered or notified to any relevant stakeholders
- Is made openly and without secrecy
- Is made impersonally or widely
- Is legal and compliant with relevant regulations
- Is offered in circumstances where refusal would be unreasonable and/or unnecessarily offensive
- Complies with other LKA Group policies and procedures
- Compliance with any obligations to third parties
Any employee or contractor who detects or observes any breach of this policy is required to report it to the Corporate Services Manager as soon as reasonably practicable, or to the managing director.
LKA Group prohibits reprisals against any party making such a report.
Consequences of a breach
Any employee or contractor found to be in breach of this policy may be treated has having committed serious misconduct leading to disciplinary action, which can include termination of employment or any other action. Nothing in this policy prevents the application of civil or criminal liability for any breach, and the related penalties.
Date: 7 March 2019