Anti-Bribery & Anti-Corruption Policy


Bribery is, in the conduct of the Company’s business, the offering or accepting of any gift, loan, payment, reward or advantage for personal gain as an encouragement to do something which is dishonest, illegal or a breach of trust.

Bribery is a criminal offence. The Company prohibits any form of bribery. We require compliance, from everyone connected with our business, with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us, and we have a zero-tolerance attitude towards corrupt activities of any kind, whether committed by McGreals employees or by third parties acting for or on behalf of McGreals.


The purpose of this policy is to convey to all employees and interested parties of McGreals the rules of the Company in relation to our unequivocal stance towards the eradication of bribery and our commitment to ensuring that McGreals conducts its business in a fair, professional, and legal manner.


It is a criminal offence to:

  • offer a bribe
  • accept a bribe
  • bribe a foreign official
  • as a commercial organisation, to fail to prevent a bribe

You should be aware that if you are found guilty by a court of committing bribery, you could face up to 10 years in prison and/or an unlimited fine. The Company could also face prosecution and be liable to pay a fine.


Corruption is the misuse of office or power for private gain. Bribery is a form of corruption which means in the course of business giving or receiving money, gifts, meals, entertainment or anything else of value as an inducement to a person to do something which is dishonest or illegal.


This policy applies to all employees of McGreals, regardless of seniority or site. It also extends to anyone working for or on our behalf e.g., those engaged by us on a self-employed basis or an agency arrangement. We will encourage the application of this policy where our business involves the use of third parties e.g., suppliers; contractors.


We realise that the giving and receiving of gifts and hospitality where nothing is expected in return helps form positive relationships with third parties where it is proportionate and properly recorded. This does not constitute bribery and consequently such actions are not considered a breach of this policy.

Gifts include money; goods (flowers, vouchers, food, drink, event tickets when not used in a hosted business context); services or loans given or received as a mark of friendship or appreciation.

Hospitality includes entertaining; meals or event tickets (when used in a hosted business context) given or received to initiate or develop relations. Hospitality will become a gift if the host is not present.

No gift should be given, nor hospitality offered by an employee or anyone working on our behalf to any party in connection with our business without receiving prior written approval from McGreals. Similarly, no gift nor offer of hospitality should be accepted by an employee or anyone working on our behalf without receiving prior written approval from McGreals.

A record will be made of every instance in which gifts or hospitality are given or received.

As the law is constantly changing, this policy is subject to review and the Company reserves the right to amend this policy without prior notice.


It is prohibited, directly or indirectly, to offer, give, request, or accept any bribe i.e., gift, loan, payment, reward, or advantage, either in cash or any other form of inducement, to or from any person or company in order to gain commercial, contractual or regulatory advantage for the Company, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.

It is also prohibited to act in the above manner in order to influence an individual in his capacity as a foreign public official. You should not make a payment to a third party on behalf of a foreign public official.

If you are offered a bribe, or a bribe is solicited from you, you should not agree to it unless your immediate safety is in jeopardy. You should immediately contact McGreals so that action can be taken if considered necessary. You may be asked to give a written account of events.

If you, as an employee or person working on our behalf, suspect that an act of bribery, or attempted bribery, has taken place, even if you are not personally involved, you are expected to report this to contact McGreals. You may be asked to give a written account of events.

Appropriate checks will be made before engaging with suppliers or other third parties of any kind to reduce the risk of our business partners breaching our anti-bribery rules.

The Company will ensure that all its transactions, including any sponsorship or donations given to charity, are made transparently and legitimately.

McGreals takes any actual or suspected breach of this policy extremely seriously and will carry out a thorough investigation should any instances arise.

We will uphold laws relating to bribery and will take disciplinary action against any employee, or other relevant action against persons working on our behalf or in connection with us, should we find that an act of bribery, or attempted bribery, has taken place. This action may result in your dismissal if you are an employee, or the cessation of our arrangement with you if you are self-employed, an agency worker, contractor etc.

Staff are reminded of the Company’s whistleblowing policy, which is available in the employee handbook, or upon request.


Modern Slavery Policy


 At McGreals, we are committed to uploading the highest ethical standards in all aspects of our operations. As part of our dedication to human rights and social responsibility, we have developed this Modern Slavery Policy. This policy outlines our commitment to combat modern slavery and human trafficking, both within our organization and within our supply chains.

 We acknowledge our responsibility to respect and promote human rights, and we strive to ensure that slavery and forced labour have no place in our business activities.


  1. Compliance with Laws: We are committed to complying with all applicable laws and regulations related to modern slavery, including the Modern Slavery Act, or any other relevant legislation enacted by the New Zealand government.
  2. Risk Assessment: We conduct regular risk assessments to identify and assess potential risks related to modern slavery in our operations and supply chains. This assessment includes evaluating the countries and industries in which we operate, as well as the activities of our suppliers and business partners.
  3. Supplier Due Diligence: We maintain a robust due diligence process to ensure that our suppliers and business partners share our commitment to combating modern slavery. This includes assessing their policies and practices related to human rights, labour standards, and modern slavery, and encouraging them to adopt similar policies.
  4. Supplier Engagement: We strive to work with our suppliers and business partners to improve labour conditions and prevent modern slavery. We encourage open dialogue and collaboration to address any identified risks, and we provide support and guidance to help them develop and implement effective measures to combat modern slavery.
  5. Training and Awareness: We are committed to raising awareness and providing training to our employees and stakeholders about modern slavery risks and indicators, as well as the steps they can take to prevent and report any suspected cases. We ensure that our employees understand their responsibility to report any concerns related to modern slavery.
  6. Reporting and Investigation: We have established mechanisms for reporting and investigating any allegations or suspicions of modern slavery. We encourage our employees, suppliers, and other stakeholders to report any concerns promptly, and we will conduct thorough investigations into any reported cases.
  7. Remediation and Accountability: In the event that modern slavery is identified in our operations or supply chains, we will take immediate action to remediate the situation. This may include terminating relationships with suppliers or business partners involved in modern slavery and providing support to affected individuals.
  8. Transparency and Communication: We are committed to being transparent about our efforts to combat modern slavery. We will regularly communicate our progress and initiatives through public disclosures, reports, and other appropriate channels.
  9. Continuous improvement: We recognize that combating modern slavery is an ongoing process. We will continuously review and improve our policies, practices, and procedures to enhance our effectiveness in addressing modern slavery risks.

    This Modern Slavery Policy demonstrates our commitment to preventing and eradicating modern slavery in all its forms. We strive to set and example for others in our industry and work towards a future where all individuals are treated with dignity, respect, and fairness. This policy will be regularly reviewed to ensure its effectiveness and compliance with evolving legal and ethical standards.


    McGreals Limited

    Level 1, 2/19 Auburn Street,

    Grafton, Auckland 1023

    09 307 5290