Anti-Bribery & Corruption Policy

This Anti-Bribery and Corruption Policy sets out Compass IoT's approach to preventing bribery and corruption across all of its operations. It is aligned with the Australian Criminal Code Act 1995 (which contains offences relating to foreign bribery), the UK Bribery Act 2010, and the US Foreign Corrupt Practices Act (FCPA).

This policy applies to Compass IoT Pty Ltd and all of its subsidiaries, related entities, employees, contractors, directors, and any third parties — including agents, consultants, and partners — acting on our behalf. It covers conduct in Australia and in any other jurisdiction in which Compass IoT operates or conducts business.

This policy is reviewed annually and updated to reflect changes in our operations or applicable law.

Bribery is the offering, giving, receiving, or soliciting of something of value in order to improperly influence the actions of a person in a position of trust — whether in the public sector or private sector. Corruption is a broader term encompassing dishonest or fraudulent conduct by those in power.

Bribery and corrupt conduct can take many forms, including:

The following commitments apply to all employees, contractors, directors, and third parties acting on behalf of Compass IoT:

Every person covered by this policy is personally responsible for reading, understanding, and complying with it. Compliance is not optional and is a condition of employment or engagement with Compass IoT.

Employees and contractors are responsible for avoiding conduct that breaches this policy, raising concerns promptly when they arise, and completing any anti-bribery training required by the company.

Managers and team leads are responsible for ensuring that those they supervise understand and apply this policy, and for creating an environment where concerns can be raised without fear of retaliation.

The leadership team is responsible for maintaining this policy, investigating reports of potential breaches, and ensuring that appropriate action is taken when a breach is confirmed.

All new employees and contractors receive anti-bribery and corruption awareness training as part of their onboarding. All covered persons are required to complete refresher training on an annual basis.

Training covers the key provisions of this policy, how to identify bribery and corruption risks, the process for raising concerns, and the consequences of non-compliance.

Anyone who suspects or becomes aware of conduct that may breach this policy is encouraged to raise it as soon as possible. Concerns can be raised by emailing trust@compassiot.com with the subject line "Anti-Bribery Concern", or directly with any member of the Compass IoT leadership team.

All reports will be taken seriously, investigated promptly, and treated as confidentially as circumstances permit. Compass IoT will not retaliate against any person who raises a concern in good faith — even if the concern ultimately proves unfounded.

Bribery and corruption are serious offences under Australian, UK, and US law. Individuals found guilty can face significant criminal penalties including imprisonment and substantial fines. Compass IoT as an organisation may face prosecution, fines, reputational damage, and exclusion from future contracts.

Any employee or contractor who breaches this policy — or who fails to report a known or suspected breach — will be subject to disciplinary action, up to and including termination of employment or engagement. Where conduct may constitute a criminal offence, Compass IoT will report it to the relevant authorities.

This Anti-Bribery and Corruption Policy was approved in January 2025 and will be reviewed regularly.