GO1 Pty Limited, together with its associated entities and complementary businesses
(collectively “GO1”, “we”, “our” or “us”) has developed a separately published Corporate Code of Conduct so that our Board members, officers, employees and contractors, wherever they may be located or working in Australia or overseas (referred to below as “you” or “your”) clearly understand the kinds of behaviour and conduct required to give effect to our values, achieve our goals and comply with our Constitution and all applicable laws and regulations.
This policy is designed to give you a more detailed understanding of the standards, conduct, behaviour and actions expected of you by GO1 in the course of your day to day relationship with GO1 and the consequences of not meeting these expectations.
You are required at all times to comply with this and other GO1 policies.
Our Chief Executive Officer (CEO) is responsible to the Board of Directors for the ethics and culture of GO1.
All managers, supervisors and team leaders have a responsibility to support the CEO in upholding a high standard of ethical behaviour and business conduct. Managers, supervisors and team leaders must take all steps that are reasonable in the circumstances to ensure that the people for whom they are responsible are aware of and uphold the conduct, behaviours and actions outlined in our Corporate Code of Conduct and set out in this policy.
Managers, supervisors and team leaders are responsible for:
✓ consistently setting a positive example;
✓ ensuring that our standards, policies and procedures are readily accessible and understood;
✓ fostering a culture in which employees understand their responsibilities, are comfortable to raise concerns without fear of retaliation and are encouraged to work according to our values;
✓ promptly responding to legitimate concerns and questions about business conduct issues;
✓ implementing risk management practices which address business conduct issues and handling breaches of standards and expectations in a timely and effective manner;
✓ enshrining the requirements of our Corporate Code of Conduct and this policy into existing systems and processes, including performance management and development processes, employment and commercial contracts, and induction and training.
Health and safety, social responsibility and environmental sustainability are fundamental to the way we do business.
✓ learn and comply with the requirements of our mandatory health and safety standards, procedures and rules and support your colleagues to do the same;
✓ ensure you identify, assess and take steps to control health and safety hazards associated with your work;
✓ immediately stop any work that appears to be unsafe and report it to your immediate manager;
✓ handle and dispose of all materials properly, safely and lawfully;
✓ make sure you know what to do if an emergency occurs at your workplace and that visitors are familiar with emergency procedures;
✓ report to your manager any accident, injury, illness, unsafe or unhealthy condition, incident or release of material to the environment (never assume that someone else will report a risk or concern and that you therefore do not need to report it);
You must not:
× undertake work unless you are trained, competent, sufficiently fit and alert to do so and free from the influence of alcohol or other drugs (illegal, legal or prescribed);
× smoke at times and in places where smoking is prohibited.
× use or tolerate threats, intimidation or other violence at work.
A conflict of interest may arise if and when a person in a decision-making position participates in an activity or acquires another interest or loyalty that jeopardises, or could jeopardise or be perceived as jeopardising the person’s judgement, objectivity, impartiality or independence.
✓ conduct all business relationships in a professional, impartial and competitive manner;
✓ declare family relationships where we are or may be considering employing or contracting with a person to work with you, report to you or whom you may report to;
✓ promptly advise your manager in writing of any outside activities, financial interests or relationships that may involve you either in an actual conflict of interest or the perception of one;
✓ promptly excuse yourself from any decision-making process where you have an interest that influences, or may be perceived as influencing, your ability to make an objective decision and to fulfil your responsibilities to GO1.
You must not:
× use your position or knowledge or our assets, identity or standing for your own personal advantage or that of others;
× work for or provide advice or consulting services to a competitor, supplier or customer of GO1;
× run any other business or be involved in other arrangements in your free time which will compete with us;
× engage in financial investments associated with competitors, suppliers or customers other than nominal investments in public companies, or arrangements for ordinary consumer transactions on standard commercial terms.
✓ respect the cultures and business customs of the countries and communities in which we operate, provided they do not conflict with our Corporate Code of Conduct and applicable laws;
✓ seek to understand the concerns and expectations of communities in which we operate, which are relevant to our business, and consider them in your decision making;
✓ act truthfully, accurately, cooperatively and courteously when dealing with government officials and community leaders;
✓ be alert to the corruption levels where you work or travel and stand firm against possible corruption.
