DOING THE RIGHT THING - Our Code of Conduct - Woolworths
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DOING THE
RIGHT THING
Our Code
of Conduct
Issued January 2016
Woolworths Limited
ABN 88 000 014 675
REVISED
2016
CONTENTS
It is our employees, doing the
right thing every day, by our
customers, our communities, About our Code of Conduct 5
HELP our suppliers and each other Our values 6
E THE
ENHANC ’S that make’s Woolworths Limited We do the right thing 7
Y
COMPAN N
Between the Flags 8
a great Company. We exist to
IO
REPUTAT
Social media 9
serve our customers in a way Appropriate Workplace Behaviour 10
We are what we wear 12
that is consistent with our
We love our customers 13
Values, particularly by Safety and health 14
“Doing the Right Thing” Staff discount card 16
Conflict of interest 17
How we do business 18
The Woolworths Limited Code
Gifts and gratuities 21
of Conduct has been developed Media and external stakeholders 22
to help all of us enhance the Political activities 23
Information systems access 24
Company’s reputation by Privacy and confidentiality 25
explaining how our legal, moral Woolworths Limited shares 26
and ethical standards can be Keeping accurate records 28
Company property 29
achieved every day through our Speak Up 30
behaviours and our choices. Your Code and Conflict
of Interest declaration 31
Our Code of Conduct is produced on
behalf of the Chief Executive Officer.
Our Code of Conduct is for
Published on 1 September 2003 and all employees, directors,
subsequently updated in November
2003, July 2004, November 2007, contractors and consultants
April 2008, June 2010, July 2014 and
January 2016. of the Woolworths Group.
If you have any questions or concerns
about any of the detail in this
It is everyone’s responsibility
booklet, please discuss with your
line manager or contact your Human to individually uphold the Code
of Conduct and to encourage
Resources representative.
The terms of this policy are not
intended to be contractual in
nature and do not form part of any
each other to do the same.
employee’s contract of employment.
2 3
E To help us
WELCOM At Woolworths we aim
to be Australia and achieve these
New Zealand’s most
trusted brand. This is a objectives, there
goal central to ensuring our
business can evolve and grow are three things
through this rapidly transforming era in retail.
To help us achieve this goal we need people
I ask of you:
who are passionate about retail, customers 1 READ IT
and doing the right thing. We are building a Please read our Code of Conduct and make sure
world class retail team to help us maximise you understand it. If there is anything you are
the opportunities on offer. Our behaviours unclear about, it is your responsibility to ask.
and actions at Woolworths are guided by
our Values. We must concentrate not only 2 AGREE TO IT
on achieving results but also on how we By reading and signing the declaration, you
get things done. This handbook explains acknowledge that you clearly understand and
your responsibilities as a representative of agree to abide by the rules and responsibilities
Woolworths and the common rules we have set out in our Code of Conduct.
about the way we behave at work.
3 FOLLOW IT
Woolworths is committed to: It is your responsibility to always work within
■ acting in the best interests of our customers, the rules, as described by our Code of Conduct.
shareholders and fellow colleagues; If you have any questions about any aspect
■ meeting the highest standards of behaviour of our Code of Conduct, please don’t hesitate
and appearance; to talk to your Manager or Human Resources
■ complying with the law and with representative.
company policies; Woolworths is a great place to work and
■ protecting company assets, information an even better place for our customers.
and reputation; Let’s keep it that way by always “Doing the
■ being respectful, friendly and safe; Right Thing”. Thank you for being a part of the
Woolworths team.
■ conducting business fairly, truthfully
and honestly.
ABOUT OUR
4
CODE OF CONDUCT 5
WE DO THE
WOOLWORTHS PEOPLE ARE SPECIAL BECAUSE...
OUR VALUES ACKNOWLEDGE WHERE WE HAVE COME FROM
RIGHT THING
AS WELL AS WHERE WE ARE GOING, AND UNITE US
AS ONE TEAM TO BE SUCCESSFUL TOGETHER
Doing the right thing is demonstrated by acting with integrity, honesty and trust at
all times - at work, when representing the Company and outside working hours.
Unacceptable conduct includes, but is not limited to:
■ possessing or consuming alcohol or illegal drugs during working hours;
■ working under the influence of illegal drugs or alcohol;
■using objectionable or obscene language towards customers or
employees of the Company;
■ making objectionable or obscene gestures to customers or employees;
■ behaving in a fraudulent and dishonest manner;
■ breaching the rule and spirit of the laws that govern the country and
Company in which we work;
■ falsifying Company documents;
■ misusing a WOW People Discount Card, One Card or Everyday
Rewards Card;
■ making unauthorised statements or providing unauthorised information
to media;
■ inappropriate use of Company information, systems or assets;
■ posting of inappropriate, false or malicious comments or materials online
regarding the Company, your workplace, your colleagues or customers.
This includes but is not limited to social networking sites, emails and
text messages.
