DONATIONS AND SPONSORSHIPS POLICY
TABLE OF CONTENTS
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PURPOSE AND OBJECTIVES This policy is intended to set out the framework for the evaluation and approval of donations and sponsorships within the Wesfarmers Insurance (WI) division. The policy incorporates the Wesfarmers Limited (Wesfarmers Group) Donations and Sponsorship Policy and is designed to work in conjunction with individual business unit policies. The policy provides a framework and parameters for WI business units. It is recognised that local relevance and alignment to business unit strategies are important and therefore a level of flexibility is allowed within the policy parameters.
BROADER CONTEXT While this policy specifically addresses donations and sponsorships, it also takes into account relevant legislation, other Wesfarmers Group policies and the divisional charter and values. Privacy Information distributed regarding appeals for donations and sponsorships will be communicated in a truthful, inclusive and respectful way. Fundraising appeals will clearly state how the funds raised will be used. Any images or stories will portray people with dignity and respect and personal information will not be disclosed inappropriately, in accordance with the Privacy Act 1988. Anti-bribery policy The Wesfarmers Group and WI have in place an anti-bribery policy which has specific requirements related to charitable donations. Fundraising will not be undertaken where any member of staff would be put under pressure to act or decide in favour of the donor solely because of the donation. The anti-bribery policy sets out the following: Apart from political donations, the Wesfarmers Group may make charitable donations that are legal and ethical under local laws and practices. No charitable donation may be offered or made without the prior approval of the officer responsible for compliance with this policy in the relevant division; and In some countries, charities can be used as a screen for illegal bribes. Care must be taken to ensure that charitable donations are applied for the intended purpose. 1 Compliance with the above is considered in Section 6 of this policy. WI charter and values Any sponsorship and donation activity must align to the WI charter, values and code of conduct. 1 Source:
1.14 Anti-Bribery â€“ April 2012 Final.Doc
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DEFINITIONS Sponsorships Sponsorships are part of a business unitâ€™s marketing strategy and, as such, are expected to give the business unit recognition for their contribution (i.e. it is a form of corporate promotion) and reach an audience relevant to the sponsoring business unit. Sponsorships: usually involve a sponsorship agreement; and must have benefits which are measurable. Donations This policy does not apply to political donations, which are addressed in Section 11 of the Anti-bribery Policy. A donation is a gift of money, time or product to support charitable and community organisations. This may be a one-off contribution or recurring, and is made without any associated expectation of a direct benefit to the business other than to be an active and responsible corporate citizen. The contribution is generally in cash and in response to a request. Where a request is for in-kind assistance, this will be evaluated and counted as a cash equivalent when monitoring the level of support given to the recipient organisation.
CRITERIA FOR SPONSORSHIPS AND DONATIONS Overall criteria The overall criteria for donations and sponsorships by the division or individual business units, are: that they are legal and ethical under local laws and practices; or that they be made to organisations with which the business unit is happy to be associated with and which preferably have direct linkage to the sphere of influence of the business unit; or that they are made for research in an area of benefit or interest to the business. Wesfarmers Insurance | Donations and Sponsorships Policy 4
In some countries, charities can be used as a screen for illegal bribes. Care must be taken to ensure that charitable donations are applied for the intended purpose. Sponsorship criteria Criteria for sponsorships should be determined by each business unit as part of their brand/marketing strategy. Sponsorship should only be provided to organisations with a demonstrated ability to manage their affairs and with good public standing. The recipient should be professionally structured and managed to ensure that the activity is successfully and efficiently run. In accordance with the WI Anti-bribery Policy, no sponsorship may be offered or made without the prior approval of the Anti-bribery Officer. However, the Anti-bribery Officer can provide Standing Authorities to other officers as appropriate. Sponsorship must also be approved by either the WI Managing Director or the WI Board, depending on the amount of the relevant payment.
