The obligations set out in this Code of Conduct apply to all persons engaged in any capacity by GFG Alliance Australia.

Transcription

1 Cde f Cnduct 1.0 INTRODUCTION GFG Alliance Australia is cmmitted t its cmpanies, leaders, emplyees, cntractrs and suppliers adhering t high standards f business cnduct and cmplying with the law and best practice. This dcument sets ut the Cmpany s expectatins with respect t business behaviur. It als establishes prcedures fr the reprting and management f breaches as they ccur. The bligatins set ut in this Cde f Cnduct apply t all persns engaged in any capacity by GFG Alliance Australia. 2.0 ACCOUNTABILITIES 2.1 Respnsibilities f All Emplyees All emplyees are expected t be familiar with the cntents f the Cde. Emplyees must als have an understanding f the business practices and plicies that directly relate t their rle and wrk lcatin. It is every emplyee's respnsibility t cmply with the Cde. Emplyees shuld seek assistance frm a manager r supervisr if they d nt fully understand hw it shuld be applied. 2.2 Respnsibilities f Managers & Supervisrs Managers and supervisrs must take all reasnable steps t ensure that GFG Alliance's emplyees (and where apprpriate, cnsultants, cntractrs, business partners and visitrs) are aware f and cmply with the Cde. Managers and supervisrs must als: ensure that all emplyees have access t relevant Cmpany plicies and prcedures; respnd prmptly and seriusly t emplyees' cncerns and questins abut business cnduct issues and seek further assistance if required; cnsult with the next level f management if prblems ccur; and demnstrate exemplary behaviur that ther emplyees can fllw. 2.3 Respnsibilities f Senir Management Senir Managers have peratinal respnsibility fr ensuring cmpliance with the Cde, and are respnsible fr ensuring that their Divisin/Business/Functin: fsters a wrkplace envirnment that prmtes and encurages hnest and pen cmmunicatin abut business cnduct issues, emphasises the imprtance f perating in accrdance with the Cde and avids placing pressure n emplyees t deviate frm the standards cntained in the Cde; establishes internal reprting and apprval prcesses that address high risk areas in relatin t business cnduct; Cde f Cnduct Versin Nvember 2017 Page 1 f 14

2 prepares supplementary guidance and supprt fr emplyees abut hw t cnduct business in particular markets cnsistent with the Cde; undertakes training cnsistent with the Cde and tailred t the peratinal needs f the business; fllws relevant prcedures fr reviewing the credentials f thers such as cnsultants, cntractrs and partners befre entering agreements with them; and incrprates the key elements utlined in this Cde in perfrmance management prcesses, emplyment cntracts, inductin prcedures, industrial agreements and similar systems. 3.0 BREACHES OF THE CODE Any individual wh breaches the Cde r any f the guidelines r plicies under it, r wh authrises, is aware f r permits any breaches will, subject t a review f the circumstances, be subject t disciplinary actin, up t and including pssible dismissal. The highest standards f crprate cnduct are critical t GFG Alliance s reputatin and success and therefre emplyees are encuraged t reprt any actual r suspected breach f the Cde. If yu becme aware f cnduct which causes yu cncern r a decisin r actin which appears t be incnsistent with the intent f this Cde, yu shuld immediately reprt it t yur manager r supervisr, wh has a respnsibility t reprt the matter t Senir Management. If yu feel unable t d this, there are a number f ther avenues fr raising a questin r cncern. Yu can raise a questin r cncern by cntacting any f the fllwing: any member f Senir Management the Cmpany s Human Resurces, Legal r Internal Audit, Cntrl and Risk functins the relevant General Manager GFG Alliance s independent and annymus tll-free htline, as listed in the Whistleblwer Plicy which is lcated n the intranet. The abve are respnsible fr prmptly respnding t emplyees' questins and cncerns regarding business r Cmpany cnduct. They must ensure that the infrmatin they prvide is accurate and that their advice is cnsistent with the Cde. All cncerns and questins will be treated seriusly. The curse f actin taken t answer a questin r respnd t a cncern will depend n the nature f the issue and its severity. It may be pssible t reslve a matter by invlving nly ne persn. Hwever, sme situatins, such as thse invlving significant legal r financial matters may require advice and input frm additinal surces such as legal advisers r auditrs. In all cases, cnfidentiality will be maintained t the highest degree practicable. Any emplyee wh reprts a breach r suspected breach f legal r ethical standards in gd faith will nt be subject t retaliatin, retributin r ther recriminatins fr making that reprt. At times, cmpliance with the Cde will affect GFG Alliance's chances f winning r retaining business. Situatins that invlve a cnflict between uphlding the Cde and prtecting GFG Alliance s shrt-term cmmercial interests shuld be penly and hnestly discussed. These situatins must be reslved in a manner that des nt cmprmise GFG Alliance's reputatin r standards. Cde f Cnduct Versin Nvember 2017 Page 2 f 14