You must not:
× authorise, offer, give or promise anything of value directly or indirectly to a government official or community leader in order to influence official action;
× attempt to obstruct or hinder the lawful collection of information, data, testimony or records by appropriately authorised government or regulatory officials;
× take action against any person who lawfully and properly cooperates with government agencies;
× intentionally favour individuals from one political, religious or ethnic group on the basis of their membership of that group (other than where such action supports our approved or legally required program of positive action, e.g. to assist historically disadvantaged groups in the community).
We are committed to fulfilling our obligations under the Privacy Act 1998 (Cth), as amended and the Australian Privacy Principles, together with any other applicable privacy legislation or regulation in countries or regions in which we operate, including the European GDPR (“Privacy Laws”).
✓ only collect personal information by reasonable and fair means, without intimidation or deceptions or unreasonable intrusion;
✓ collect personal information about an individual only from the individual unless it is unreasonable or impracticable to do so;
✓ only collect personal information if the information is reasonably necessary for one or more of the functions or activities of GO1;
✓ comply with all legal requirements that apply to the collection, storage, use, disclosure, quality and security of personal information.
✓ use personal information only for the purpose for which it was collected unless otherwise authorised by the relevant individual or by law;
✓ utilise safeguards to help protect personal information against such risks as loss or destruction or unauthorised access or use, modification or disclosure;
✓ have a system to help ensure that personal information is not retained longer than legally required or necessary to meet the business reason for which the information was collected;
✓ maintain the accuracy of personal information;
✓ otherwise comply with the Privacy Laws.
You must not:
× access personal information unless you have appropriate authorisation and a legitimate business need for that information;
× provide personal information to anyone inside or outside of GO1 without proper authorisation;
× conduct reference checks without proper authorisation or the consent of the individual.
✓ keep GO1 information confidential;
✓ report any leaks or unauthorised disclosure of GO1 information, of which you become aware, to your manager or through any whistle-blower medium we may have in place from time to time;
✓ be careful with the information you talk about with other GO1 employees or contractors, including any confidential projects you are working on;
✓ seek advice from the Company Secretary or Group Legal Counsel if you have any doubt about the propriety of any transaction that you are contemplating.
You must not:
× disclose inside information to anyone outside of GO1, including family and friends, unless it is appropriately authorised, documented and is necessary for our business activities;
× trade in the shares of counterparties when you have access to inside information that, if it were made public, could reasonably be expected to affect the counterparty’s share price.
✓ seek approval in writing from a Member of the Executive team to engage in any outside employment, including as a director or consultant or office holder to boards or government instrumentalities; in doing so, provide the following details:
o The name and business activities of the employer; o the position and nature of the work; and o the hours of work; and abide by any decision that is made.
You must not:
× work for or have an interest in any organisation or activity involving a competitor, supplier or customer of GO1 or organisation affiliated with any of these.
✓ report any gift, hospitality or entertainment accepted, rejected or returned, whether directly or through an intermediary;
✓ ensure that gifts, hospitality and entertainment are modest and comply with applicable laws, regulations, and local customs; use good judgement in deciding what is modest;
✓ politely decline any offer that is not in line with our Corporate Code of Conduct and our management practices;
✓ clearly communicate our requirements on accepting gifts, hospitality and entertainment at the beginning of any new business relationships, especially where cultural norms may be different from those outlined in our Corporate Code of Conduct;
✓ assess and avoid the potential for a conflict of interest when offering or accepting gifts, hospitality or entertainment.
You must not:
× request or imply that you would accept a gift or hospitality or entertainment of any kind from a supplier, customer, partner or other party with whom we make business;
× keep a gift or accept hospitality or entertainment above a modest value without obtaining authorisation from a member of the GO1 Executive Team;
× exchange gifts, hospitality or entertainment with our competitors’ representatives; this may create an actual or perceived conflict of interest or be perceived as anticompetitive behaviour.
✓ seek approval from the Chief Executive Officer before committing GO1 to any donations to or sponsorships of any cause or charity.
