Our Code of Conduct
Contents Managing Director and Chairman s Message 1 About the Code of Conduct 2 Working Together Your Responsibilities 3 Business Policies & Procedure 4 Environment, Health & Safety 5 Equal Employment Opportunity, Discrimination, Bullying & Harassment 6 Privacy 7 Working with Customers, Partners and Suppliers (Our Brand & Reputation) 8 Working with Community & Government 9 Conflict of Interest 10 Anti-corruption 13 Accurate reporting 15 Competition Laws 16 Use of MG Property 17 MG Media & External Communications 19 How to Raise a Concern 21 Consequences of Breaching the Code 22 Your commitment 23
Managing Director and Chairman s Message The success of Murray Goulburn Co-operative Co. Limited (MG) is dependent on the knowledge, experience and talent of our employees, the strength of our management team, the quality of our business strategy and our compliance with the highest standards of corporate conduct, ethics and governance. We have a proud history since the MG was formed by a group of dairy farmers in Victoria, Australia, in 1950. We are constantly working to reinforce and communicate our values to our employees, shareholders, customers, suppliers and the broader community. We believe it is important to provide a clear set of values that emphasise a culture encompassing strong corporate governance, sound business practices and good ethical conduct. The Code of Conduct has been prepared for the guidance and benefit of all people employed, contracted by, associated with, or acting on behalf of MG. The Code of Conduct extends to all Company Directors. The Code of Conduct has been adopted by MG as it expresses the core values that drive our behaviour and aspirations. The key values underpinning the Code of Conduct are as follows: > our actions must be governed by the highest standards of integrity and fairness; > our decisions must be made in accordance with the spirit and letter of applicable law; and > our business must be conducted honestly and ethically, with skills and our best judgement, and for the benefit of customers, employees, shareholders and MG alike. You are required to read and be familiar with the Code of Conduct. The Board of Directors will adhere to the values and standards in the Code of Conduct and expect all employees to do the same. By doing so we can be proud of our individual and collective achievements, and ensure that MG maintains a reputation for the highest standards of business conduct, professionalism and integrity. We appreciate your support. Yours sincerely Gary Helou Managing Director Phillip W Tracy Chairman Code of Conduct page 01
About the Code of Conduct MG is committed to the highest level of integrity and ethical standards in all business practices. We all make decisions every day that can impact the success of MG and its reputation. Having a clear understanding of our expectations ensures that we are well equipped to make these decisions with integrity. The Code of Conduct outlines how MG expects you to behave and conduct business in the workplace on a range of issues. It forms an integral part of the MG Governance Framework and includes legal compliance and guidelines on appropriate ethical standards. The objectives of the Code of Conduct are to: > provide a clear benchmark for professional behaviour; > support our business reputation and corporate image within the community; and > make directors and employees aware of the consequences if they breach the Code of Conduct. Please take the time to read and understand the Code of Conduct. The Code of Conduct applies to: > everyone who works at MG, including permanent and casual employees, directors and our contractors and consultants; and > all business activities with suppliers, contractors, customers and shareholders in Australia and overseas. The Code of Conduct does not include every ethical issue that you might face or every law and policy that applies to MG. The Code of Conduct is supported by a range of policies, procedures and laws that must also be adhered to. Make sure you know the duties and obligations relating to your work and comply with them. We encourage you to: > actively understand the procedures and laws which affect or relate to MG s operations; > attend seminars presented by MG or other external service providers to maintain your knowledge of procedures and laws, as well as to increase your awareness of relevant legal and industry developments; and > interpret the law in a way which reinforces MG s reputation for integrity. As a global business, we are subject to the laws and regulations of countries in which we trade and operate. Where differences exist as the result of local customs, norms, laws or regulations either the Code of Conduct or local requirements must be applied whichever sets the higher standard of behaviour. If you have a question, please ask your Manager, People and Culture or the General Counsel. Code of Conduct page 02
