Anti-Bribery and Anti-Corruption Policy

1. What is this policy?

MUFG Pension & Market Services is committed to complying with all applicable laws and regulations and conducting our business with the highest standards of ethics and integrity. MUFG Pension & Market Services does not tolerate bribery and corruption. The Anti-Bribery and Anti-Corruption Policy (the Policy) supports the Code of Conduct and Ethics that sets the standards for the way we work.

The Policy sets out the requirements, responsibilities and approach for the governance, prevention, deterrence, detection, investigation and reporting of instances of bribery and corruption involving employees, consultants and/or any other third parties in a business relationship with MUFG Pension & Market Services, including members, investors, customers, clients and vendors.

Words in bold have the meaning stated in ‘Section 8. Definitions’ and appear in bold when first used.

2. Why do we need this policy?

Bribery and Corruption have a detrimental impact on society and the integrity of the markets. MUFG Pension & Market Services aims to act with the highest standard of integrity and honesty in all it does and is committed to drive an effective anti-bribery culture.

Adherence to anti-bribery and anti-corruption best practice governance, controls and compliance is essential to our business principles and is consistent with our values.

The Policy:

• Confirms we will comply at all times with legislation in the jurisdictions where it operates
• Prohibits the promising, offering, giving, solicitation or receiving of bribes and anything of value, directly or indirectly through third parties, including public officials, if improperly intended to influence a course of action or obtain an advantage
• Prohibits falsifying or concealing any records or accounts that relate to the business or that of its customers, suppliers and other business partners
• Confirms that facilitation payments, kickbacks and secret commissions are not acceptable business practices
• Enables staff to understand their roles and responsibilities in the identification, prevention, detection and escalation of bribery and corruption incidents
• Reinforces that we will terminate a contractual relationship with a third party if they are found to have been involved in bribery and corruption activities
• Prohibits all donations to political parties and campaigns, directly and indirectly, and requires approval for attendance at selected events
• Seeks to protect our reputation.

3. Who does the policy apply to?

The Policy applies to MUFG Pension & Market Services Holdings Pty Limited and its subsidiaries (MUFG Pension & Market Services) directors, employees, contractors and all other people who represent us or undertake work for our benefit (our People) globally.

Compliance with the Policy is mandatory, and no exceptions are allowed.

4. How to comply with this policy?

MUFG Pension & Market Services has adopted a risk-based approach to managing bribery and corruption which recognises that the threat posed varies across the jurisdictions and business sectors in which we operate, and the nature of the business we transact. 

Responsibilities have been assigned to each of the Board, management, Risk and Compliance team, and employees.

4.1 Responsibilities of the board

The Board is ultimately accountable for managing the risk of bribery and corruption and is committed that no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption practices, or because of reporting in good faith their suspicion that an actual or potential bribery or corruption offence has taken place or may reasonably occur in the future. 

4.2 Responsibilities of management

Management must:

• Review the risk factors relevant to their business activities, jurisdictions of operations and business relationships with third parties, including public officials and carry out regular risk assessments
• Implement appropriate controls to mitigate identified risks
• Conduct proportionate due diligence on all business relationships and promote appropriate governance
• Only make or accept payments in accordance with contractual obligations
• Monitor that all sponsorships and charitable donations are approved in line with normal purchasing procedures, and that due diligence is carried out on recipient bodies to prevent real and perceived undue business advantage being gained in this way
• Report regularly to the relevant business unit Risk Committee regarding risks and incidents, with appropriate escalation to the respective Divisional Head of Risk and Compliance. 

4.3 Responsibilities of the divisional heads of risk and compliance

The Divisional Heads of Risk and Compliance are responsible for implementing the Policy and assisting management in identifying bribery and corruption risks, overseeing controls implemented to mitigate existing and emerging bribery and corruption risks and overseeing the investigations of suspected or actual bribery and corruption incidents or misconduct.

4.4 Responsibilities of employees

All employees must:

• Act with honesty and integrity and in the best interests of MUFG Pension & Market Services and those parties with it has a business relationship, and not engage in bribery or any other corrupt behaviour
• Comply with the Policy requirements, complete and follow the anti-bribery and anti-corruption training requirements
• Declare all gifts and hospitality provided and received, in line with the reporting and approval requirements of the Gifts and Hospitality Policy
• Be alert to any suspected or actual unethical or corrupt activity and report promptly all behaviour that is unlawful, improper, unethical or criminal in nature.

Employees may attend political party conferences and political functions in their capacity as a MUFG Pension & Market Services employee, only with the approval of the Managing Director (or Chairman for a Director), for commercial reasons and where the proposed amount to be paid is not in excess of the value of the function.  

4.5 Jurisdictional regulatory obligations

Businesses in all jurisdictions must comply with the requirements of this Policy. In jurisdictions where the local legislative and regulatory requirements exceed the requirements set out in this Policy, the businesses operating those jurisdictions must comply with such higher standard. 

4.6. Training and access to the Policy

All directors, employees and selected contractors are required to undergo training on the Code of Conduct and Ethics, which includes bribery and corruption content, at the beginning of their employment and on an annual basis thereafter.  

The Policy is available on our website, intranet and on request from the Risk and Compliance team.

5. How will policy compliance be monitored?

5.1 Reporting and monitoring

Bribery and corruption incidents may be reported through a range of channels, including Incidents and Suspicious Matters Reporting (via the GRC system), line managers, business unit risk and compliance managers, the human resources team and the Executive Leadership Team.

In order to facilitate the process for reporting of bribery and corruption and any other disclosures of serious concerns, we have also established a Whistleblower Policy and has implemented various channels (internal and external) through which employees and other eligible persons can report suspected or actual incidents anonymously if they choose.

Any matters of a criminal nature will be reported by the Chief Financial Officer, in consultation with the Chair of the Board Risk Committee, to the police and, if appropriate, other appropriate regulatory authorities. 

Any material breaches of the Policy will be reported to the Board or the Board Risk Committee. 

5.2 Non-compliance

Failure to take reasonable steps to comply with this policy may result in disciplinary action, up to and including termination of employment. Such persons may also face civil or criminal actions.

Infringement of this Policy may have serious implications for the reputation of the company, including adverse regulatory and media comment together with the possibility that serious criminal or civil penalties may be levied.

6. What does MUFG Pension & Market Services expect from third parties?

Third parties, such as suppliers, agents, or anyone engaged by them to act for or on behalf of the MUFG Pension & Market Services must not: 

• Offer, give, request, agree to receive, or accept a bribe, or
• Do anything to circumvent controls in place to deter, prevent or detect bribery. 

Third parties are expected to have controls and processes in place that are: 

• Proportionate to the bribery risk
• Communicated to all relevant parties, and
• Reviewed regularly and reflect current legislation and best practice. 

To the extent permitted under applicable law and in accordance with contractual requirements, third parties must, as soon as reasonably practicable, notify us if a person acting on their or our behalf is suspected of bribery or corrupt practices or prosecuted, charged with or convicted of any Bribery or Corruption related offences.

7. Are there any interrelated policies?

This Policy should be read in conjunction with:

• MUFG Pension & Market Services Code of Conduct & Ethics
• MUFG Pension & Market Services Gifts & Hospitality Policy
• MUFG Pension & Market Services Fraud Prevention Policy
• MUFG Pension & Market Services Incident Management Policy
• MUFG Pension & Market Services Global Whistleblower Policy

8. Definitions

[Last updated: 22 August 2024]