✓ take care to prevent waste, loss, damage, misuse, theft or misappropriation of our assets and comply with, and ensure that third parties comply with, our requirements and all laws regarding the use and transfer of our assets;
✓ lock or appropriately secure unattended buildings, storage areas, vehicles and equipment owned, leased or occupied by us;
✓ report unauthorised access to our facilities to your immediate manager;
✓ regard, both during and after your employment or engagement, the information obtained by participating in the development of processes or products for GO1, or the results of such work, as our property;
✓ advise us of the results of all work done during or outside of working hours that relate to the business or operation of GO1 to enable us to protect our interests and rights in, relating to or resulting from such work;
✓ assist us to obtain patents, copyrights or other protections of our intellectual property in the name of the relevant company within GO1;
✓ make sure that your conduct, actions or work product do not infringe any third-party intellectual property rights and, if you are ever in doubt about potential infringements, seek advice from our Group Legal Counsel.
You must not:
× allow unauthorised persons to enter any GO1 facilities;
× copy keys to our facilities without appropriate authorisation or give keys to unauthorised persons;
× disregard security complaints or inadequate security procedures or practices that might present safety or security threats to our people or assets;
× bring to GO1 any confidential information, including computer records, from prior employers or principals.
✓ access and use GO1’s computer, email and internet resources for business purposes only or for limited private purposes provided this:
o is kept to a minimum; o does not interfere with or delay your work obligations in any way; and
o complies with all GO1 policies and directions and is not inconsistent with your contract of employment or engagement.
✓ if you receive offensive or sexually explicit material, delete it immediately and report it to your team leader and IT team (particularly where the material is of a serious nature or is received on a repeated or frequent basis);
✓ only comment on social media as a representative of GO1 if you are trained and authorised by the Chief Executive Officer to do so only in accordance with our Social Media Policy and guidelines;
✓ where your personal comments or profile on social media can identify you as an employee or contractor of GO1:
o only disclose and discuss publicly available information;
o ensure that all content published is accurate and not misleading and complies with all relevant GO1 policies;
o expressly state on all postings (that identify you as our employee or contractor) the stated views are your own and are not those of GO1; o be polite and respectful to all people you interact with;
You must not use our computer resources for:
× displaying or transmitting offensive or sexually explicit material, including from outside sources;
× unlawful activities (e.g. hacking);
× activities that create an actual or potential conflict with your obligations to GO1 (e.g.
sending sensitive information to a competitor);
× copying or using material in a way that infringes another party’s copyright or other intellectual property rights;
× sending abusive language or graphics in either public or private messages;
× activities which could cause congestion and/or disruption of networks or systems;
× accessing, viewing, posting, downloading, storing, transmitting, sharing, printing, distributing or soliciting of any information or material that might be construed as offensive, obscene, defamatory, threatening, harassing, bullying, discriminatory, hateful, racist, sexist, infringing copyright, constituting a contempt of court, breaching a court suppression order, or as otherwise unlawful;
× sending email messages containing material that is or could reasonably be considered offensive, defamatory, discriminatory, derogatory threatening or obscene; e.g.
o sexual comments or images,
o solicitation of non-business causes (e.g. to political or religious causes unless the activity is a GO1 sponsored or sanctioned activity); o chain-letters;
o gender specific comments, or any comments that might offend someone on account of his or her age, gender, sexual orientation, religious or political beliefs, national origin or disability;
You must not knowingly:
× download, install, open or use any unauthorised software, program or file;
× connect, install or use any unauthorised hardware or other equipment;
× use software for which GO1 does not have a licence or sufficient licences;
× open any files or software containing or potentially containing viruses.
When engaged on social media, you must not:
× Imply that you are authorised to speak as a representative of GO1, nor give the impression that the views you express are those of GO1 unless specifically authorised and trained to do so;
× use our email address or any GO1 logos or insignia, especially where they may give the impression of official support or endorsement of your personal comment;
× use the identity or likeness of another employee, contractor or other member of GO1;
× make any comment or post any material that might otherwise cause damage to our reputation or bring us into disrepute.
✓ keep accurate, complete, true and up-to-date books, records, accounts and documentation;
✓ record work time, absenteeism and financial transactions relating to GO1 accurately and in accordance with generally accepted accounting standards;
✓ protect our official records from unauthorised access, interference or use;
✓ be alert to ensure that no undisclosed or unrecorded account, fund or asset is created or maintained;
✓ cooperate fully with our internal and external auditors;
✓ demonstrate integrity and accuracy when submitting and approving expense claims;
✓ retain documents and records in accordance with the applicable laws and our internal information management practices;
✓ return or transfer the custody of all relevant records if you change your job within GO1 or if you leave GO1 for any reason;
✓ immediately report any actual or suspected irregularities or weaknesses in relation to auditing, accounting or internal controls to your manager or through any whistleblower medium we may have in place from time to time;
You must not:
× commit GO1 to contractual obligations that are beyond the scope of your delegated authority;
× deliberately falsify records or make false or misleading entries, including by omission, in any reports, records, expense claims or other financial or nonfinancial records or conceal or tamper with our records or documents;
× influence or allow others to do anything that would compromise the integrity of our records or reports or circumvent or compromise our review and approval processes.