Working Together Your Responsibilities In the spirit of co-operation, everyone is responsible for understanding and adhering to the Code of Conduct. By representing MG, you are expected to act in a manner consistent with our values and carry out your responsibilities professionally and ethically. Understand that how you go about business activities on behalf of MG is as important as what you achieve. All Employees and Contractors As an employee or contractor, it is your responsibility to: > know and comply with the Code of Conduct; > know and comply with MG s policies and procedures; > act with trust, loyalty, honesty and respect; > act in MG s best interests and according to legal and company business practices; and > raise any concerns or issues with your Manager, People and Culture Representative or through the anonymous Raising a Concern channel. Leaders Leaders in the business include supervisors, managers, executives and directors. Everyone with leadership roles in our business helps to provide guidance and direction. In particular, leaders have a responsibility to: > communicate the Code of Conduct to employees and contractors in their team; > create a culture where employees understand their responsibilities and feel confident to raise concerns; > identify potential business risks; > take a leadership role in observing and promoting the behaviour and standards in the Code of Conduct and related policies; > emphasise the importance of ethical conduct and compliance with the Code; > take immediate action if they observe a potential breach of the Code of Conduct or if a potential breach is reported to them. Code of Conduct page 03
Business Policies & Procedure MG believes in treating everyone we do business with fairly and equally. Our principles on key business issues are outlined below. All employees should be familiar with applicable laws. To help with this, MG issues policies and procedures to assist you. Ignorance of the law does not excuse you from your obligation to comply with the law or the Code of Conduct. The Code of Conduct should be read in conjunction with the following MG policies and procedures: > Public Disclosure; > Risk Management; and > Related Party and Conflicts of Interest. Copies of these documents are available on MG s website (www.mgc.com.au). MG continually assesses and upgrades its policies and procedures to ensure compliance with corporate governance requirements. You will be notified of any material changes or the introduction of new policies or procedures, which you are required to comply with. Code of Conduct page 04
Environment, Health & Safety Our first priority is safety. We are committed to maintaining a healthy and safe working environment for our employees, contractors and visitors. We are also committed to doing business in an environmentally responsible manner and identifying environmental risks that may arise out of its operations. You should familiarise yourself with MG s Health and Safety procedures to ensure the workplace is safe and without risk to yourself and others. You should also follow any lawful and reasonable instructions consistent with these procedures. Everyone has an obligation to comply with all health and safety laws, applicable regulations and procedures. Safety breaches can give rise to disciplinary action, including and up to termination of employment. If you are aware of, or suspect, an action that is not safe and/or is in breach of applicable laws and regulations, report the matter in accordance with the Raising a Concern part of this Code of Conduct. Remember, a healthy and safe working environment is everyone s responsibility. Always Comply with relevant health and safety laws, regulations and MG procedures, and help those working with you to do the same Ensure you identify, assess and take control of hazards Immediately stop any work that appears to be unsafe Use personal protective equipment required for the task Ensure you and your visitors are aware of emergency and evacuation procedures Report any accident, injury, unsafe condition, near miss or incident to your manager so action can be taken Never Undertake work unless you are trained, competent, medically fit and sufficiently rested and alert to do so Undertake work when you may be impaired by alcohol or drugs (illegal, legal or prescribed) Engage in or tolerate bullying, threats, intimidation or violence at work Compromise on health and safety procedures Ignore any unsafe condition or practice, near miss or safety incident Report to work in a condition that means duties cannot be performed safely Code of Conduct page 05
Equal Employment Opportunity, Discrimination, Bullying & Harassment We are committed to equal employment opportunity, and compliance with the full range of fair employment practices and anti-discrimination laws. We want a workplace free from any kind of unlawful discrimination, harassment, bullying, victimisation or any other form of unacceptable behaviour. Fair work practices do more than keep us compliant with applicable workplace laws. They contribute to a culture where everyone is treated with integrity and respect. Treating everyone fairly is the best way to build and maintain strong relationships. All employees are expected to be familiar with these procedures. Unacceptable behaviour will not be tolerated at MG under any circumstances. This includes: > judging a person on characteristics such as race, religion, gender, family responsibilities or any other prohibited ground of discrimination; > displaying material which is offensive or derogatory (including in emails or posts on social networking sites); > engaging in unwelcome conduct of a sexual nature towards another person, such as innuendo or inappropriate humour; or > bullying behaviour, such as verbal or written abuse. MG will promptly investigate complaints or allegations of unacceptable behaviour. Where allegations of a breach are substantiated, appropriate action will be taken, ranging from counselling to termination of employment. Retaliation against anyone for raising a genuine concern about unacceptable behaviour is not tolerated. Always Never Treat everyone with respect and dignity Behave in a way that could reasonably be perceived as offensive, intimidating or humiliating Make employment related decisions and actions on merit Speak up if you are upset by a person s behaviour. If you are uncomfortable speaking to the person directly, talk to your Manager or People and Culture Representative Make decisions based on age, race, gender or any other prohibited ground Ignore a concern about someone s behaviour Code of Conduct page 06
