Our Code Of Ethics

What is a "Code of Ethics"?

A Code of Ethics is designed to set out clear expectations for the Directors and employees of an organisation in order that the organisation observes and fosters high ethical standards.

Who establishes the Code of Ethics?

The Code of Ethics has been developed by the Directors of the Company. As circumstances change within the Company it will be necessary to expand or update the Code of Ethics to ensure that the Code remains relevant.

Adherence to the Code of Ethics?

The mere existence of a Code of Ethics will not create ethical and responsible practices, it is merely a guide of expected behaviours and sets standards against which behaviours can be judged. A Code of Ethics is ineffective unless directors and employees adhere to it. The Directors will be responsible for overseeing the implementation of the Code of Ethics and for monitoring compliance with the Code. A Code of Ethics will not be effective unless there are consequences for employees who breach the Code.

Complaint Procedures

The Company encourages any director or employee who considers that there has been a breach of this Code of Ethics to make a complaint in the first instance to either the Chairperson of the Audit and Risk Committee or the CEO who will then forward the complaint to the Audit and Risk Committee for investigation. The Audit and Risk Committee will report its findings to the Directors who will determine appropriate actions having taken into account the relevant information.

Complainants using this procedure expressly authorise the Company to disclose to the Audit and Risk Committee such personal information as is necessary to respond to the complaint. Such information will be held safe by the Audit and Risk Committee, CEO and the Directors and will not be disclosed to persons other than the parties to the complaint.

NB: These complaint procedures are further complemented by the Financial Services Federation (FSF) Code of Conduct.

Code of Ethics

1.1 Each employee must discharge his/her duties honestly and in good faith in what he/she believes to be in the best interests of the Company;

1.2 Each employee must use the Company assets entrusted to him/her only for a proper purpose and in the best interests of the Company;

1.3 Each employee must not make improper use of information gained through his/her position with the Company;

1.4 Each employee will keep confidential all information gained as a result of his/her position and, except where permitted by law or by the Company, will not disclose information to other people or organisations;

1.5 Each employee must act with the care, diligence and skill expected of a director or employee of a company and must demonstrate commercial reasonableness in his/her decisions;

1.6 Each employee has an obligation, at all times, to comply with the spirit as well as the letter of the law, to comply with the Constitution of the Company and exhibit a high standard of ethical behaviour.

1.7 An employee should not engage in conduct likely to bring discredit to the Company;

1.8 An employee must not allow personal interests, or the interest of any associated person to conflict with the interests of the Company;

1.9 Each employee will at all times be fair, reasonable and honest in the conduct of their business with customers, clients and employees of the Company;

1.10 With the exception of company approved initiatives, each employee will not give or receive gifts, inducements, a gratuity, facilitation payments or bribes that would compromise their decision making and obligation to the Company;

1.11 Each employee will strictly adhere to the terms and conditions of their Employment Agreement;

1.12 Employees are expected to comply with this Code of Ethics at all times. The Complaits Committee will review compliance with the Code on an ongoing basis and will report to the Board on an annual basis;

1.13 An employee will report any instances of unethical decision making and/or behaviour;

1.14 An employee who holds a professional membership (i.e. – NZ Law Society, Institute of Chartered Accountants) should observe the relevant professional code of ethics to the extent that these do not conflict with their employment obligations to the Company; and

1.15 Failure to comply with this Code as written may constitute "serious misconduct" in terms of an employee's Employment Agreement.