✓ when engaged in private political activities in your own time, make it clear that you are speaking or acting on your own behalf and not on behalf of GO1;
✓ conduct business dealings on behalf of GO1 with any political party, politician, elected official or candidate for public office in any country in accordance with our Corporate Code of Conduct and all applicable laws and regulations governing corporate participation in public affairs and anti-corruption;
✓ seek approval from the Chief Executive Officer for involvement in any businessrelated activities organised by or on behalf of a political party or candidate and be transparent when undertaking such activities;
✓ be mindful and respectful of GO1’s reputation and how the public would perceive your actions when engaging with government officials.
You must not:
× give free or discounted use of our premises or equipment as an in-kind donation to a political party;
× pay wages or salaries of a GO1 employee working for a party or candidate during normal working hours;
× make a cash or an in-kind contribution or incur expenditure using a GO1 account to any political campaign, political party, political candidate or elected official or use charitable donations as a veil for a political payment;
× use your position in GO1 to try to influence any other person to do any of the above.
EEO, non-discriminatory practices and the treatment of colleagues
GO1 is committed to the principle of equal employment opportunity and to providing a productive workplace in which you can work free of unlawful discrimination and harassment.
In support of this commitment:
✓ act with fairness and respect and with concern for individual rights in all your dealings with other people, consistent with our Corporate Code of Conduct;
✓ ensure employment-related decisions, including recruitment, selection, transfers, promotions, performance reviews, training and development, supervision and management, counselling, disciplinary procedures, remuneration and separation are based solely on merit and legitimate business considerations;
✓ familiarise yourself with and act in accordance with local legislation and cultural considerations that may impact workplace decisions and actions;
✓ understand and comply with our separately published policy entitled EEO, Discrimination and Harassment Policy;
✓ participate in any investigation conducted in relation to discrimination, harassment, bullying or victimisation as and when required by GO1.
You must not:
× discriminate or tolerate discrimination against a person or make jokes on the basis of the person’s gender, marital status, pregnancy, parental/family responsibilities (including breastfeeding needs), race, age, disability, sexual orientation, transgender, political/religious beliefs, trade union activity/inactivity or physical appearance;
× behave in a manner that could reasonably be perceived as offensive, insulting, intimidating, malicious, humiliating, harassing or bullying or engage in sexual harassment (e.g. unwelcome sexual advances, requests for sexual favours, inappropriate or unwelcome physical contact or sexual suggestions, distribution or display of sexual material, including inappropriate pictures or cartoons) - if you are unsure of the meaning of these behaviours, refer to our EEO, Discrimination and
Harassment Policy) or ask a Human Resources team member for help;
× spread malicious rumours or use our resources to transmit derogatory, discriminatory, abusive or harassing material;
× victimise a person who has complained of the kinds of behaviour described above.
If you are in a management position that carries responsibility for relevant employment decisions, you must:
✓ recruit for employment from a diverse pool of candidates in a manner that promotes diversity for all positions, including senior management and the Board of Directors;
✓ review succession plans to ensure an appropriate focus on diversity;
✓ identify and have regard to specific factors in recruitment and selection processes to encourage diversity;
✓ manage programs to develop a broader pool of skilled and experienced senior management and Board candidates, including, workplace development programs, mentoring programs and targeted training and development.
✓ report to work fit and ready to carry out your duties free from the influence of alcohol and other drugs;
✓ advise your immediate manager of any prescription drugs you are taking that might impact upon the safe and effective performance of your work;
✓ drink responsibly in case GO1, at its discretion, allows the consumption of alcohol at work events and on its premises
You must not:
× undertake any work, including driving to and from work and attending work functions, when you are impaired by alcohol or other drugs, whether they are legal, prescribed or illegal;
× consume, offer or make available to any other person alcoholic beverages or other drugs (legal, prescribed or illegal) at any GO1 site or office unless GO1 explicitly allows the consumption at its discretion;
× possess, use or transfer alcohol or illegal drugs or other illegal substances on our premises;
× ignore a case of substance abuse if you witness one.
