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Code of Conduct

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Effective Date 31 March 2017

Policy Owner Human Resources

Applies To All Anzchem Employees

Purpose and Aims
ANZCHEM Pty Ltd, (the Company, we, our, us) is committed to achieving the highest standards of ethical conduct in all aspects of our business. All the Company employees, officers and directors must display exemplary standards in relation to professional business conduct as well as complying with the law. High standards of conduct will serve to enhance our reputation for fair and responsible trading, as a good employer, and encourage appropriate behaviour across the business. We believe that these behaviours build trust between our people and clients, enhance our reputation and ensure our continued prosperity.
This Code of Conduct (Code) articulates the principles which guide the conduct of the Company business and reflect our commitment to integrity and honesty, legal compliance, the community and environment, fair dealing, accountability, open communication and diversity in our workplaces. If you work at the Company in any capacity, including employees, potential employees and contractors, whether on a full-time, part-time or casual basis, on or off-site, or if you are a customer or visitor attending our workplace or an event we have organised (you, person, people), then this Code applies to you and you must familiarise yourself with, and comply with, this Code and any variations to this Code. Please note specifying anything after the word including does not limit what else is included.
This Code is a Company policy and may be reviewed, varied, added to or withdrawn by the Company at any time, at our absolute discretion. This Code, and any amendments to it, does not form part of your employment contract or agreement or any independent contractor agreement (as the case may be).

The Company will make this Code available through the People Portal or displayed at site in accordance with applicable industrial agreements.

Be Ethical and Honest
All of our affairs must be conducted and seen to be conducted in an ethical and honest manner. This means that our people are expected to act with honesty and integrity in all the Company business dealings. Lack of integrity and honesty impacts morale of our people, damages our reputation and may constitute a criminal offence.

Our people are expected to take reasonable care to meet business commitments which are made, to follow standard business practices, to respect others, to adhere fully to their own values and the Company values in the performance of work and to be accurate and truthful in dealings with third parties. Unethical and dishonest behaviour may be regarded as serious misconduct and may result in dismissal.

Comply with all Laws and the Company Policies
Our people must comply strictly with:
• all laws, licences, rules and regulations which apply to the conduct of our business across all jurisdictions, including competition laws;
• all the Company policies, including this Code, the Workplace Behaviour Policy, Health & Safety Policy, human Resources, Group, Finance and Management policies; and
• All relevant policies of our parent company, Associated British Foods (ABF), including the Red Book and ABF Anti-Bribery Policy.
It is the responsibility of all our people to ensure to that they have sufficient knowledge about the laws, licences, rules and regulations which affect the performance of their duties for and operation of the business at the Company and that they are familiar with and comply with all the Company policies as well as relevant policies of ABF.
Advice may be sought from managers, H.R. specialists, Group Legal or other appropriate personnel as required, and copies of all policies which apply to our people are available on the SharePoint Portal or with the site H.R. Manager. Failure to comply with laws and/or policies may result in disciplinary action. Please refer to the SharePoint Portal or your H.R. Partner for a listing of the Company policies and ABF policies which our people and contractors are required to be familiar with and comply with in working for us.

Be a Good Corporate Citizen
The Company is committed to being a good corporate citizen. We strive to achieve the high standards expected of companies in the countries in which we operate. Every person is encouraged to become involved in the Company charity work and to be involved in the community. the Company has a commitment to the protection of the environment and our people are called to challenge practices that they believe may be environmentally irresponsible.

Avoid Conflicts of Interest
Our people must not place themselves in a position which may lead to a conflict, or perceived conflict of interest, between their personal interests and those of our business. A conflict of interest exists if a person is involved in other employment, businesses or external activities that interfere with, or impact on, their ability to satisfactorily perform their duties for the Company. All our people should ensure that their activities do not conflict with or reflect adversely on our interests, deprive us of legitimate work time, or compete with our businesses.

