(a) The Code supports the organisation’s Core Values (being most closely aligned to “Integrity is not negotiable”) and provides a link to local policies.

(b) If an employee breaches this Code, the organisation will implement disciplinary action which, depending on the circumstances, may include formal verbal warning, removal from current role or dismissal.

(c) Below are some ‘do’s’ and ‘don’ts’ under the Code:

(i) We must be aware of conflicts.  There may be times when our personal interests conflict with those of the Organisation or our customers.  In these circumstances, we should take action to remove or manage the conflict so as to avoid detriment to the Organisation or our customers.

(ii) We must not make unauthorised gains or payments.  As a general rule, don’t accept or offer to give:

· gifts;

· services;

· discounts;

· gratuities; or

· other gains,

from (or to) people who conduct business with the company.  This principle has particular application where we are involved in a tender.

There are some exceptions – small gifts or invitations to local social or sporting functions are generally acceptable.  The offering and acceptance of bribes to/from anyone is prohibited outright.

(iii) We must only use company assets as authorised.

(iv) We must not disclose confidential information.  Unless we have permission, we must not use or give out confidential information.  This includes not giving confidential information about the Organisation or its customers or suppliers to other business units in the Organisation or external parties, or using the information provided for a different purpose without first obtaining permission.

(v)  We must ensure everyone has an equal opportunity.  Discrimination or harassment of any kind is totally inconsistent with our philosophy.

(vi) We must compete fairly.  All employees must be committed to fair competition in all markets in which the Company operates, by not intentionally misleading clients, business partners, competitors or community.

(vii) We must take into account any environment, health and safety impacts before making any business decision.

(viii) We must not make unauthorised public statements.

(ix) We must not make unauthorised political donations on behalf of Organisation

(x) We must be familiar with the policies and procedures that relate to our work.  In particular, we must be clear on our limits of authority and never:

· exceed those limits by committing the company verbally, in writing or by e-mail; or

· agree to restrict our business unit or any other business unit in Organisation from competing in a market or from expanding into any new regions without the consent of the company’s Chief Executive Officer.

(xi) We must help each other.  Every employee shall consciously promote the culture of helping each other and to work collaboratively.

(d) Employees may speak to their line managers or business unit’s chief executive officer, company secretary or legal counsel if they are unsure whether a course of action they are contemplating taking, constitutes to a breach in Code of Conduct.  

CONFLICT OF INTEREST

While it is not practicable to enumerate all conflict situations, the following should provide some indication of the relationships which should be avoided unless with the written consent of the MD.

The employee should not :-

(a) Engage in trade for private gain during office hours.

(b) Undertake work for payment or act in the capacity of a consultant for any employer other than the Company.

(c) Receive from the public, suppliers and customers any commissions, cash or gifts in kind for any preferential treatment given or received.

(d) Accept invitations to be entertained by customers, suppliers etc which are of such character as to place the employer under any real or apparent obligation to the members of the other party.

(f) Lend money at interest or borrow money from or in any manner place himself under pecuniary obligation to any person who is in any way subject to his official dealings with him.

(g) release to anyone not employed by the Company any data or information of a confidential nature concerning the Company on its decisions, plans, financial or business forecasts or competitive bids etc or use information to his personal advantage.

(h) employ a relative to work in his department or in a position that may lead to a conflict of interest.

We approach to Health, Safety and Environment is management driven and all personnel are fully trained to perform their tasks as required. Work methods are generated in consultation with employees and reviewed prior to activities commencing, with changes made as required.