Internal Control Compliance Policy for Overseas Operations

Date of Issue: 21 May 2025

Organisation: Australian Institute of Pharmacognosy

1. Purpose

This policy outlines the internal control procedures used by the Australian Institute of Pharmacognosy to ensure its overseas activities comply with Australian legal requirements related to criminal, humanitarian, and financial conduct. The Institute upholds its responsibility to act ethically and lawfully in all jurisdictions.

2. Scope

This policy applies to all personnel, volunteers, directors, and third-party organisations involved in overseas operations or funded by the Institute. It also applies to any entity receiving funds, equipment, or services from the Institute outside of Australia.

3. Legal Compliance Obligations

The Institute’s internal controls are designed to ensure full compliance with Australian laws addressing the following matters:
- Money laundering
- Financing of terrorism
- Sexual offences against children
- Slavery and slavery-like conditions
- Trafficking in individuals and debt bondage
- People smuggling
- International sanctions
- Taxation (Australian and applicable local laws)

4. Internal Control Procedures

The following internal controls are implemented to ensure compliance:

- Conducting due diligence on all overseas partners and beneficiaries.

- Screening all third parties against Australian and international sanctions and watchlists.

- Requiring all overseas agreements to include clauses prohibiting illegal activity and mandating compliance with Australian laws.

- Training personnel and volunteers on identifying red flags for illegal conduct, including modern slavery, trafficking, and child exploitation.

- Requiring all financial transactions to be documented, traceable, and approved by two authorised individuals.

- Maintaining records of all overseas activities for auditing and regulatory review.

- Prohibiting the transfer of funds to individuals or organisations in breach of Australian law or international sanctions.

5. Reporting and Whistleblower Protections

Any person associated with the Institute may confidentially report suspected breaches of law or policy. Reports will be reviewed promptly by the Chair or designated officer. Whistleblowers are protected from retaliation and may choose to remain anonymous.

6. Review and Policy Updates

This policy shall be reviewed every two years or sooner if required by changes to applicable law or operational expansion.

7. Approval

Approved by the Board of the Australian Institute of Pharmacognosy.