Code of Conduct

Purpose

The purpose of this Corporate Code of Conduct is to provide a framework for decisions and actions in relation to ethical conduct in employment. It underpins the Company’s commitment to integrity and fair dealing in its business affairs and to a duty of care to all personnel (employees, interns, trainees, practitioners), clients and stakeholders. The document sets out the principles covering appropriate conduct in a variety of contexts and outlines the minimum standard of behaviour expected from employees.

Accountabilities

Senior Management

Senior management are responsible and accountable for:

  • undertaking their duties and behaving in a manner that is consistent with the provisions of the Code of Conduct;

  • the effective implementation, promotion and support of the Code of Conduct in their areas of responsibility; and

  • ensuring employees under their control understand and follow the provisions outlined in the Code of Conduct.

 

Employees

 

All employees are responsible for:

  • undertaking their duties in a manner that is consistent with the provisions of the Code of Conduct;

  • reporting suspected corrupt conduct; and

  • reporting any departure from the Code of Conduct by themselves or others.

 
Personal & Professional Behaviour

 

When carrying out your duties, you should:

  • behave honestly and with integrity and report other employees who are behaving dishonestly;

  • carry out your work with integrity and to a high standard and in particular, commit to the Company’s policy of producing quality goods and services;

  • operate within the law at all times;

  • act in the best interests of the Company;

  • follow the policies of the Company; and

  • act in an appropriate business-like manner when representing the Company in public forums.

 
Conflict of Interest

 

Potential for conflict of interest arises when it is likely that you could be influenced, or it could be perceived that you are influenced by a personal interest when carrying out your duties. Conflicts of interest that lead to biased decision making may constitute corrupt conduct.

  • Some situations that may give rise to a conflict of interest include situations where you have:

  • (i)  financial interests in a matter the Company deals with or you are aware that your friends or relatives have a financial interest in the matter;

  • (ii)  directorships/management of outside organisations;

  • (iii)  membership of boards of outside organisations;

  • (iv)  personal relationships with people the Company is dealing with which go beyond the level of a professional working relationship;

  • (v)  secondary employment, business, commercial, or other activities outside of the workplace which impacts on your duty and obligations to the Company;

  • (vi)  access to information that can be used for personal gain; and

  • (vii)  offer of an inducement.

  • You may often be the only person aware of the potential for conflict. It is your responsibility to avoid any conflict from arising that could compromise your ability to perform your duties impartially. You must report any potential or actual conflicts of interest to the CAO.

  •  If you are uncertain whether a conflict exists, you should discuss that matter with the CAO and attempt to resolve any conflicts that may exist.

  • You must not submit or accept any bribe, or other improper inducement. Any such inducements are to be reported to the CAO.

  • To be read in conjunction with the Company’s Anti-Corruption & Anti- Bribery Policy.

 
Public & Media Comment
  • Individuals have a right to give their opinions on political and social issues in their private capacity as members of the community.

  •  Employees must not make official comment on matters relating to the Company unless they are:

    • (i)  authorised to do so by the CEO; or

    • (ii)  giving evidence in court; or

    • (iii)  otherwise authorised or required by law.

  • Employees must not release unpublished or privileged information unless they have the authority to do so from the CEO.

  • The above restrictions apply except where prohibited by law, for example in relation to “whistleblowing”.

 
Use of Company Resources

 

Requests to use Company resources outside core business time should be referred to senior management for approval.

 

If employees are authorised to use Company resources outside core business times they must take responsibility for maintaining, replacing, and safeguarding the property and following any special directions or conditions that apply.

Employees using Company resources without obtaining prior approval could face disciplinary and/or criminal action. Company resources are not to be used for any private commercial purposes.

 
Security of Information

Employees are to make sure that confidential and sensitive information cannot be accessed by unauthorised persons. Sensitive material should be securely stored overnight or when unattended. Employees must ensure that confidential information is only disclosed or discussed with people who are authorised to have access to it. It is considered a serious act of misconduct to deliberately release confidential documents or information to unauthorised persons, and may incur disciplinary action.

Intellectual Property/Copyright

Intellectual property includes the rights relating to scientific discoveries, industrial designs, trademarks, service marks, commercial names and designations, and inventions and is valuable to the Company.

The Company is the owner of intellectual property created by employees in the course of their employment unless a specific prior agreement has been made. Employees must obtain written permission to use any such intellectual property from the CEO and Finance Director before making any use of that property for purposes other than as required in their role as employee.

Discrimination & Harassment

Employees must not harass, discriminate, or support others who harass and discriminate against colleagues or members of the public on the grounds of sex, pregnancy, marital status, age, race (including their colour, nationality, descent, ethnic or religious background), physical or intellectual impairment, homosexuality or transgender.

Such harassment or discrimination may constitute an offence under legislation. Senior management should understand and apply the principles of Equal Employment Opportunity.

Corrupt Conduct

Corrupt conduct involves the dishonest or partial use of power or position which results in one person/group being advantaged over another. Corruption can take many forms including, but not limited to:

  • official misconduct;

  • bribery and blackmail;

  • unauthorised use of confidential information;

  • fraud; and

  • theft.

Corrupt conduct will not be tolerated by the Company. Disciplinary action up to and including dismissal will be taken in the event of any employee participating in corrupt conduct.

To be read in conjunction with the Company’s Anti-Corruption & Anti-Bribery Policy.

Occupational Health & Safety

It is the responsibility of all employees to act in accordance with occupational health and safety legislation, regulations and policies applicable to their respective organisations and to use security and safety equipment provided.

Specifically all employees are responsible for safety in their work area by:

  • following the safety and security directives of senior management;

  • advising senior management of areas where there is a potential problem in safety and reporting suspicious occurrences; and

  • minimising risks in the workplace.

Legislation

It is essential that all employees comply with the laws and regulations of the countries in which we operate. Violations of such laws may have serious consequences for the Company and any individuals concerned. Any known violation must be reported immediately to senior management.

Fair Dealing

The Company aims to succeed through fair and honest competition and not through unethical or illegal business practices. Each employee should endeavour to deal fairly with the Company’s suppliers, customers and other employees.

Insider Trading

All employees must observe the Company’s “Trading Policy”. In conjunction with the legal prohibition on dealing in client’s securities when in possession of unpublished price sensitive information. 

Breaches of the Code of Conduct

Employees should note that breaches of certain sections of this Code of Conduct may be punishable under legislation.

Breaches of this Code of Conduct may lead to disciplinary action. The process for disciplinary action is outlined in the Company policies and guidelines, relevant industrial awards and agreements.

Reporting Matters of Concern

Employees are encouraged to raise any matters of concern in good faith with the CEO, Finance Director or CAO, without fear of retribution.