Compliance Policy

About this Policy

This Compliance Policy (Policy) is the Company’s principal policy about compliance with all prevailing and applicable laws and regulations. It is to be read in conjunction with the Company’s policies including (but not limited to) the Compliance Manual and the Code of Conduct and Ethics.

Policy applies to

This Policy governs the conduct of API, its Australian and New Zealand wholly owned subsidiaries and all Directors and employees of those entities.

In addition, API expects contractors, consultants, suppliers, franchisees and other third parties to comply with the ‘spirit and intent’ of this Policy in their dealings with API or when representing API’s interests.

Policy Owner

General Counsel and Company Secretary

Compliance Manager

A Compliance Manager will be appointed and will report to the General Counsel and Company Secretary and the Chair of the Audit and Risk Committee of the Board.

The Compliance Manager will be responsible for coordinating the activities of Compliance Officers including training. The Compliance Manager will provide reports to the Audit and Risk Committee as required.

Compliance Officers

Compliance Officers will be appointed representing key API business divisions. Compliance Officers will be responsible for identifying and resolving division specific compliance issues with support from the Compliance Manager or the API Legal Department as required.

Laws and Ethical Standards

All persons the subject of this Policy must comply, at all times, with all prevailing and applicable laws and regulations governing API’s operations, in keeping with the highest legal, moral and ethical standards.

Interpretation of Laws

It is recognised that, in some cases, there may be uncertainty about which laws and regulations are applicable and there may be difficulties in interpretation. In such circumstances, advice must be sought from the Compliance Manager, Compliance Officers or the API Legal Department to ensure compliance.

Relevant Laws

API’s business is impacted by a number of Commonwealth, State and Territory laws, regulations and codes such as,

  • Trade Practices Act (and relevant Fair Trading Laws)

  • Franchising Code of Conduct

  • Therapeutic Goods Act

  • Privacy Act

  • Corporations Act and ASX Listing Rules

  • Laws relating to the protection of the environment

  • Laws relating to occupational health and safety standards

  • Laws relating to employment

Laws such as the Trade Practices Act are designed to promote competition in business and to protect the interests of consumers. This law generally outlaws anti-competitive agreements or understandings between competitors; certain exclusive supply or distribution arrangements; colluding with competitors on tenders; misuse of market power to damage competitors; anti-competitive mergers and misleading and deceptive conduct.

Reporting of Compliance Issues and ‘Whistleblower’ protection

All persons the subject of this Policy are expected to report information or raise questions about possible violations of this Policy to senior management, the Compliance Manager, Compliance Officers, the API Legal Department or API’s nominated independent whistleblowing service provider using the toll free hotline.

Any such reports by a person acting in good faith can be made without fear or reprisal and information provided will be kept confidential and secure.

Consequences of Breach of Policy

Any person found to be knowingly or recklessly concerned in a contravention of this Policy or any applicable Laws will be subject to disciplinary action which may lead to termination of employment, and may be subject to legal prosecution.

Contravention cannot be justified by claims of ignorance, good intentions or failure to seek legal advice.

Breach of laws can carry potentially serious consequences for the business, employees and other individuals concerned. Consequences can include bad press, substantial fines and imprisonment.

API will not indemnify any such person against any personal liability, penalties or costs arising from such behaviour.

Related policies

Compliance Manual

Code of Conduct and Ethics



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