DRA is committed to upholding the highest levels of professional standards and conduct in the collections industry. We have modelled our anti-corruption policy on proven experience and best practice. This policy is outlined below.
1.1 Anti-Corruption Policy
All staff at DRA are responsible for corruption prevention and detection. Any such behaviour is always reported to management. Bribery and corruption is strictly against company policy, and DRA is committed to complying with bribery and corruption laws in all of the jurisdictions in which it operates. The objective of this policy is to define unacceptable behaviour relating to bribery and corruption and to direct its identification and prevention.
We understand that while corrupt behaviour need not involve a criminal act, such as being bribed to steal something, it can involve a corrupt act, such as giving a person a benefit to which they are not entitled.
The following steps provide our staff with clear procedures on how to handle and prevent corrupt behaviour at DRA:
- If any staff member is offered a bribe, they must immediately terminate the conversation, task or meeting. If it happens on DRA property, they must excuse them self and immediately contact their supervisor, who will inform the operations manager.
- If corrupt behaviour happens outside of the office, our staff must return to the office and as soon as possible and record what happened, including the time and exact words used. This is vital for their protection and may be used in an investigation.
- Offers of money and/or bribes in any form should never be accepted. Under no circumstances should our staff endanger themselves or attempt a citizen’s arrest. DRA will contact the appropriate authorities.
- When an ambiguous and potentially corrupt statement is made, such as “We might be able to sort something out” or “Perhaps I can do you a favour”, clarification of this statement must be sought. This will find out whether it’s a simple misunderstanding or an attempt at bribery and corruption.
1.2 Gifts, Favours and Hospitality
DRA has strict policies regarding the acceptance of gifts, favours and hospitality. We simply state that our staff cannot demand or accept any type of payment (financial, gifts or favours) for services performed in the normal course of duties, whether before, during or after hours. This excludes activities for which DRA charges a fee.
We do not allow offers of money in any form to be accepted. All gifts and benefits received become the property of DRA and its use or disposal is the responsibility of DRA, not the staff member. This can take many forms, including donation to a social club or a charity. In some circumstances, staff may be allowed to keep a gift.
All gifts or benefits received must be notified to the operations manager. Our staff are asked to exercise judgment when offered gifts or favours by any person or organization, as accepting an offer of gifts or favours, even of a token kind, can appear to compromise our professional integrity.
1.2.1 Example of Acceptable Gifts and Benefits
- Unsolicited gifts or benefits of nominal value, or of an inconsequential or trivial nature, where there is no real or apparent conflict of interest. For example marketing items such as corporate mementos, pens, mugs, notepads and key rings
- Modest hospitality simultaneously available to colleagues such as tea, coffee and a modest lunch. In some cases, this can be regarded as a common courtesy, as opposed to a gift or benefit
- Prizes won as a result of conducting official business
- Invitations to local sporting or cultural functions where our presence does not imply an inappropriately close or preferred relationship with the person or company who invited u.
We would record these gifts in a Gift Registry to ensure a record of propriety.
1.2.3 Examples of Unacceptable Gifts and Benefits
- Tickets to sporting events or other entertainment
- Sports team sponsorship by a supplier
- Free or discounted products for personal use, such as use of a gym, holiday accommodation or personal travel
- Expensive alcoholic beverages
- Club memberships or magazine subscriptions that have only been made available to one person.
- Any gift, benefit or hospitality during any period of contract negotiation.
1.3 Reporting of Corrupt Behaviour
All DRA staff are fully conversant with our anti-corruption policies and process, as it a mandatory topic in our staff induction program. This ensures that, should corrupt behaviour be identified, they are well equipped to put the following process into action.
Where corrupt behaviour has been identified, the immediate supervisor is advised. They meet with the accused consultant within 24 hours to discuss the accusation and if the consultant is not at work it must occur as soon as they return.
The accused consultant has two business days to respond to the accusation. The consultant meets with their supervisor and/or the operations manager to discuss the accusation and provide their side of the allegation. DRA can instigate a formal investigation, either internally or by an external consultant. The investigator has five working days to complete the investigation and make recommendations.
Depending on the investigation’s outcome and recommendations, the following actions may occur:
- The matter is referred to police.
- Employee is terminated
- Employee is demoted
- Employee is cleared of the allegation.
All parties are advised of the investigation’s findings and given a copy of the report.