Privacy MG respects your privacy and the privacy of others. MG will only collect and retain personal information that is necessary to meet business requirements. MG will not use or disclose such information for any purpose other than the purpose for which it is collected. Personal information means information or data relating to an individual who can be identified by that information or data alone, or in combination with other information or data which is in MG s possession. This may include, but is not limited to, information about MG s employees, customers, contractors, consultants and job applicants. Various privacy laws apply to MG. These laws regulate the way MG: > collects; > uses; > discloses; > keeps secure; and > gives people access to their personal information. You should familiarise yourself with, and comply with: > Australian privacy laws and, where applicable, the jurisdiction of your business unit. If you have any questions in relation to privacy, please contact either your Manager/ People and Culture Representative or the General Counsel. Always Never Comply with applicable privacy laws and principles, including requirements about the collection, use, disclosure, security and access to personal information Ensure any personal information you hold about others is stored securely and keep it away from others who do not need to see it Share personal information of any kind (including health information such as medical records) unless required for a legitimate business purpose Gossip about personal details concerning others Destroy personal information securely Allow others to use your secure computer password Code of Conduct page 07
Working with Customers, Partners and Suppliers (Our Brand & Reputation) Our reputation and brand are very important to us. We are immensely proud of our achievements and the enduring partnerships we have developed with our customers, partners and suppliers world-wide. We expect the highest ethical standards of all our people, whether they are working with customers, partners, suppliers, shareholders, government or the community. Good business practices, and MG s ways of working mean that when you are dealing with others you must: > perform your duties in a professional manner; > act with honesty and integrity; > conduct business in line with the Code of Conduct, MG values and relevant laws and regulations; and > strive at all times to enhance MG s reputation and performance. Code of Conduct page 08
Working with Community & Government MG actively supports the communities in which we live and work. We all have a duty to act in a manner that merits the continued trust and confidence of the public. You are expected to uphold MG s commitment to pursue good corporate citizenship and to ensure that you do not act in any way that could cause harm to MG s reputation or market position during or after your engagement with MG. We support and encourage you to actively contribute to the needs of the local community. If you wish to make a contribution (such as donations or sponsorship) on behalf of MG, consult the General Manager, People and Culture or the General Counsel for approval. Code of Conduct page 09
Conflict of Interest While you are working with MG, it is important that nothing conflicts with your responsibilities to us both inside and outside of work. Even the perception of a conflict can compromise your work or MG s reputation. A conflict of interest exists where loyalties are divided. You may have a conflict of interest if, in the course of your employment or engagement with MG: > any of your decisions lead to an improper gain or benefit to you, or an associate or relative; or > your personal interests, the interests of an associate or relative, or obligation to another person or entity, conflict with your obligations to MG. Conflicts of interest include both financial interests and non-financial interests. You are responsible for informing MG of any conflicts of interest (actual or potential). If you are concerned that you may have a conflict of interest, you must disclose that interest in writing and discuss it with your Manager and your People and Culture Representative. The following are some common examples that illustrate actual or apparent conflicts of interest that you must avoid. These examples are a guide only. A conflict of interest might arise from: > a personal relationship; > holding outside jobs, directorships, memberships, affiliations, or public office; > offering or accepting gifts, hospitality or entertainment; > your financial interests in other businesses; > jobs or affiliations of close relatives; or > pursuing MG business opportunities for personal gain. Company Reputation You must not