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Owner's Expectations Manual

Annex 9: Specimen contents of a code of conduct/ethics

1 Philosophy and commitment to the code

  • This section of the code should include a clear statement of the philosophy of the code (eg, that it represents the core values of the company and is a fundamental aspect of good business practice) and commitment by the board and management to it.

2 Responsibilities to shareholders

  • This section should include a statement acknowledging the objective to operate as a successful business, while adhering to the Crown's expectations in all areas.

3 Responsibilities to stakeholders

  • This should include a company's approach to serving the needs of stakeholders (including employees, customers and suppliers) and the community generally (eg, through environmental protection policies or sponsorship).

4 Responsibilities to employees

  • This section should provide an outline of the company's practices in areas such as health and safety, diversity, training and further education.

5 Legal compliance

  • The code should include policies that the company follows to ensure active compliance with legislation.

6 Conflict of interests

  • This section of the code should specify how the company handles actual or potential conflict of interests, the individual's obligation to disclose and the need to “err on the side of caution”.

7 Policies on gifts, bribes, commissions, use of company property and confidential information

  • This section of the code should have an outline of the policies the company has in place to prevent unethical or unlawful behaviour in these areas and how the property of the company, its own and individuals' information, are kept secure and confidential.

8 Reporting of unethical behaviour and code breaches

  • The code should describe the process that the company follows to encourage the reporting of unethical behaviour and the measures taken to deal with breaches of the code.
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