3 4.0 LEGAL & ETHICAL ISSUES 4.1 Cmpliance with the Law Sme laws affect everyne, such as thse cncerning equal emplyment pprtunity, ccupatinal health, safety and bribery, fraud r crruptin. Other laws primarily affect emplyees in particular rles, such as thse cncerning prduct liability, credit management, tax, trade practices and fair cmpetitin. It is every emplyee s respnsibility t ensure that they fully understand all laws and regulatins relevant t their rle. The laws that gvern GFG Alliance s business activities may be cmplex, but ignrance f the law des nt excuse GFG Alliance r its emplyees frm their bligatin t cmply. Emplyees shuld seek advice frm the Legal department if they are unclear abut laws r regulatins relating t their wrk. Matters relating specifically t taxatin shuld be referred t the Tax department fr guidance. 4.2 Using and Accunting fr Cmpany Resurces Emplyees must nt use Cmpany funds, prperty, equipment, r ther resurces fr persnal benefit. In additin, emplyees are respnsible fr safeguarding the Cmpany resurces under their cntrl, including infrmatin, and fr maintaining accurate Recrds regarding the use f these resurces. In particular: emplyees shuld use Cmpany funds sensibly and effectively. Expenditures must be reprted accurately and in a timely manner. Submissin f a fraudulent r misleading expense reprt is regarded as serius miscnduct; an accurate and auditable recrd f all financial transactins relating t the Cmpany must be maintained in accrdance with relevant accunting standards. N entry shuld be made in the Cmpany's financial recrds that distrts r disguises the true nature f any transactin. Nnfinancial recrds such as persnnel files, envirnmental dcumentatin, statutry recrds and safety statistics ( Recrds ) must als be accurately and rigrusly maintained; unauthrised remval f Cmpany equipment, supplies r ther resurces is regarded as theft; Cmpany resurces must nt be sld, laned r dnated withut management apprval; emplyees shuld take apprpriate precautins t prevent theft, damage r misuse f Cmpany resurces. Fr example, unattended buildings, strage areas and Cmpany vehicles shuld be lcked when they are nt in use. Emplyees must nt duplicate keys t Cmpany prperty withut authrisatin frm management; emplyees shuld nt destry r dispse f Cmpany resurces withut management apprval. Emplyees are prhibited frm intentinally damaging Cmpany resurces; and dispsal f Cmpany Recrds, and ther dcumentatin shuld be in accrdance with the law and applicable Cmpany standards and guidelines. 4.3 Cnfidentiality and Prprietary Infrmatin Infrmatin is a valuable crprate asset, and the pen and effective disseminatin f infrmatin is critical t ur success. Hwever, much infrmatin abut GFG Alliance s business activities is cnfidential r prprietary. Cnfidential infrmatin is infrmatin that GFG Alliance cnsiders private and that is nt cmmn knwledge utside the Cmpany. Prprietary infrmatin is infrmatin GFG Alliance wns, develps, pays t have develped, r t which it has an exclusive right. Bth cnfidential and prprietary infrmatin can be written as well as unwritten. Cde f Cnduct Versin Nvember 2017 Page 3 f 14