act in any way that could cause harm to MG s reputation or market position during or after your engagement. You have a duty to act in a manner that merits the continued trust and confidence of the public. Improper Gifts and Benefits Conflicts of interest can arise when you or a member of your family receive improper personal benefits as a result of your position. You and your relatives should not give unreasonable gifts to, or receive unreasonable gifts from, MG s customers or suppliers or others with whom MG interacts. You should also take into account your capacity to influence dealings that MG may have with gift or hospitality providers, and any improper personal benefit that may flow to you or a relative, friend or associate through the exercise of that influence. You may only accept unsolicited gifts or benefits with a value less than $100. Code of Conduct page 10
Conflict of Interest (continued) If refusal may offend, or if the value is estimated to be greater than $100, speak with your manager. Unless your manager approves this, it should be returned without delay. We encourage you not to accept a gift (of any kind or value) in circumstances where your business judgment might appear to have been compromised, or where you or MG would be embarrassed if the gift was made public. MG has extensive dealings with companies based in countries where gift giving has important cultural significance and plays an important role in business relationships. While you should be aware and respectful of such cultural practices, we encourage you to remain mindful of MG s requirements in this regard. Read and become familiar with the Related Parties and Conflicts of Interest Policy, which can be found on the website (www.mgc.com.au). If you are in doubt as to the appropriateness of a gift, please check with your People and Culture Representative or the General Counsel. Bribes, Inducements and Commissions You must not promise, offer, pay or receive any bribes, facilitation payments, inducements or commissions. This includes any item intended to improperly obtain favourable treatment or avoid unfavourable circumstances directly or indirectly. See the following section for further information. You must not give or receive any unreasonable gifts or otherwise act in an unethical way. Remember that agreeing not to act may have the same ramifications as acting in an unethical way. Requests for facilitation payments must be reported to your manager without delay. Code of Conduct page 11
Conflict of Interest (continued) Always Take particular care when providing any benefit to a government official Take care when accepting any item so that there is no misunderstanding created about any reciprocation or tied benefit Disclose in writing to your Manager and to People and Culture any outside activities, financial interests or relationships that may present a conflict or the appearance of one Act ethically and professionally in all personal and business dealings Avoid action or relationships that may cause potential conflicts or create the appearance of conflict with your role Never Offer, promise or provide any benefit to a government official, or cause this to occur, with the intention of securing business that is not legitimately due, or a business advantage Accept or give any gift or benefit which is cash/cheques/vouchers (which may be cashed), discounts or free services unless freely available to all other employees without discrimination Accept any benefits or hospitality during a contract negotiation or where it may give the appearance of undue influence without approval from your manager Engage, directly supervise, or make employment related decisions about a relative or partner unless authorised to do so by MG Personally pursue any opportunities that MG could have an interest in or that are identified through your position at MG or use of MG information or property Code of Conduct page 12
Anti-corruption MG prohibits all forms of bribery. In particular, we prohibit offering, promising or giving anything of value, either directly or indirectly, to any party in order to gain an unfair business advantage, such as obtaining or retaining business, or induce someone to perform their work improperly. This prohibition includes authorising, causing or allowing such conduct to occur through another employee or a third party. Facilitation payments are also prohibited and requests for facilitation payments must be reported to your manager without delay. If a payment is made in circumstances where there is an imminent threat to the life or safety of an employee, officer or contractor, this must be immediately reported to your manager and accurately recorded (including the amount and circumstances of the payment). MG also prohibits receiving, requesting or agreeing to receive anything of value that results or may result in the improper performance of your duties as an employee of MG. Special considerations apply when interacting with a Government official. Government official is broadly defined and includes: (1) government officials and employees at all levels of government; (2) employees or agents of state-owned or controlled enterprises (even if publicly listed); (3) government agents, advisers and consultants, including regulatory bodies, public institutions, the judiciary, the military and police; (4) other individuals acting in an official capacity on behalf of governments, governmental