Code of Ethics

Updated on

1. Application

This Policy applies to:
•  Super Housing Partnerships (HoldCo) Pty Ltd, its subsidiaries and companies over which it exercises control (“SHP”); and
• All directors, officers and employees of SHP (which includes temporary employees and contract staff and consultants) in relation to their activities while at or working for SHP(“Personnel”).

2. Code of Ethics and Professional Conduct

2.1 Overview
SHP expects that all Personnel conduct themselves according to the highest standards of ethics, integrity, and behaviour when dealing with our clients, colleagues and other stakeholders. Full compliance with all legal obligations imposed by statute or any other source of law is required by all Personnel. This Code of Ethics establishes the standards of behaviour that must be met by all Personnel. Where these standards are not met, appropriate disciplinary action will be taken, up to and including termination of employment or engagement. In cases where a breach of the policy involves a breach of any law, government authorities or the police may be notified.

2.2 Operation
This policy outlines SHP’s expectations from all Personnel and we require all Personnel to be familiar with and comply with the terms of this policy at all times. Insofar as this policy imposes any obligations on SHP, those obligations are not contractual and do not give rise to any contractual rights. To the extent that this policy describes benefits and entitlements for employees, they are discretionary in nature and are also not intended to be contractual. The terms and conditions of employment that are intended to be contractual are set out in an employee’s written employment contract

2.3 Governance Framework
This is a Workplace Policy reviewed and endorsed by the Board at least every three years. SHP may unilaterally introduce, vary, remove or replace this policy at any time.

2.4 Standards of Conduct
The standards expected of employees include:
• Compliance with all company and workplace policies, procedures, rules, regulations and contracts;
• Compliance with all laws;
• Compliance with all reasonable and lawful instructions given by or on behalf of SHP;
• Devotion of the employee’s entire time, attention and skill during normal working hours and at other times as reasonably necessary for the employee to perform their duties;
• To be honest and fair in dealings with customers, clients, co-workers, management and the general public, and to treat them with courtesy and respect;
• To be faithful and diligent, and actively pursue SHP’s best interests at all times;
• To work in a safe and compliant manner, and to observe all workplace health and safety rules and responsibilities;
• Refraining from any discriminatory, bullying or harassing behaviour toward customers, clients, co-workers, management and the general public;
• To not make any statements to the media about the SHP’s business, unless expressly authorised to do so by SHP (requests for media statements should be referred to the Chief Executive Officer);
• To not make any statements about the SHP on social media, or any other public platform, that may harm the SHP’s reputation;
• To not, in connection with the employee’s employment, accept any financial or other benefit from any entity other than SHP – unless acceptance of such benefit is in accordance with SHP’s other workplace policies or is otherwise disclosed to SHP and expressly permitted by SHP;
• To not engage in any employment or provide any services to any person or entity other than SHP, except with the SHP’s prior written consent;
• To not engage in any employment or provide any services to a supplier or competitor of SHP, except with SHP’s prior written consent;
• Immediately disclosing any potential, perceived or actual conflict of interest (whether direct or indirect) that may give rise to a conflict with the performance of the employee’s obligations to the SHP, or SHP’s business, confidential information or reputational interests. SHP may direct employees to take action to eliminate or reduce any such conflict, and employees must comply with such directions;
• To not engage in conduct, whether during or after work hours, that in the opinion of SHP causes damage or potential damage to the SHP’s property or reputation;
• To not use at work, or come to work while affected by (including any hangover or withdrawal effects), any drugs of abuse (whether illicit, prescription or otherwise) or alcohol;
• To not discriminate on the basis of personal characteristics including (but not limited to) sex, race, colour, nationality, disability, pregnancy, age, marital status, political opinion, religion, social origin or sexual orientation;
• To ensure and maintain punctuality;
• To respect the SHP’s property;
• To dress in an appropriate manner and to ensure that appearance is presentable, clean, neat and tidy (including but not limited to wearing any uniform that is required of you by SHP);
• To not use SHP internet to access and/or download sexually explicit material or other offensive material;
• To not use SHP email to send sexually explicit or suggestive material, or other offensive or harassing material;
• To maintain both during employment and after termination of employment with SHP, the confidentiality of any confidential information, records or other materials acquired during the course of employment;
• At all times, behave in a way that upholds SHP’s core values and the integrity and good reputation of SHP;
• Report any conduct of other workplace participants which is in breach of any of the above, or potentially in breach of any of the above, without delay.