Employees are required:
■ to behave in a manner which is consistent with the Woolworths Values,
whether that is in your usual workplace, when performing company
duties off site, on social media, when interacting with customers and
suppliers, on company business trips, or at company functions such as
Christmas parties
Failure to demonstrate honesty, integrity and trust may result in disciplinary action,
including termination of employment.
6 7
You must
ensure you:
SOCIAL
ATE
WE OPER N ■ carry out your duties in
‘BETWEE ’
good faith, always following
MEDIA
GS
THE FLA
relevant policies and
There are a procedures;
significant number
of compliance ■ complete the training
requirements that apply to applicable to your role and
our day to day activities at work, raise anything you don’t
the products we sell and the services
we provide. Meeting those compliance
understand with your
requirements is part of how we line manager; Just like our words and actions,
messages and graphics in electronic
do business.
■ do not engage in behaviour, form can be offensive to
Compliance requirements are many and or ignore behaviour by some people.
varied - but include such areas as Food others, which breaches
Ensure that you:
Safety, Fair Trading, Privacy, Workplace compliance requirements;
Health and Safety, Tobacco, Responsible ■ do not send racial, sexual,
Service of Alcohol and many more. ■ promptly raise issues defamatory, threatening or obscene
or suspected messages to any employee or anyone
We have adopted ‘Between the Flags’
breaches with outside the Company;
as our vision for compliance.
your manager
■ do not download, retrieve,
In Surf Lifesaving, flags are staked in and support send or store inappropriate, sexually
the sand at the beach to symbolise the their explicit or racist material on
boundaries within which it is ‘safe’ to
resolution. your computer or other Company
swim. People know where the boundaries
electronic device;
are, but they also know that there are
people there who will support them if ■ do not instigate or distribute
they get into trouble. Just like down at the ‘junk or chain’ mail that can congest
beach, you can always put your hand up the network and inhibit the free flow
for help when you are ‘Between the Flags’. of business information.
If you lead a team we expect you
Failure to comply may result in
to lead by example, demonstrating a
disciplinary action, including
strong commitment to compliance.
termination of employment.
Need more information?
Need more information?
See the Compliance Policy.
See the Social Media Guidelines
8 9
Bullying does not include
reasonable management action taken Employees
are expected:
in a reasonable way, such as;
RIATE
APPROP CE
■ informing a team member about
A
unsatisfactory work performance including
WORKPL R At Woolworths, undertaking performance management ■ raise the matter with your
to
U
BEHAVIO
■ setting reasonable performance goals,
Doing the Right Line Manager if you believe
Thing, means we are standards and deadlines
you are experiencing unlawful
all responsible to foster ■ reasonable directions by management
discrimination, harassment
a working environment Unlawful discrimination is the less
where everyone is treated with
or bullying. If you are unable
favourable treatment of a person or group
dignity, courtesy and respect. This includes of people based on particular attributes. to do so, you can also speak
not engaging in conduct or behaviour Some examples include: to your Human Resources
which is bullying, harassment or unlawful
■ sex, intersex status, marital or relationship Representative.
discrimination in the workplace.
status, pregnancy, breastfeeding, parental
Team members should be aware that conduct
■ to victimise or otherwise
not
status or carers’ or family responsibilities
that is found to be bullying, harassment disadvantage anyone as a
■ sexual preference, sexual orientation,
or discrimination could be a breach of the gender identity, lawful sexual activity or result of making a complaint.
relevant legislation and therefore illegal. transexuality ■ act honestly when
to
Some examples of harassing ■ race, colour, descent, nationality, national
raising a complaint and if
behaviours include; origin, ethnicity or religion
you become involved in an
displaying offensive material (including ■ disability or impairment, and/or age
■
investigation, you are required
electronic format) Examples may include, but are
not limited to:
to keep anything discussed
■ unwelcome physical contact such as
shoulder massaging and invading an confidential.
■ exclusion from work-related or social
individual’s personal space activities
■ offensive or demeaning statements, jokes, ■ limiting access to recruitment and selection
comments or innuendo for opportunities, promotion, transfer, training
■ unwelcome remarks or insinuations about and other employment benefits
a person’s appearance, sexual activities or ■ harassment or bullying or vilification
private life
Always be aware of your behaviour
Some examples of bullying as harassment, bullying and discrimination
behaviours include; can be carried out in a number of ways
■ abusive, insulting or offensive language or including verbally, in writing, through email,
comments text messaging, instant messaging, being
■ spreading misinformation or malicious published on the internet, videos or other
rumours social media channels.
■ behaviour that belittles and/or humiliates Failure to comply with these obligations
■ unreasonable exclusion from workplace may result in disciplinary action, including
activities termination of employment.
Need more information?
See the Appropriate Workplace
Behaviour Policy
10 11
WE LOVE
WEAREWHAT OUR
ERS
WEWEAR
CUSTOM
At Woolworths
Limited, we are
You can committed to
delivering the best
demonstrate possible shopping
experience for our customers.