agencies and instrumentalities or political parties or political candidates; and (5) and employees or agents of public international organizations. You should consult the General Counsel before giving gifts, hospitality, travel or anything of value to a Government official. Corruption risks also exist when MG hires a third party to act on MG s behalf (a Business Partner ). Appropriate due diligence must be conducted before a Business Partner is retained. Business Partners must also agree in writing to comply with the anti corruption section of this Code of Conduct (an anti-corruption clause ) as a condition of doing business with MG. A breach of anti-corruption laws is a serious offence, which can result in fines for MG, as well as fines or imprisonment for employees and officers. A breach of the Code of Conduct will also result in disciplinary action, up to and including dismissal. Code of Conduct page 13
Anti-corruption (continued) Always Comply with the Code of Conduct and Gift Procedure when providing anything of value to a third party, including a Government official Take particular caution in providing or offering anything of value to a Government official, including gifts, hospitality, travel, per diems, or charitable donations Conduct due diligence with Business Partners Include an anti-corruption clause in contracts with Business Partners, which requires them to comply with MG s Code of Conduct Ensure all expenditures are accurately recorded in MG s books and records Never Give, promise or offer a bribe, improper benefit, kick-back, secret commission (or authorise this to be done) either directly or indirectly Give, promise or offer any benefit to a Government official with the aim of securing an improper advantage or inducing the official to act improperly Engage a Business Partner where there is a material risk that they will engage in corrupt conduct Do business with a Business Partner which refuses an anti-corruption clause Never falsify accounts, or use personal money to avoid complying with MG s requirements or Code of Conduct Immediately report any corruption concerns Ignore potential corrupt conduct Code of Conduct page 14
Accurate reporting All data created and maintained by MG must be accurate and complete. Altering, falsifying or destroying information or creating misleading information will not be tolerated. MG will comply with all applicable accounting and financial reporting rules and laws. All transactions must be properly authorised and accurately recorded in the relevant accounts and records as required by law and MG requirements. Once created, data must be appropriately retained and disposed of according to information management practices and applicable laws. There is never a justification for falsifying records or misrepresenting facts. Such conduct may constitute fraud and can result in civil or criminal liability for you and for MG. Always Keep accurate and complete company records, accounts and documents in accordance with generally accepted accounting principles Co-operate with internal and external auditors Immediately report any actual or suspected irregularities or weakness in relation to reporting, auditing, accounting or internal control matters Retain documents and records in accordance with applicable laws and procedures Never Falsify any record or make a false or misleading entry (including by omitting information in a report, record or expense claim) Ignore or avoid review or approval procedures Influence or allow another to do anything that would compromise the integrity of MG s records or reports Conceal or tamper with MG s records or documents Code of Conduct page 15
Competition Laws MG is committed to complying with laws governing competition. Competition (or anti-trust) laws are designed to prohibit a range of practices that restrain trade or restrict free and fair competition, such as price fixing and acts designed to achieve the power of a monopoly. You are encouraged to familiarise yourself with the legal requirements applying to competition and fair trading and to undertake training or attend seminars to develop and maintain your knowledge so that you can act in accordance with those requirements. Breach of competition laws can result in serious consequences for individuals as well as MG. Any failure by an employee to comply with MG s competition and fair trading requirements is extremely serious and may lead to disciplinary action, up to and including termination of employment. Always Never Maintain MG s independence in pricing, marketing and selling of any product Consider the appearance and implications of interacting with a competitor in business or personal settings Contact General Counsel: > Before exchanging competitively sensitive information with a competitor; > If inappropriate contact or anti competitive behaviour is initiated by a competitor or other third party; and > If a complaint is made about the competitive behaviour of MG Group. Collude with a competitor, for example by: > Fixing, or altering prices of goods; > Fixing competitive terms such as commissions or credit terms; > Agreeing to reduce or limit production capacity; > Illegally coordinating bidding or tendering activities; or > Boycotting any customer or supplier. Obstruct a competition or consumer regulator by providing false or misleading information Disclose to a third party competitive business strategies and plans, operations and other information of competitive value to MG Code of Conduct page 16
