TEG Code of Conduct

Introduction

Ethical business practices and high standards of personal behaviour are fundamental to the way we work as a responsible, sustainable business.

Our Code of Conduct reflects who we are, what is important to us and outlines our expectations and our responsibilities.

Our Code applies to all employees, contractors, officers, and Directors referred to as Workers in this document.

The reputation and good standing of the Company depend on the conduct of the Company’s business and how the public perceives such conduct. Unethical actions, or the appearance of unethical actions, are unacceptable.

Whilst Workers must comply with The Code, it does not cover every situation a Worker might face so it is important to use good judgement in everything we do.

If in doubt about a course of conduct, Workers should ask themselves:

Is this consistent with our Code of Conduct and expected standards of behaviour?
Could it endanger anyone’s safety or cause injury?
How does this sit with our culture?
How will it reflect on me and the Group?
Am I willing to be held accountable for this decision?

Any Worker in breach of our code may be subject to disciplinary action, including termination of employment or contract for services.

Living Our Culture

In line with our culture, Workers are required to:

Treat everyone with whom they deal with fairly, courteously and with respect
Perform their duties to the best of their ability
Ensure their personal interests do not conflict with their duty to TEG
Never unfairly discriminate against or bully a person
Never engage in improper or offensive behaviour
Comply with all laws and regulations applicable to any activity undertaken by members of the TEG Group
Perform work in a safe manner
Always work within TEG’s policies and rules
Never act in a way that would harm TEG’s reputation
Be considerate and respectful of the environment and others

The Working Environment

Human Rights and Ethical Behaviour

TEG respects all human rights and in conducting our business, we regard those rights relating to non-discrimination, fair treatment and respect for privacy to be the most relevant and to have the greatest potential impact on our people. We believe that every employee is entitled to a working environment which promotes dignity and respect to all.

Workers must not engage in discrimination, inhumane treatment or abuse of their workers. Our Leaders are to respect and provide a safe working environment for every person engaged in their operations. All Workers must adhere to Company policies that address discrimination, bullying, harassment (including sexual harassment), victimisation, abuse and any other unlawful conduct, or threats of any such treatment.

Diversity and Inclusion

TEG embraces the principles of diversity, inclusion and equality. At TEG a balanced workforce where everyone belongs, supported by processes and policies which advocate this is the heart of our strategy. We value diversity and understand that this drives a high-performance culture.

We expect our Workers to adopt practices and procedures that promote an inclusive and respectful environment across our workplaces. Our decisions are made without considering a person’s racial origin, age, disability, religion, culture, sexual orientation or gender identity. At TEG we treat each other fairly, equally and with respect. We do not tolerate inequality, unlawful discrimination, harassment or bullying. We also expect Workers to foster gender equality in their operations and avoid unconscious bias in recruitment or promotion of their Workers.

Health and Safety

TEG requires all Workers to Comply with applicable health and safety laws. Workers must comply with Company policies and procedures when performing their duties. Workers should question unsafe or improper operations and, if necessary, stop work to address them. Hazards and risk should be reported to HR in line with Company policy. Workers should report all injuries and safety incidents. Managers are required to provide Workers with information, instruction, training and supervision as is necessary to work safely and without risks to their health.

Modern Slavery

TEG has a zero-tolerance approach to modern slavery. We expect all our Workers to understand and where relevant identify, report and address the risks of modern slavery in their global and domestic operations and supply chains.

Conflicts of interest

Workers must always make business decisions based on what is best for TEG. A conflict of interest can arise when personal activities, interests or relationships (whether direct or indirect) are inconsistent with the interests of the Group. Conflicts of interests can take many forms. These include:

Accepting gifts and entertainment or other personal benefits
Holding employment or operating a business outside of the Group
Having a personal or business interest with persons involved in business dealings with the Group

Having a conflict of interest is not necessarily a breach of our Code of Conduct. However, failure to disclose a conflict and, where required, obtain consent, will be a breach of The Code.

Business Practices

Financial records

We must keep financial records and have appropriate controls in place to evidence the business reason for making payments to third parties and that all expenditures are properly authorised and accurately and transparently recorded. Employees must comply with the recording, reporting and approval requirements of our Delegation of Authority and Business Travel and Expense Policy. No entry may be made to records that distorts or disguises the true nature of any transaction.

Asking for Guidance and Speaking Up

At TEG all Workers have a responsibility to help prevent, detect and report unethical, unlawful or improper conduct.

If you need information or advice as to how our Code of Conduct or other polices work, you should ask for guidance from your Manager, Human Resources or the Legal team.

We also have a Whistleblowing Policy. The policy encourages the reporting of instances of unethical, unlawful or improper conduct.

We are committed to the process by which any concerns raised are reviewed in an impartial, fair and objective manner. Anyone who makes a report may do so without fear of reprisal, intimidation or disadvantage. False reports may damage the Group’s reputation and the reputation of people named in a report. Deliberately making a false report will be treated as a serious disciplinary matter.

Any Worker, who in good faith, raises a complaint or discloses an alleged breach of our code, whilst following correct reporting procedures, will not be disadvantaged or prejudiced. All reports will be dealt with in a timely and confidential manner.

Workers can report their concerns to the Senior Leadership Team or any of the people in the below positions:

Chief Financial Officer, TEG
Group General Manager, P&C, TEG
Group General Counsel, TEG
Head of Human Resources (APAC & USA)
Human Resources Manager (United Kingdom)

Or via email to Report@teg.com.au. Should a Worker wish to make an anonymous report, they might want to consider sending an email to this email address from a new email account created for the purpose of the report.