4 Cnfidential and prprietary infrmatin may include but are nt limited t: cst and pricing, including unpublished infrmatin abut past, current and future prices; methds by which GFG Alliance determines its bids; dcuments, recrds, r ther infrmatin cncerning GFG Alliance s business strategies, sales r marketing plans r activities, business results, unannunced prducts r services, and financial results and data; custmer and emplyee recrds; data entrusted t an emplyee by a custmer, supplier, r cnsultant; sftware r cmputer systems develped by GFG Alliance; GFG Alliance s trademarks and plans fr new trademarks, which include symbls, wrds and phrases used t identify and distinguish GFG Alliance s prducts and services; the prducts f GFG Alliance s research and develpment, such as inventins, patents and engineering infrmatin; GFG Alliance s prcesses, prcedures and knw-hw; rganisatinal infrmatin; peratinal infrmatin; and any ther infrmatin that culd be f use t a cmpetitr t place GFG Alliance at a cmpetitive disadvantage. Because the disclsure f such infrmatin culd seriusly damage GFG Alliance s interests, safeguarding this infrmatin is the respnsibility f all GFG Alliance emplyees. If yu learn abut Cmpany prprietary r cnfidential infrmatin during the curse f yur emplyment, yu shuld be careful nt t share it with thers including fellw emplyees unless they need t knw fr a legitimate business reasn. Yu shuld als guard against unintentinally disclsing prprietary r cnfidential infrmatin. Situatins that culd result in inadvertent disclsure f such infrmatin that yu shuld be sensitive t may include but are nt limited t: discussing cnfidential r prprietary infrmatin in public places such as restaurants, public transprt, elevatrs r aerplanes; psting cntent/cmments t scial netwrking sites, blgs, frums r in private s r text messages; talking abut it in public, n a mbile phne r mbile device; wrking with sensitive material n mbile devices in public; and transmitting such infrmatin by unsecured means. Yur bligatin t prtect GFG Alliance s cnfidential and prprietary infrmatin cntinues even after yu leave the Cmpany. Just as GFG Alliance values and prtects its wn cnfidential and prprietary infrmatin, it is ur plicy and practice t respect the cnfidential and prprietary infrmatin f third parties with whm GFG Alliance has agreed t treat such infrmatin in cnfidence. GFG Alliance als values and prtects the persnal infrmatin f emplyees. Cde f Cnduct Versin Nvember 2017 Page 4 f 14

5 4.4 Fraud, Bribery and Crruptin GFG Alliance des nt tlerate fraud and crruptin. All actual r suspected fraud shuld be referred t Internal Audit, Cntrl and Risk Management, fr investigatin. Where genuine fraud r ther criminal activity is genuinely suspected, GFG Alliance will alert and wrk with plice and seek t press charges. Perpetratrs will be subject t suspensin, dismissal and civil actin t recver any financial lss caused t GFG Alliance. GFG Alliance s Fraud Plicy and Glbal Cmpliance Manual are lcated n the intranet. Dishnest activity invlving deceptin which results in actual r ptential financial lss amunts t fraud. Dishnest activity invlving a misuse f a psitin within GFG Alliance t achieve persnal gain fr yu r anther persn r entity amunts t crruptin. Invlvement in fraud, bribery and crruptin is a criminal ffence and threatens the reputatin f GFG Alliance and represents a fundamental risk t ur brand and business. If the nly way t win business requires paying a bribe r therwise breaching the Cde, GFG Alliance des nt want the business. GFG Alliance emplyees and cntractrs must nt ffer, prmise, authrise r prvide anything f value t any public fficial in rder t influence the fficial fr the purpse f btaining r retaining any cntract, licence, permit r ther business advantage fr GFG Alliance. Likewise, emplyees r cntractrs must nt ffer any benefit t a third persn (such as a relative r business partner f the fficial) with the intentin t influence the fficial. Public fficials may include but are nt limited t: emplyees r cntractrs f cmpanies whlly r majrity wned by freign Gvernments r the Australian Gvernment; a persn in the service f a Gvernmental bdy including a member f the military r the plice frce; a plitician, judge r member f the legislature f a cuntry; an emplyee, cntractr r persn therwise in the service f a public internatinal rganisatin; r an individual wh is r wh hlds himself r herself ut t be an authrised intermediary f a public fficial. GFG Alliance emplyees and cntractrs must nt ffer, prmise, authrise r pay anything f value t any persn wh wrks fr r represents any f ur current r ptential custmers r suppliers t influence that persn t perfrm their functin imprperly r reward them fr ding s. Emplyees and cntractrs als must nt ffer r prvide a benefit r "secret cmmissin" t an agent r representative f anther persn r cmpany in rder t btain a business advantage fr GFG Alliance where the agent r representative intends t cnceal their receipt f that benefit. GFG Alliance r its emplyees culd als cmmit ther criminal ffences if they are invlved in receiving r cncealing the receipt f prfits wn by paying bribes r ther things f value, r in cncealing the nature r recipient f a bribe r ther benefit in Cmpany financials and Recrds. GFG Alliance can be liable under anti-crruptin laws fr the actins f agents, distributrs, cnsultants and ther cntractrs, particularly where they are affiliated t r therwise prvide a benefit t a freign public fficial r where they therwise breach anti-bribery laws. Particular care must be taken with cntractrs wh assist in securing business, r wh arrange intrductins t key Gvernment decisin-makers in a freign cuntry. In accrdance with the GFG Alliance Offshre Agent Appintment Prcedure, emplyees must cnduct apprpriate backgrund and reputatin checks in accrdance with the ff-shre agent appintment prcedure befre selecting r cmmencing negtiatins with any agent, distributr, cnsultant r ther cntractr utside f Australia and New Zealand. Cde f Cnduct Versin Nvember 2017 Page 5 f 14