Use of MG Property We are all responsible for safeguarding and using MG property and assets in an appropriate way. MG property must never be used for personal benefit or any unlawful purpose. Company property and assets include cash, securities, business plans, confidential information, intellectual property (including computer programs, software and other items), office equipment and supplies, cars, mobile phones and computers. You are expected to take appropriate measures to ensure that MG property is not damaged, misused or stolen. This includes not allowing property to be disposed of, sold, destroyed or loaned without proper approvals. To the extent permitted by law, MG reserves the right to monitor or audit employee use of its information systems, and access electronic communication or information stored on MG systems for maintenance, business needs or to meet a legal or procedural requirement. You are encouraged to use common sense and observe professional standards regarding content and language when creating documents that may be retained by MG or a third party. Our information and electronic communications systems should not be used to access or post material that breaches MG procedures or any laws. Personal use of MG s electronic communications systems must also be consistent with the procedures approved by the IT department and applicable laws. Confidentiality You must not disclose or use, in any manner, confidential information about MG, its customers or its affairs, that you acquire during employment with MG, unless the information is already legitimately publicly available. Confidential information means any information about MG s business that is not available to the public and includes documents, books, accounts, processes or other know how that is: > supplied to you by MG; or > generated by you or colleagues in the course of performing your work with MG. This obligation continues to apply to you even after you leave MG. If you are unsure whether information is of a confidential nature, seek advice from your manager before disclosure. Please refer to the IT department regarding the use of MG s information systems. Code of Conduct page 17
Use of MG Property (continued) Intellectual Property Just like other company property, you must safeguard MG Intellectual Property (IP) from use by outsiders. IP is a valuable asset and protecting it is important so our competitive advantage can remain strong. Any inventions, trademarks, discoveries, processes and improvements made by you during your work with MG, remain the property of MG. This means MG will hold all proprietary rights to intellectual property and trade secrets. This includes all ownership rights, copyright, exclusive rights to develop, make, use, sell, licence or benefit from any inventions, discoveries, processes and improvements made during your work with MG. Always Take care to prevent loss, damage, misuse or theft of MG property Report the loss or theft of MG property immediately (eg. your computer, files or bag) Return all MG property including documents and confidential information at the end of your engagement or at MG s request Store MG property and documents securely and ensure it is covered by appropriate insurance if required to be removed from site If requested by MG, destroy or delete any confidential information stored in electronic, magnetic or optical form so it cannot be retrieved or reconstructed Never Use MG property for any unlawful purpose or unauthorised personal benefit Ignore the loss, misuse or theft of MG property Disclose or use confidential information about MG unless approved by MG Remove MG property or documents from official premises without a good and proper reason Accept or use any other organisation s confidential information Code of Conduct page 18
MG Media & External Communications MG must provide timely, accurate and complete disclosure to the community and shareholders. Public disclosures may only be made by authorised spokespersons, or with the permission of the Shareholder Relations team. This includes documents such as annual reports and any other communications including press releases, briefings on business performance, The Devondaler, interviews, speeches, articles, social media, blogs, reports, and information on the MG website. Media statements and official announcements may only be made by persons authorised under the Public Disclosure Policy. If you receive a request for information and you are not authorised to respond to the enquiry, refer the request to the Corporate Affairs Manager or the General Manager Shareholder Relations. If you are asked to speak at a conference, please ensure you have the written permission of your manager before agreeing to present. If the conference is a public forum, you must provide a copy of the presentation that has been approved by your manager to Corporate Affairs no less than 48 hours before the event or before it is disclosed publicly, whichever is the earlier. If you are approached to provide content for or participate in an interview with The Devondaler, please discuss this with your manager. The primary consideration regarding content in The Devondaler is to ensure accuracy of information and courtesy to your colleagues. Unless the Corporate Affairs Manager or General Manager Shareholder Relations have given prior written consent, you must not participate in public forum discussions (including social media and internet-based forums) about MG, its competitors or the industry in which MG operates. When using social media for personal communications, please keep in mind everything you say is in the public domain and may reflect upon you as an MG employee. You are responsible for the integrity of the information, reports and records under your control and you are expected to exercise the highest standard of care in preparing materials for public communications. Code of Conduct page 19