2.5 Due Diligence
SHP takes an active approach to setting out our standards of practice in relation to due diligence that all employees must understand and abide by whilst employed by SHP.
SHP defines due diligence as being the reasonable background assessments and procedures undertaken before entering into an agreement or contract with a third-party – and to act with the highest standard of care in order to avoid adverse effects on the business as a result of not undertaking adequate due diligence. SHP sees due diligence as meaning ‘due diligence for doing business with SHP’.

SHP acknowledges our responsibility to ensure environmental, social and governance standards are maintained throughout our supply chain. A failure to uphold appropriate due diligence practices can adversely affect SHP’s business operations and reputation.

The required due diligence process to be undertaken when doing business with third-party contractors, consultants, and other goods and service providers (“Stakeholders”) across all areas of the business is outlined below:
• Ensure all Stakeholders comply with all legal requirements and professional standards within their given field or area of expertise.
• Where appropriate, ensure all Stakeholders understand, support and comply with SHP’s ESG Policy.
• Where possible, ensure all Stakeholders align with SHP’s ‘Supplier Code of Conduct’ (i.e. locally based, demonstrate ethical and sustainable business practices, are brand-aligned where possible, represent value for money and are committed to developing a positive working relationship with SHP).
• It is each employee’s individual responsibility when selecting and/or recommending a new Stakeholder do business with SHP, that the employee do their own background research on the Stakeholder’s business practices, environmental and social governance policies, reputation and quality track-record of their goods and/or service.
• It should be common practice for employees to request the following information when conducting due diligence on a new Stakeholder:
- Information on their diversity and inclusion policies and procedures.
- Information on their local procurement strategies and supply chain processes, policies, and procedures.
- Information on their environmental sustainability policies including: energy, water and waste management strategies and reduction targets.
- Information on their governance, community and social impact and/or charitable giving and philanthropic initiatives.

2.6 Indigenous and Human Rights
In formalising the Code, SHP acknowledges the United Nations guiding principles on business and human rights (also known as the Ruggie Principles). We understand our obligations with respect to human rights and the responsibility we have as a business to protect against human rights abuses, demonstrate and implement respect for human rights and if SHP should cause or contribute to having adverse human rights impacts, enable the appropriate and effective remediation for victims of business-related human rights abuse.

It is the responsibility of each employee to uphold SHP’s stance on human rights, ensuring that all employees and other stakeholders an employee may work with in relation to SHP, are treated with dignity and without discrimination, at all times.

SHP acknowledges the rights of Indigenous peoples and the responsibility we have to Indigenous communities within the locations we work. Being located on the traditional lands of the Wurundjeripeople of the Kulin nation, we acknowledge that sovereignty was never ceded and pay our respects to elders past and present, and extend this respect to other Indigenous Australians.

2.7 A Shared Responsibility
Preventing unlawful and inappropriate conduct in SHP is the responsibility of all. We have a shared responsibility to ensure that no individual is subjected to unlawful or inappropriate behaviour. As already noted in the Code, inappropriate workplace behaviours simply will not be tolerated by SHP and disciplinary action will be taken in proven instances.

Managers also have a role in ensuring a healthy, safe and productive work environment and to this end must:
• Create and maintain an environment free from unlawful and inappropriate conduct;
• Ensure they and their staff understand and comply with SHP Policy as adopted from time to time;
• Ensure all complaints are promptly investigated;
• Take appropriate disciplinary and corrective action;
• Ensure no victimisation or retaliation occurs;

It is the individual responsibility of all SHP Personnel to:
• Understand and comply with SHP’s Policy;
• Be aware of how their conduct may be perceived by others;
• Respect co-workers and business associates;
• Report unlawful or potentially unlawful conduct to your immediate manager or the Chief Executive Officer.
• Report inappropriate conduct in accordance with SHP’s Complaints Handling Policy.

All SHP employees are required to be patient, courteous and inclusive – ensuring that people of all backgrounds are welcomed and feel supported by our business, employees and workplace culture. We acknowledge that there is strength in diversity and as such, we encourage employees to share their feedback on this Code with their immediate manager or the Chief Executive Officer.

SHP employees must not engage in any conduct prohibited by this or any other SHP policy and, so that inappropriate behaviour is swiftly dealt with, should not tolerate harassment or inappropriate conduct.

2.8 Your options in reporting matters
If you believe you have been subject to inappropriate conduct, you should let SHP know by following the Complaints Handling Policy.