GWA055 Created By Updated By Executive Director Date May 2012 Rev. No. 1 Date NA File Name GWA055 Approved By GWA Group Limited Board of Directors Date May 2012 Pages 9 All printed copies are uncontrolled unless they have been signed and a copy number recorded. Distributed and signed by Copy No.
TABLE OF CONTENTS 1. PURPOSE... 3 2. SCOPE... 3 3. RESPONSIBILITY... 3 4. APPLICABLE DOCUMENTS... 3 5. DEFINITIONS... 4 6. RECORDS... 4 7. GENERAL PRINCIPLES AND REQUIREMENTS... 4 8. MEASURABLE OBJECTIVES, TARGETS AND KPIS... 6 9. ADDENDA... 9
1. Purpose GWA Group Limited ( the Company ) is committed to the promotion of diversity in the organisation through the implementation of targeted employment policies and initiatives to achieve a diverse workforce, as well as ensuring our employees enjoy a workplace environment free from harassment, discrimination and bullying. This Diversity policy sets out the framework for achieving a diverse workforce. The Company recognises the significant benefits arising from a diverse workforce such as: increasing the pool of talent from which the Company can draw high quality employees: retaining talented employees; the different perspectives that can be brought to the Company from a diverse workforce which may encourage greater innovation and efficiencies; and improved corporate performance and increasing shareholder value. 2. Scope This policy applies to all directors, managers and employees of the Company and its subsidiaries. 3. Responsibility Although the Board retains ultimate accountability for this Policy, the Board has delegated responsibility for Policy implementation to the Managing Director. In turn the Managing Director has delegated to the Executive Director responsibility for the administration of this Policy (including its reporting to the Board, or its relevant sub committee as appropriate). 4. Applicable Documents Page 3 of 9 Pages
GWA001 Employment Policies Manual 5. Definitions Diversity is acknowledging, understanding, accepting, valuing, and celebrating differences among people. Diversity occurs in areas such as gender, race, religion, sexual preference, age impairment or disability, family responsibilities, marital status and status as a parent or carer. However, it is not limited to these examples. Diversity also exists between individuals in the roles they perform, where they are from, and their socio-economic status. 6. Records What Who Where How Long GWA GWA055 Executive Director GWA HO Indefinitely 7. General Principles and Requirements 7.1 This policy reflects the ASX Corporate Governance Principles and Recommendations ( ASX Recommendations ) for addressing Diversity and the Company s Code of Conduct. The is based on the following principles: 1. Treat others with respect, value differences and maintain privacy; 2. Value diversity and it will bring opportunities to enhance our businesses; 3. Women and minority cultural groups will not be disadvantaged in gaining employment and accessing the benefits and privileges that other persons enjoy in their employment with the Company; Page 4 of 9 Pages
4. Transparency will be exercised in all recruitment decisions from Board level to entry level; 5. Workforce composition statistics will be reviewed annually to determine if there are any areas that warrant an increased focus on diversity; and 6. Public reporting of progress against the Company s diversity objectives. 7.2 The Company will ensure that it is attuned: to diverse strategies to deliver the Group s objectives; to diverse corporate, business and market opportunities; and (c) to diverse tactics and means to achieve those strategies in and to take advantage of those opportunities in. 7.3 Managers will ensure that they are: adding to, nurturing and developing the collective relevant skills, and diverse experience and attributes of our employees; ensuring the Company s culture and management systems are aligned with and promote the attainment of a diverse workforce. 7.4 Employees will ensure that they: respect every employees dignity, rights, freedoms and individual needs; and comply with the Company s Equal Employment Opportunity and Harassment Policy Page 5 of 9 Pages
7.5 The Company will develop strategies, initiatives and programs to promote diversity, including the achievement of gender diversity. 7.6 In particular, the Group will set measurable objectives, and targets or key performance indicators (KPIs) for the strategies, initiatives and programs to achieve gender diversity. 7.7 The Group will implement the strategies, initiatives, programs and measurable objectives referred to in 7.5 and 7.6. 7.8 Management will monitor, review and report to the Board (including via the Nomination Committee) on the achievement of gender diversity and progress on other diversity initiatives arising under this Policy. 8. Measurable Objectives, Targets and KPIs 8.1 KPIs Gender Diversity With respect to gender diversity, management will: develop, for approval by the Board or its relevant sub committee, as appropriate: i. measurable objectives concerning the strategies, initiatives and programs to achieve gender diversity; ii. targets or KPIs to verify progress towards attainment of those measurable objectives. measure performance against those targets and KPIs; (c) report from time to time on the progress of the matters referred to in and. Page 6 of 9 Pages
8.2 Compliance Requirements 8.2.1 The Company will meet its obligations with respect to the issue of Diversity, as may be required under the ASX Recommendations and other regulatory requirements (if any), including by: a) establishing this Policy as a compliant policy under ASX Recommendation 3.2 by: i. establishing measurable objectives for achieving gender diversity; ii. the Board or its relevant sub committee assessing annually the measurable objectives for achieving gender diversity and the progress in achieving them. b) disclosing this Policy or a summary of it under ASX Recommendation 3.5; c) in its Annual Report, and in the terms of ASX Recommendation 2.4, disclosing the processes the Board adopts and the criteria the Board takes into consideration in its selection of prospective new Board members; d) in its Annual Report, and in the terms of ASX Recommendation 3.3 and 3.4, disclosing: i. the measurable objectives for achieving gender diversity set by the Board in the terms of this Policy; ii. the progress from time to time towards achieving them; iii. the proportions in the Group (relative to their male counterparts) of: female employees; females in senior executive positions; females on the Board Page 7 of 9 Pages
e) incorporating in the Corporate Governance Statement in its Annual Report a statement as to the mix of skills and diversity that the Board is looking to achieve in membership of the Board, in the terms of ASX Recommendation 2.6. f) the Executive Director will assume line responsibility to assure that the Company meets its compliance and reporting obligations referred to in to (e) above, including by collecting and collating all relevant data and ensuring that management processes and systems are adequate and effective for such reporting obligations to be met. 8.3 Communication The Company commits to the communication of this Policy within the Group, to its shareholders and the market, including via its website: by way of transparency and accountability; and to better promote the prospects of attainment of diversity in the workplace. 8.4 Accountability Reporting and accountability in the terms of this Policy will be via the monthly Board reporting process. At least annually the Nomination Committee will review the progress towards attainment of gender diversity, and otherwise to assist the Board in meeting its compliance requirements under 8.2. Page 8 of 9 Pages
8.5 Addenda to this Policy The following shall constitute addenda to this Policy as if set out in this Policy: approved strategies, initiatives and programs and measurable objectives; and approved measurable objectives, targets and KPIs; as may be approved by the Board from time to time. 8.6 Overriding Caveat Nothing in this Policy shall be taken, interpreted or construed so as to endorse: (c) the principal criteria for selection and promotion of people to work within the Group being other than their overall relative prospect of adding value to the Company and enhancing the probability of achievement of the Company s objectives; any discriminatory behaviour by or within the Company contrary to the law, or any applicable codes of conduct or behaviour for the Company and its employees; any existing person within the Company in any way feeling threatened or prejudiced by this Policy in their career development or otherwise, merely because their Diversity attributes at any time may be more, rather than less, common with others. 9. Addenda Page 9 of 9 Pages