CODE OF CONDUCT

1. Purpose and Scope

This Code of Conduct sets out the ethical, legal, and professional standards expected of all directors, officers, employees, contractors, consultants, and representatives of the organisation.

It applies to all business activities, locations, and interactions, including dealings with clients, suppliers, regulators, partners, competitors, employees, and the community.

Compliance with this Code is mandatory.

2. Legal and Regulatory Compliance

The organisation is committed to full compliance with:

  • Applicable Australian Commonwealth, State, and Territory laws

  • Relevant international laws, treaties, and conventions

  • Industry-specific regulatory requirements

  • Contractual and licensing obligations

Where laws differ across jurisdictions, the stricter requirement applies.

Employees must not knowingly engage in any activity that breaches the law or assists others to do so.

3. Ethical Conduct and Integrity

All personnel must act honestly, ethically, and in good faith at all times.

This includes:

  • No fraud, bribery, corruption, or misrepresentation

  • No false, misleading, or deceptive conduct

  • Accurate record keeping and reporting

  • Fair dealing with customers, suppliers, and competitors

Unethical conduct will not be tolerated, even if it appears commercially advantageous.

4. Anti-Bribery and Corruption

The organisation strictly prohibits:

  • Bribes, kickbacks, facilitation payments, or improper benefits

  • Offering, giving, receiving, or soliciting anything of value to influence decisions

  • Corrupt practices in public or private sectors

This applies in line with:

  • Australian Criminal Code (Part 7.6)

  • OECD Anti-Bribery Convention

  • UN Convention Against Corruption

5. Conflicts of Interest

Personnel must avoid situations where personal, financial, or other interests conflict—or appear to conflict—with the interests of the organisation.

All actual or potential conflicts must be:

  • Declared promptly

  • Managed transparently

  • Recorded and addressed

Failure to disclose conflicts is a serious breach of this Code.

6. Human Rights and Fair Treatment

The organisation respects internationally recognised human rights, including principles set out in:

  • Universal Declaration of Human Rights

  • ILO Core Conventions

  • Australian Human Rights legislation

The organisation prohibits:

  • Forced labour, child labour, or human trafficking

  • Discrimination, harassment, bullying, or victimisation

  • Abuse of power, intimidation, or exploitation

Equal opportunity, dignity, and respect are mandatory in all workplaces.

7. Workplace Health and Safety

The organisation is committed to providing a safe and healthy work environment in accordance with:

  • Australian Work Health and Safety (WHS) legislation

  • Relevant Codes of Practice and Standards

All personnel must:

  • Follow safety procedures

  • Report hazards, incidents, and near misses

  • Take reasonable care for their own safety and others

Unsafe behaviour or disregard for safety obligations is unacceptable.

8. Environmental Responsibility

The organisation is committed to environmental protection and sustainable practices, including:

  • Compliance with environmental laws and permits

  • Pollution prevention and waste minimisation

  • Responsible resource and energy use

  • Protection of biodiversity and ecosystems

Environmental harm caused through negligence or misconduct will be addressed decisively.

9. Information Security and Privacy

The organisation protects confidential, personal, and sensitive information in accordance with:

  • Privacy Act 1988 (Cth)

  • Australian Privacy Principles (APPs)

  • Applicable data protection and cyber security laws

Personnel must:

  • Safeguard information assets

  • Use data only for authorised purposes

  • Prevent unauthorised access, disclosure, or misuse

Information security breaches must be reported immediately.

10. Use of Company Resources

Company resources, systems, and assets must be used:

  • For legitimate business purposes

  • Responsibly and lawfully

  • In a manner that protects value and reputation

Misuse, theft, or unauthorised use of company property is prohibited.

11. Fair Competition and Market Conduct

The organisation supports free and fair competition and complies with:

  • Competition and Consumer Act 2010 (Cth)

  • Anti-trust and fair trading laws

Prohibited conduct includes:

  • Price fixing or collusion

  • Market manipulation

  • Misleading or deceptive conduct

  • Abuse of market power

12. Reporting Misconduct and Whistleblower Protection

Personnel are encouraged and expected to report suspected misconduct, breaches of this Code, or illegal behaviour.

The organisation:

  • Provides confidential reporting channels

  • Protects whistleblowers from retaliation

  • Investigates all reports fairly and promptly

Retaliation against whistleblowers is strictly prohibited.

13. Accountability and Disciplinary Action

Breaches of this Code may result in:

  • Disciplinary action

  • Termination of employment or contract

  • Legal action or referral to authorities

Senior leadership is accountable for enforcing this Code and leading by example.

14. Review and Continuous Improvement

This Code of Conduct is reviewed periodically to ensure:

  • Ongoing legal compliance

  • Alignment with international best practice

  • Effectiveness in promoting ethical behaviour

15. Acknowledgement

All personnel must acknowledge that they have read, understood, and agree to comply with this Code of Conduct.