6 Any breach r suspected breach f this sectin f the Cde r any cncerns regarding a prpsed agent r cntractr shuld be immediately reprted t yur manager r supervisr and t the Chief Legal Officer. 4.5 Fair Call Htline GFG Alliance expects emplyees wh becme aware f imprper cnduct t raise thse cncerns. The Cmpany s Fraud Plicy and Whistleblwer Plicy cntain the cntact details f GFG Alliance s independent and annymus tll-free htlines. Bth plicies are lcated n the intranet. 4.6 Cnflicts f Interest The accepted standard in business and under this Cde, is that all business decisins are at arm s length and impartial. A cnflict f interest is a situatin where an individual stands t benefit, directly r indirectly, as a result f a decisin they make n behalf f the Cmpany. That is, where it can be argued that their capacity t make a prper and impartial decisin is cmprmised. Fr managers and emplyees at all levels, the ptential fr cnflict f interest is a business reality. Fr example: whether t emply a friend r family member even thugh yu believe they are the best candidate; whether t purchase a prduct r service where, it can be argued, there is sme persnal benefit; r whether t enter int a business arrangement with a persn r entity with which yu are nt fully at arm s length. Whilst avidance is always preferable, ften the issue is less abut whether a cnflict f interest exists, but hw individuals deal with such situatins. GFG Alliance s expectatin is that emplyees recgnise and immediately disclse t their manager r supervisr any situatin r decisin that invlves, r culd be perceived by thers t invlve, a cnflict f interest. This will prtect the emplyee as well as the Cmpany. If in dubt, cntact Senir Management r the Legal department. In the case f GFG Alliance s Directrs and Senir Management, it shuld be nted that specific disclsure r apprval requirements might arise with regard t cnflict f interest situatins under the Crpratins Act (and equivalent legislatin utside f Australia), the Cmpany s Cnstitutin, ther plicy r gvernance dcuments and related party disclsures in GFG Alliance s financials and Recrds. 4.7 Cpyrighted Materials and Trademarks Many materials used in the curse f wrk are prtected by cpyright laws such as cmputer sftware, audi and vide tapes, trade jurnals, bks and magazines. Presentatin slides, training materials, management mdels, r ther materials prepared by utside cnsultants r rganisatins may als be cpyrighted. Yu shuld nt reprduce, distribute, r alter cpyrighted materials wned by thers withut valid permissin f the cpyright wner r its authrised agent. As it is nt always easy t determine if such permissin exists, yu must btain such permissin befre using these materials. GFG Alliance s trademarks, service marks, lgs and marketing slgans are als valuable assets, which must be prtected. Emplyees shuld ensure these prprietary marks are used prperly and nly fr legitimate business purpses f GFG Alliance. 4.8 Trade Practices Plicy GFG Alliance is cmmitted t a pr-cmpetitive culture and cmpliance with the cmpetitin, anti-trust and trade practices laws f all cuntries in which it perates r cnducts business. Cmpliance with these laws als prmtes ethical standards and a cmmitment t free and fair cmpetitin. Specifically: Cde f Cnduct Versin Nvember 2017 Page 6 f 14

7 cnduct that is prhibited by cmpetitin, anti-trust r trade practices laws must be avided. Where the impact f the law is uncertain, emplyees must seek apprpriate legal advice frm the Legal department and act n an infrmed judgment; n emplyee has authrity t cntravene this plicy r t authrise r cndne cntraventin by thers. Cntraventin cannt be justified by claims f ignrance, gd intentins r failure t seek legal advice and will be regarded as a serius breach f yur respnsibilities and duties as an emplyee; GFG Alliance will cntinue t cnduct emplyee educatin and cmpliance prgrams n a regular basis t help ensure the success f this plicy; any emplyee becming aware f a breach r ptential breach f cmpetitin, anti-trust r trade practices laws shuld reprt their cncerns t the Legal department; and GFG Alliance intends t prmte a c-perative relatinship with the Australian Cmpetitin and Cnsumer Cmmissin and ther relevant regulatry agencies in cuntries where it perates. 4.9 Privacy GFG Alliance is cmmitted t prtecting the privacy f individual s persnal infrmatin by cmplying with the Australian Privacy Principles set ut in the Privacy Act 1988 and any successr Australian privacy principles that apply t the Cmpany as a result f amendments t that Act. Any custmer infrmatin must be managed in a prfessinal and ethical manner with regard t use and distributin f internal Recrds. If custmer recrds cntain infrmatin f a persnal nature, that infrmatin is nt t be used fr any ther purpse r disclsed utside the rganisatin withut the permissin f the custmer r the individual cncerned unless required t be prvided by law. The fllwing guidelines shuld be adhered t: nly cllect persnal infrmatin if it is necessary fr yur business activities and nly by lawful and fair means; use persnal infrmatin nly fr business purpses relevant t GFG Alliance s relatinship with the individual; nly disclse persnal infrmatin as advised in GFG Alliance s Privacy Cmpliance Guidelines; prtect persnal infrmatin received; de-identify persnal infrmatin where necessary r apprpriate; allw individuals t access and crrect their persnal infrmatin where apprpriate; be aware f the GFG Alliance s Privacy Plicy and Privacy Cmpliance Guidelines; and d nt cllect sensitive infrmatin withut apprpriate cnsent. Persnal infrmatin is infrmatin r an pinin abut an individual whse identity is apparent r can reasnably be ascertained frm the infrmatin r pinin. Generally, an individual s name will have t be n the relevant recrd befre it might be categrised as persnal. Hwever, in sme circumstances ther details may be sufficient t ascertain an individual s identity. Cde f Cnduct Versin Nvember 2017 Page 7 f 14