Everything you produce for GO1 or in the course of your work for GO1 that has the capacity to be stored in physical or electronic form is our property.
You must keep all confidential information confidential which means you must:
✓ only use and disclose confidential information so far as it is necessary for the proper and authorised performance of your duties;
✓ maintain and take all steps necessary to maintain all confidential information in strictest confidence;
✓ ensure that proper and secure storage is provided for any confidential information in documented or other readable form;
✓ take all reasonable precautions necessary to prevent accidental disclosure of any of the confidential information;
✓ if at any time you believe that you are obliged by law to disclose confidential information, immediately notify the Company Secretary of such belief, giving the reasons why you have formed the belief and not disclose the confidential information until we have an opportunity to consider those reasons and take such action as we consider necessary in the circumstances.
You must not:
× use for your own benefit, or disclose to, or use for the benefit of any other person, firm or corporation, or use to the detriment of GO1, any confidential information.
There are laws, codes, standards and regulations that govern our business transactions and practices in all jurisdictions in which we operate, which may vary from jurisdiction to jurisdiction. Some of these are the subject our Corporate Code of Conduct and this policy. Whether contained in the Corporate Code of Conduct and this policy or not, you must:
✓ be aware of and comply with the laws, codes, standards and regulations that govern your conduct.
✓ maintain independence of judgement in pricing, marketing and selling of our products;
✓ consider the appearance and implications of interacting with competitors, whether in a business or personal setting, and avoid any action which could imply unlawful coordination with competitors;
✓ contact our Group Legal Counsel (and obtain approval as required):
o before joining or renewing membership of a trade association involving competitors, o before submitting any information to a competition authority,
o before exchanging competitively sensitive information, directly or indirectly, with a competitor, o if inappropriate contact is initiated by a competitor, o if a complaint is made about the competitive behaviour of GO1,
You must not:
o if you suspect that a third party is acting in an anti-competitive manner toward GO1.
collude with a competitor by:
o fixing, raising, lowering or stabilising prices of products sold or purchased;
o fixing other competitive terms such as pricing formulae, discounts, margins, rebates, commissions or credit terms; o rigging a bid or otherwise illegally coordinating bidding or tendering activities; o allocating markets, customers, suppliers or geographic territories, o boycotting any customer or supplier;
× obstruct a competition authority by providing false or misleading information, concealing or destroying documents or alerting any third party to the existence of an investigation;
× seek to obtain a competitive bid;
× give one supplier’s confidential business information (for example, proposed rates, winning bid information and the like) to another supplier.
If you think a decision or action is out of step with our values, Corporate Code of Conduct or this policy or you have a concern about how to comply with the Code of Conduct, any GO1 policy or procedure or any other GO1 requirement or the law, you have a right and a responsibility to raise that concern.
You are encouraged to:
✓ report any breaches of or behaviours that are inconsistent with the Corporate Code of Conduct or this policy or other GO1 policies to your manager or through any whistleblower medium we may have in place from time to time;
✓ anticipate and plan in advance to guard against new or potential circumstances where corruption might occur or have the potential of occurring;
✓ acknowledge the necessity of compliance with anti-corruption laws when setting key performance indicators;
✓ immediately report any corruption, fraud or competition concerns to your manager or through any whistleblower medium we may have in place from time to time so that appropriate action can be taken;
✓ cooperate with and participate in any investigation concerning improper conduct.
You must not:
× victimise, harass, or discriminate against whistleblowers or witnesses or their relatives or colleagues.
If you have any queries about the interpretation of our Corporate Code of Conduct or this policy or have concerns about how they are being applied, you should immediately raise them with your manager. Where this is not possible or it is inappropriate to do so, contact your People & Culture representative, Group Legal Counsel or a member of senior management.
Conduct or behaviour that is inconsistent with or in breach of our Corporate Code of Conduct, this policy or other separately published policies and procedures may be investigated by GO1 and may be subject to disciplinary action, including termination of your employment or engagement.
o the health or safety of a person; or
o the reputation, viability or profitability of GO1.
Examples of serious misconduct warranting summary dismissal include:
For a copy of the Corporate Code of Conduct, please send a request to Legal@go1.com”