All persons must notify the Company of any commitment to another employer, business or external activity which may lead to a conflict, or results in a conflict. A serious conflict of interest which cannot be satisfactorily resolved may result in termination of employment.

Refuse Improper Gifts and Hospitality
The Company recognises that there may be situations in which it may be appropriate to accept modest gifts or business hospitality out of courtesy and to build relationships with our clients and business associates. However, the Company is committed to fair and honest conduct of business and our people must refuse, and must not provide to any other party, any gifts or hospitality which would be inconsistent with standard business practices, be construed as improper or corrupt, or violate any law, regulation, rule, the Company or ABF policy. Our people should all refer to, familiarise themselves with, and comply with the Anti-Bribery & Corruption Policy, which provides further detail on this issue.

Use the Company Resources and Property Responsibly
Our people are to use and operate the Company resources and property in a proper and efficient manner and are to protect the Company resources and property from loss, damage, misuse, theft, embezzlement and inappropriate destruction at all times.
Our people are not permitted to use any the Company resources or property, including computer equipment, telephones, facsimiles and the email system for any non-the Company activity (other than an incidental and minor personal purpose) whether in or outside of work time, unless prior approval for the use of that resource or property has been given by that person’s line manager.
An incidental and minor personal purpose is a personal purpose which does not:
• substantially impact on the person’s performance of their duties to the Company;
• give rise to personal gain to the person; or
• constitute a use that would otherwise violate other the Company policies including those in respect of employee time, commitments to work and use of equipment.

Keep the Company’s Information Confidential
All information pertaining to the Company may only be used in the performance of duties to the Company and it is prudent to assume that all such information is confidential (including information about the Company’s business and financial affairs, employees, intellectual property, its competitors, customers, employees, products and services). The improper handling of confidential information may constitute a breach of law or a the Company policy.

Respect the Privacy of Individuals
The Company respects the privacy of individuals whose personal information it holds, and complies with the National Privacy Principles. It is essential that all persons who handle personal information are familiar with and comply with the General Privacy Policy and People Privacy Policy, and privacy procedures as relevant to their duties.

Cultivate Safe, Healthy and Diverse Workplaces
The Company is committed to providing our people with equal access to opportunities and, as far as reasonably practicable, healthy and safe workplaces. Our people should be familiar with and comply with the Company’s policies, including the Workplace Behaviour Policy and the Health & Safety Policy. A measure of our success in this area is that the Company businesses look to be as diverse and representative of the communities in which they operate.

Your Responsibility to Report Breaches of this Code of Conduct
If you believe there is an actual or suspected breach of this Code occurring, it is your obligation to bring it to the attention of one of those listed below. All reports will be treated seriously and confidentially within the Group, except to the extent the Company may have to disclose information to a regulatory body, as required by law or to allow for a proper investigation or disciplinary process. You will not be victimised or treated unfairly for making a complaint provided it is made in good faith. However, complaints that are vexatious or malicious may result in disciplinary action against the complainant.

Ways to Raise a Concern
Tell your line manager/head of department/Human Resource Partner There is no special procedure for doing this – you can tell him/her about the problem or put it in writing if you Notify the Chief Financial Officer, of our Parent Company, SPI Pharma.
If you have reasonable grounds for believing that the CEO or Directors of the Company may be involved or condoning behaviour in breach of this Policy you should report it to the Company Secretary of ABF – contact Rosalyn Schofield on + 44 20 7299 3641 or rosalyn.schofield@abfoods.com

Consequences of breaching this Code of Conduct
We retain discretion to commence disciplinary action for breaches of this Code. Disciplinary action may include a written warning, counselling, suspension or the termination of a person’s employment or engagement. We may also refer a breach of this Code to law enforcement authorities where necessary.

Related documents
• ABF Red Book
• General Privacy Policy
• Employee Privacy Policy
• Anti-Bribery & Corruption Policy
• Supplier Code of Conduct