8 4.10 Gifts and Entertainment Emplyees must exercise care with respect t giving r receiving business related gifts. This applies t direct payments and t payments in kind, including the prvisin f gds r services, persnal favurs and entertainment such as meals, travel and tickets t events. Accepting r ffering gifts f mderate value [defined as less than A$150 r equivalent value verseas] is acceptable in situatins where it is legal and in accrdance with nrmal business practice such as where the exchange f gifts is custmary, and the gifts are apprpriate fr the ccasin. Hwever, emplyees must nt give r accept gifts f any kind in circumstances that culd be reasnably regarded as unduly r imprperly influencing the recipient r creating a business bligatin n the part f the recipient. In particular, gifts shuld nt be given in circumstances that culd in any way be seen as an attempt t gain influence in respect f any particular matter t the advantage f GFG Alliance r t speed up an apprval, cnsent r ther administrative prcess. If there is any dubt, the situatin shuld be referred t yur manager r supervisr. The glden rule is disclsure. Ensuring yur manager r supervisr is aware f all gifts that may be cnsidered inapprpriate r significant it ensures transparency and seeks t avid any suggestin f a cnflict f interest. Gifts and entertainment must be recrded in yur Divisin r Functin register (if applicable). Yur manager r supervisr must apprve stentatius r expensive gifts. Similarly, if an emplyee receives a gift, they shuld cnsult their manager r supervisr fr a decisin n whether it shuld be kept, handed t the Cmpany r returned. Small and mdest gifts shuld be reprted t yur manager r supervisr. The mnetary value f the gift and legal requirements shuld be cnsidered when determining whether a gift shuld be retained by an emplyee, handed t the Cmpany r returned. If it is determined that a gift shuld be handed t the Cmpany, the gift shuld be dnated t a nminated charity r made available t all emplyees in the business unit r Divisin. The curse f actin will depend n the type f gift received. The fllwing items must nt be given r accepted under any circumstances, regardless f their value: cash r persnal cheques; drugs r ther cntrlled substances; prduct r service discunts that are nt available t all emplyees; persnal use f accmmdatin r transprtatin; and payments r lans t be used tward the purchase f persnal prperty. Under n circumstances shuld an emplyee request a gift f any kind frm a supplier, custmer, r ther party with whm GFG Alliance cnducts r is likely t cnduct business. In additin, emplyees must nt exchange gifts with representatives f GFG Alliance's cmpetitrs, since the prvisin r receipt f such gifts may create an actual r perceived cnflict f interest. This plicy als applies t emplyees' immediate family members and t any agents r third parties that are emplyed t represent the Cmpany Outside Appintments Emplyees must seek apprval frm their manager r supervisr befre accepting a directrship in anther business crpratin, statutry authrity r similar bdy. Each case will be cnsidered n its merits. Apprval is required fr psitins in Gvernment advisry bdies; plitical parties; prfessinal institutins; trade assciatins; charitable, public, scial, r sprting rganisatins; and similar grups if the psitin: has senir r high status; will invlve a significant amunt f the emplyee's time t the extent that it culd affect their ability t fulfil their respnsibilities t the Cmpany; is likely t invlve public cntrversy; r Cde f Cnduct Versin Nvember 2017 Page 8 f 14