MG Media & External Communications (continued) Those documents and materials should: > comply with any applicable legal requirements; > accurately reflect the transactions or occurrences to which they relate; > not contain any false or intentionally misleading information; and > be in reasonable detail and recorded in the proper account and in the proper accounting period. MG has adopted the Public Disclosure Policy as a means of ensuring compliance with its disclosure and communication obligations under the Corporations Act 2001 (Cth). Ensure that you are aware of the requirements of the Public Disclosure Policy and, if it applies to you, you must act in accordance with the policy. Always Report media and investor inquiries promptly to the Corporate Affairs Manager Never Disclose information to the public unless authorised to do so Always seek permission from your manager to speak at public and industry events and provide the Corporate Affairs with a copy of your presentation Always think about your personal brand when using social media Let your manager know about articles and photographs to appear in The Devondaler Speak first, ask permission later you may accidentally release commercially sensitive information Make comments about MG on Facebook, Twitter and Online Forums, without first checking with the Corporate Affairs Manager Assume that because The Devondaler is MG s internal publication it is OK to pass on information about your team or business activities Code of Conduct page 20
How to Raise a Concern If you observe actions or behaviour that concerns you, or that may represent a breach of the Code of Conduct, we encourage you to raise the issue promptly with your Manager or with People and Culture Representative. Any concern raised will be treated confidentiality and you may remain anonymous if you wish. Channels to Raise a Concern You are encouraged to report to your Manager any genuine behaviour or situation which you believe breaches or potentially breaches the Code of Conduct, policies or the law. Alternatively, you can report unacceptable behaviour through any of the following channels: > General Counsel > People and Culture If you feel unable to raise an issue in this way, you can make a confidential, anonymous call to the Ethics Hotline to report unacceptable or undesirable conduct. To access the confidential alert line: > from Australia, call 1300 30 45 50 (8am to 6pm AEST Mon Fri); > outside of Australia, call +61 3 9811 3275; or > email: mg@stopline.com.au. What happens when a concern is raised MG is committed to ensuring that you are not disadvantaged or discriminated against for raising a concern in good faith. It is a breach of the Code of Conduct for any employee to cause disadvantage to or discriminate against an employee who makes a report under the Code of Conduct. Anyone who victimises someone for raising a concern in good faith will face discipline, which may include termination of employment. You have MG s commitment that, whenever possible, your calls, notes, emails and other communications will be dealt with confidentially. You are required to comply with any investigations into concerns about breaches of MG s policies or procedures. Code of Conduct page 21
Consequences of Breaching the Code We expect everyone who works at MG to know and comply with the Code of Conduct. MG recognises that breaches of the Code of Conduct may occur from time to time. We expect that any breach will be inadvertent and without intent, however it should be clearly understood that any breach may result in disciplinary action or other penalties. Depending on the nature of the breach, penalties may be imposed ranging from counselling up to termination of your contract or engagement. MG will act objectively and in accordance with any applicable provisions or requirements in an employment contract. MG reserves the right to inform the appropriate authorities where it is considered that there has been criminal activity or an apparent breach of the law. Make sure you know the rules that apply to you, and comply with them. If you have any questions regarding the Code of Conduct, policies or procedures at any time, you should contact your Manager and/or your People and Culture Representative. Code of Conduct page 22
Your commitment You will receive a copy of the Code of Conduct when you join the Company. It is your responsibility to read and understand the Code of Conduct. If there are any aspects of the Code that you do not understand please contact your manager or your People and Culture contact. All employees are required to sign an annual commitment to the Code of Conduct acknowledging they have read and understand their responsibilities under the Code of Conduct and related MG policies and procedures. Code of Conduct page 23
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