Donation criteria Business units determine who they support subject to the criteria below. Recipient organisations must be registered as a charity or “not-for-profit” entity with the relevant Government body where appropriate. In accordance with the WI Anti-bribery Policy, no donation may be offered or made without the prior approval of the Anti-bribery Officer. However, the Anti-bribery Officer can provide Standing Authorities to other officers as appropriate. The donation must also be approved by either the WI Managing Director or the WI Board, depending on the amount of the donation. As a guide, the following categories would be supported: Arts, entertainment and culture – locally organised events and activities with broad community appeal. For example, arts and craft fairs. Sport and recreation – junior and senior development programs, clinics and regional carnivals. For example, junior tennis tournament. Youth Support – funding towards programs that provide support and development of youth. For example, school literacy program. Environmentally-friendly – funding towards environmental projects and groups, including those which address environmental problems, climate change and sustainable resource usage. Community welfare – support for charitable, community and welfare organisations such as the Australian Cancer Council daffodil days.
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Safety, health and well-being – safety, health and well-being programs such as ‘R u ok?’ day or Movember. Insurance –related – any activities where the business can leverage its technical expertise for the benefit of the community. The division and business units will NOT support: Appeals from bodies – funding towards events run by organisations that are in themselves grant-making or funding bodies. Culturally sensitive programs – funding to organisations and groups who discriminate or limit membership based on race, colour, creed, gender, beliefs, class, national origin or cultural considerations. Individual/team scholarships – scholarship support is not available for family members of team members and/or local residents to assist meeting the costs of competing at nationally recognised mainstream events at a state or national level. Political organisations or campaigns - contributions or support to organisations or programs whose primary purpose is to elect candidates to public office, influence legislation or public opinion. This excludes relevant industry bodies such as the Insurance Council of Australia, Insurance Council of New Zealand, ANZIIF, NIBA and IBANZ. In line with the Wesfarmers Policy, political donations may not be made at business unit or divisional level. Refer to section 11 of the Wesfarmers Anti-bribery Policy. Religious activities – funding or support to religious organisations undertaking religious activities. However programs offered by the welfare branches of religious organisations are eligible (eg. St Vincent De Paul, Anglicare and the Salvation Army). International activities – generally, activities which are outside the country where the business is located. However, consideration will be given to exceptions on a caseby-case basis (eg. when supporting employee-driven activities). Certain organisations – the division and business units organisations should not be associated with organisations actively promoting alcohol, tobacco, drugs, gambling or firearms.
FUNDING Donations and sponsorships should be budgeted as a separate line item within each business unit. Budgets should be set by the business unit taking into account local market conditions and business sector practice. Individual amounts are subject to approval limits set down by Wesfarmers Limited in the table below. Each business unit is responsible for setting internal approval limits below the maximum amounts of $2,000 for donations and $10,000 for sponsorships, subject to the WI Anti-Bribery Officer provision of standing authorities. Internal approval limits shold be consistent with the business unit’s Delegated Authorities. As noted below, in all cases, donations and sponsorships must be recorded in the divisional database.
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COMPLIANCE Each business unit is responsible for developing procedures to ensure compliance with this policy. WI has put in place a mechanism for each business unit to record sponsorships and donations (the “Gifts, hospitality and donations register” via business unit intranet portals). This information will need to be formally reported to the division as requested, and at least annually. The information should be provided to the divisional WI Anti-Bribery Officer (the WI General Manager, Risk and Compliance) to ensure compliance with the WI anti-bribery policy and for the purposes of annual sustainability reporting and related audits.
HOW TO RAISE A CONCERN WI employees must report donations or sponsorships which they suspect or believe constitute instances of bribery or other improper conduct to their line manager and/or the WI Anti-bribery Officer, or use the procedure set out in the Group’s Whistleblower Policy. A copy of the Group Whistleblowers Protection Policy can be found in the Group Policy Manual, which is available on the WESi/WESe intranet sites. If anyone is unsure whether a particular donation or sponsorship arrangement constitutes bribery or related improper conduct, they should ask their line manager and/or the WI Anti-bribery Officer.
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DOCUMENT MANAGEMENT Information Classification
Internal Use Only External Use Acceptable Confidential Strictly Confidential
Document Number Last Updated
Policy Review Date
Revision Updated to be consistent with the Wesfarmers Donations & Sponsorship Policy.
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