9 will invlve activities r features that are r culd be incmpatible with GFG Alliance's plicies r standards. Emplyees shuld btain apprval befre accepting any significant payment fr their invlvement with an advisry bard r similar grup, including reimbursement fr travel and related expenses. Whenever an emplyee participates in an utside activity, it is their respnsibility t ensure that any pinins they express are clearly their persnal views and cannt be interpreted as the views f the Cmpany. Full-time emplyees shuld nt take additinal emplyment with utside rganisatins r perate their wn business and they must seek apprval befre ding s. Any emplyee whse situatin may require apprval shuld advise their manager r supervisr. Where necessary, requests fr apprval shuld be referred t the relevant Divisin Executive General Manager and the Cmpany Chief Legal Officer advised appintment alng with the apprval prvided. 5.0 HEALTH, SAFETY AND ENVIRONMENT 5.1 Occupatinal Health, Safety and Welfare GFG Alliance is cmmitted t achieving the highest perfrmance in ccupatinal health, safety and welfare with the aim f creating and maintaining a safe and healthy wrking envirnment thrughut its businesses. Cnsistent with this, the Cmpany will: seek cntinuus imprvement in its ccupatinal health and safety perfrmance taking int accunt evlving cmmunity expectatins, management practices, scientific knwledge and technlgy; cmply with all applicable laws, regulatins and standards and where adequate laws d nt exist, adpt and apply standards that reflect the Cmpany's cmmitment t ccupatinal health and safety; invlve emplyees and cntractrs in the imprvement f ccupatinal health and safety perfrmance; train and hld individual emplyees accuntable fr their area f respnsibility; avid, manage and mitigate risk by implementing management systems t identify, assess, mnitr and cntrl hazards and by reviewing perfrmance; ensure that GFG Alliance emplyees, cntractrs and visitrs are infrmed f and understand their bligatins; cmmunicate penly with emplyees, gvernment and the cmmunity n ccupatinal health and safety issues; cntribute t the develpment f relevant ccupatinal health and safety plicy, legislatin and regulatins; and supprt relevant ccupatinal health and safety research. 5.2 Alchl, Drugs and Tbacc GFG Alliance recgnises that circumstances vary amng different cultures and cuntries regarding the use f alchl, drugs, and tbacc. Hwever, despite these differences, every emplyee is respnsible fr taking apprpriate steps t prevent wrkplace injuries and illnesses and fr cntributing t a safe and healthy wrk Cde f Cnduct Versin Nvember 2017 Page 9 f 14

10 envirnment. This bligatin includes respnsible behaviur with respect t the use f alchl, drugs, and tbacc at wrk, when cnducting Cmpany business and at Cmpany spnsred activities. Emplyees must nt be impaired by illegal r legal drugs, including alchl, while at wrk r when cnducting Cmpany business. Under the Cmpany s varius fit fr wrk prgrams, cmpliance with these requirements may be assessed at any time. Pr wrk perfrmance repeatedly caused by alchl r drug use, r significant impairment that creates a safety risk, are regarded as serius miscnduct. In additin, GFG Alliance prhibits the pssessin, transfer r use f illegal substances n Cmpany premises r sites, in cnjunctin with Cmpany business, at Cmpany functins r Cmpany spnsred activities. T prevent passive cigarette smke expsure, all Cmpany buildings and sites must have designated smking and nn-smking areas. Smking is prhibited in all shared wrk areas and in ther cmmunal areas such as cnference rms, dining facilities, receptin areas, and first aid rms. Smking is prhibited in buildings r ffices that use a recycling air cnditining system, Cmpany vehicles carrying nn-smking passengers and places in which smking creates a significant fire risk. If smking areas are prvided, they shuld be sealed ff frm adjacent wrk areas, clearly marked, adequately ventilated and reasnably cnvenient. Smke shuld be prevented frm entering a recycled air cnditining system and nn-smkers shuld nt be expsed t passive cigarette smke in any way. 5.3 Envirnment It is GFG Alliance's apprach t achieve a high standard f envirnmental care by cmplying with relevant legislatin and seeking cntinuus imprvement in perfrmance by taking accunt f evlving scientific knwledge and cmmunity expectatins. Specifically, GFG Alliance's apprach is t: cmply with all applicable laws, regulatins and standards; uphld the spirit f the law and where laws d nt adequately prtect the envirnment, apply standards that minimise any adverse envirnmental impacts resulting frm its peratins, prducts and services; cmmunicate with Gvernment and the cmmunity n envirnmental issues, and cntribute t the develpment f plicies, legislatin and regulatins that may affect GFG Alliance; ensure that its emplyees and suppliers f gds and services are infrmed f GFG Alliance s apprach and are aware f their envirnmental respnsibilities in relatin t GFG Alliance s business; and ensure that management systems identify, cntrl, mitigate and mnitr envirnmental risks arising frm peratins. 6.0 HUMAN RESOURCES GFG Alliance is cmmitted t maintaining an efficient, skilled, diversified, flexible and cmmitted wrkfrce thrugh a range f emplyment practices and arrangements. While mst emplyees will be engaged n a full-time permanent basis, a range f alternatives are available, t meet specific business requirements. Cde f Cnduct Versin Nvember 2017 Page 10 f 14

11 6.1 Recruitment and Selectin GFG Alliance recgnises that peple are a distinguishing feature f a successful business and is cmmitted t maintaining and building an apprpriately skilled, mtivated and diverse wrkfrce. GFG Alliance will select the mst apprpriate persn fr the psitin and will nt cmprmise its selectin criteria r prcesses. GFG Alliance s selectin prcesses will: be thrugh, cnsistent and efficient; be (and appear t be) fair, valid, impartial and nn-discriminatry; assess merit against specific and multi-dimensinal criteria (relevant and demnstrable knwledge, skills, qualificatins, experience and perating style); ensure applicants are prvided with sufficient infrmatin t understand the business, the requirements f the psitin, and the selectin criteria t be applied; and respect privacy and cnfidentiality. 6.2 Managing Diversity, Harassment and Bullying in the Wrkplace GFG Alliance is cmmitted t maintaining a diverse wrkplace free f unlawful discriminatin, harassment and bullying. GFG Alliance is cmmitted t ensuring that: all emplyment decisins are fair, reasnable, and based n merit; n individual r grup is treated less favurably than anther fr reasns nt immediately relevant t the circumstances; emplyees, visitrs and thers in the wrkplace are treated with respect in an envirnment free f unlawful discriminatin, harassment, bullying and ffensive behaviur; the display, strage r transmissin f material likely t cause ffence will nt be permitted n Cmpany premises r equipment; emplyees at every level understand their rights and respnsibilities with respect t discriminatin, harassment and bullying; cmplaints f unlawful discriminatin, harassment and/r bullying are taken seriusly and are apprpriately and prmptly investigated; legislative standards are met with respect t EEO and the management f diversity, harassment and bullying in the wrkplace; and individuals are nt prevented frm wrking safely and effectively n the basis f their level f English literacy. GFG Alliance is cmmitted t training and educating emplyees, managers and supervisrs t be able t recgnise and deal with instances f discriminatin, harassment and bullying in the wrkplace, as well as t prmte harmny and equality in the wrkplace. It is the respnsibility f managers and supervisrs t ensure that all wrkplace decisins and activities are free f unlawful discriminatin, harassment and bullying and t apprpriately investigate all cmplaints r suspected instances f unlawful discriminatin, harassment r bullying. The Cmpany cnsiders any breach t be miscnduct. If, after investigatin, allegatins f harassment are substantiated, GFG Alliance will implement apprpriate disciplinary actin against thse respnsible, up t and including dismissal. Cde f Cnduct Versin Nvember 2017 Page 11 f 14

12 Fr mre infrmatin, refer t the Managing Diversity, Harassment & Bullying in the Wrkplace Plicy. 7.0 COMPANY INFORMATION & EXTERNAL RELATIONSHIPS 7.1 Infrmatin Systems and Technlgy GFG Alliance emplyees use a wide range f infrmatin systems and technlgy t cnduct business including smart and mbile phnes, vic , facsimile, the Internet, electrnic mail and ther devices. Access t, and use f, these systems is subject t the Cmpany s Acceptable Use f Infrmatin Systems and related plicies, as amended frm time t time. The principles underpinning these plicies include: GFG Alliance prvides services and access t the Internet fr legitimate business purpses. In sme cases third parties (ther cmpanies) may als prvide GFG Alliance emplyees with access t their systems and equipment fr specific business purpses. The use f these and ther systems fr nn-gfg Alliance business represents a threat t system efficiency and security; all Cmpany infrmatin is the prperty f GFG Alliance and as such must be treated as any ther asset f the Cmpany. Every emplyee has a respnsibility t prtect the infrmatin cmmunicated r stred n all electrnic devices frm accidental and unauthrised access, disclsure, mdificatin r deletin. except in the curse f an emplyee s duties r with the express permissin f their manager r supervisr, emplyees must nt use cmpany cmputer, , intranet and internet systems and netwrks r ther devices: using anther persn s user name and passwrd; fr persnal cmmercial purpses; fr regular (daily) share trading and mnitring; t send unslicited bulk , t transmit chain letters r fr mass mailing (spamming); t run instant messaging sftware; t harass, abuse, r defame any persn; t receive and/r transmit prngraphy, prfanity r ther ffensive material; fr gambling purpses; t play n-line r netwrk games; t btain, pssess r transmit illegal r pirated material; t btain, pssess r transmit cnfidential r prprietary infrmatin withut authrisatin; fr disseminating persnal cntact infrmatin f fficers r emplyees f GFG Alliance withut their cnsent; fr any ther illegal purpse; in a way that knwingly causes interference with r disruptin t any netwrk, infrmatin service, equipment r any user theref; t knwingly dwnlad sftware r media files r data streams that will create a security risk r use a greater amunt f netwrk bandwidth than is apprpriate; r d anything else which will r may bring GFG Alliance int disrepute; cause GFG Alliance r any f its custmers, suppliers r ther assciates t bear unreasnable risks r csts; cause Cde f Cnduct Versin Nvember 2017 Page 12 f 14

13 disruptin t any f GFG Alliance s business r services r be in breach f any privacy bligatins. GFG Alliance reserves the right t mnitr use f its infrmatin systems and technlgy. This includes mnitring the nature and cntent and restricting the transfer f certain material t r frm emplyees. 7.2 Disclsure f Cmpany Infrmatin The relevant GFG Alliance Lead Team member must apprve all internally prduced materials such as brchures, press releases and reprts fr Gvernment departments befre distributin utside the Cmpany. If any dubt exists abut the apprpriateness f the material r if the material will be distributed natinally r internatinally, the matter must be referred t the Legal department and Crprate Affairs. In all cases, it is the respnsibility f the business unit General Manager t ensure that Crprate Affairs receive a cpy f the material. Emplyees wh are asked t make public speeches n tpics related t GFG Alliance must btain the permissin f their manager r supervisr. If the matter appears t have significant imprtance, it shuld be referred t Crprate Affairs in advance. Any emplyee wh wishes t cntribute an article r paper t an utside publicatin n a tpic related t GFG Alliance must ensure that the dcument is apprved in advance by the relevant GFG Alliance Crprate Lead Team member and Crprate Affairs. 7.3 Relatinships with Gvernment Wherever GFG Alliance cnducts business, the Cmpany respects the authrity f Gvernment. GFG Alliance will maintain hnest relatinships with Gvernments, their agencies, fficials, and persnnel. GFG Alliance's ability t cnduct business is directly affected by Gvernment decisin-making. Therefre, GFG Alliance seeks t have cnstructive relatinships with Gvernment. GFG Alliance regularly shares infrmatin and pinins with Gvernment n issues that affect the Cmpany. The exchange f infrmatin and pinins is essential t infrmed decisin making by bth Gvernment fficials and GFG Alliance. Emplyees wh prvide infrmatin t Gvernments n behalf f GFG Alliance must ensure that all infrmatin is accurate and cmplete. Errrs r missins may be cnstrued as a vilatin f a law r regulatin and might damage the Cmpany's credibility. Emplyees wh lbby n behalf f the Cmpany r represent GFG Alliance in Gvernment matters must cmply with all applicable laws and regulatins relating t crprate participatin in public affairs. 7.4 Plitical Cntributins and Activities GFG Alliance maintains a psitin f impartiality with respect t party plitics. Accrdingly, GFG Alliance des nt cntribute funds t any plitical party, plitician r candidate fr public ffice in any cuntry. GFG Alliance cntributes t the public debate f plicy issues that affect the Cmpany. Fr example, GFG Alliance might discuss relevant issues with Gvernment fficials r prvide written advice abut the likely impact f prpsed plicies n the Cmpany. At times, attendance at events hsted by a plitical party may be required fr briefing purpses. Yur manager must be cnsulted if there is any dubt abut whether attendance at a functin wuld cmprmise GFG Alliance's impartiality r if any fee paid fr attending the functin is likely t exceed the cst t the plitical party f the meal r ther aspects f the functin. Cde f Cnduct Versin Nvember 2017 Page 13 f 14

14 8.0 RECENT DOCUMENT VERSION HISTORY Versin Issue Date Key Changes N/A 18/08/15 Last Annual Review by the Arrium Gvernance & Nminatins Cmmittee, apprved by the Arrium Limited Bard n 18 August /11/17 Rebranded t GFG Alliance. Varius web links and cntact details updated. Remved elements f Cde that were applicable nly t Australian publicly listed cmpanies. Cde f Cnduct Versin Nvember 2017 Page 14 f 14