You are expected to dress appropriately
during work hours or when representing the
“loving our Every decision and action we make
every day has an impact. Whether we
Company. This means presenting yourself in
a professional, business appropriate style at
customers” are serving a customer in our stores,
or making a decision about what
all times. In addition you must ensure that
your attire does not present a safety issue
by ensuring: product to buy, our customers must
always be our first consideration.
and is in line with your divisional dress
standard requirements.
■ you understand what “We love our customers” is one of
our customers want; the Woolworths Values and shows our
This includes: commitment to ensuring that every
■ wearing the preferred dress or professional
■ you spend time directly shopping experience is a positive one.
business attire; with them; Part of our approach for success is to
■ wearing appropriate protective or safety ■ you know the customer make a lasting, positive impression
on our customers every time we have
clothing when required; benefit of every action an opportunity to interact with them.
■ being clean, tidy and maintaining personal we take; The way we behave and serve our
hygiene and grooming; customers show how we feel about
■ you are friendly,
wearing a name badge or identity cards them and our Company.
■
when on Company premises;
responsive and
respectful at
wearing only Company authorised logos,
■
all times.
promotional garments or accessories e.g. caps;
■ jewellery should be kept to an acceptable
level reflecting business standards;
■ in some instances there are additional
department requirements relating to the
wearing of jewellery e.g. when working in a
Fresh Food Department;
■ no visible body piercing including tongue
piercing (other than earrings).
You also need to ensure that personal
electronic devices are not used in customer
facing environments, except when it is for the
benefit of our customers. Personal electronic
devices includes, but is not limited to, mobile
phones, smart phones and ipod’s. You are
not to use personal electronic devices when
undertaking activities that may harm yourself
or customers.
12 13
My personal
commitment
to safety:
AND
SAFETY
■ I will look out for my safety
DESTINATION HEALTH
ZERO
and the safety of others; The journey to achieve
and sustain world-class
■ I will immediately stop safety performance has no
any job or task that I believe end point.
is unsafe;
At Woolworths, our commitment is ongoing
■ I will always address any and we aim to prevent all incidents.
hazards when I become The safety, health and welfare of employees,
aware of them; contractors, customers, suppliers and
Woolworths Limited invites you on a members of the wider community is of
■ I will adhere to the journey – and the Destination is ZERO. prime importance to the Woolworths Limited
Company’s safety rules; This means ZERO harm to people, the business. We strive to create a culture where
environment and the community. all employees believe it is essential to work
■ I will not use equipment safely for themselves and each other.
that I am not trained or To achieve this vision, Woolworths
authorised to use; Limited encourages you to: We believe that:
■ every injury can be prevented;
■ I will always wear Personal ■ make safety personal and ask
every incident is an opportunity to prevent
“what can I do to help”?; ■
Protective Equipment (PPE) a reoccurrence;
required for the task; ■ know no task is so urgent and no ■ every injury is a result of a behaviour;
service is so important that we cannot
■ I will report all incidents and take time to do it safely;
■ Destination ZERO is achievable.
injuries immediately.
It is everyone’s responsibility to ensure that
■ be responsible for your own safety
you comply with Safety and Health policies
and health and that of co-workers,
and processes at all times to protect your
contractors, visitors and customers;
health and that of others, including our
■ be mindful of the environmental customers, from potential hazards.
impact of our activities and choices;
If you see an unsafe act, you are responsible
■ recognise and promote excellence for identifying and reporting the hazard to
in safety, health and environmental minimise any potential risk. If you are in
performance. doubt about safety issues you should speak to
your line manager for assistance or follow the
Safety and Health Issue Resolution process.
Need more information?
See the Safety and Health Policy.
14 15
T OF You should
CONFLIC T
INTERES disclose
All employees of Woolworths
WOW PEOPLE
Limited are expected to declare
any interest they might have
any dealings
DISCOUNT CARD
that could adversely affect
the Company. In some cases our
individual interests may put us in that may
WOW People Discount
Card obligations.
direct conflict with those of the Company and this
could cause unnecessary embarrassment for us or for
mean you:
the Company’s reputation in the marketplace.
■ The WOW People
Woolworths Limited expects that any direct ■ do business with or are
Discount Card is for
working relationship between family [included but employed by a Company
personal/household use
only and not for goods
not limited to, parent, siblings, spouses or partners] that is a competitor of
be declared. It is important to ensure that no one puts
for resale. Woolworths Limited;
themselves into a position where a potential conflict
The card is only for use of interest or opportunity for collusion may arise
■
by the person whose name and if you find yourself in this situation ensure you ■ do business with
appears on the card. declare it immediately to your Line Manager or companies in which
HR representative. Woolworths Limited or
■ Cardholders may Over time personal situations may change and
be asked to present
its employees’ families
employees who believe they are in a situation that
identification upon request may be a potential conflict with Woolworths Limited
have major interests;
at the Point of Sale. are required to advise their line manager and
complete a new Conflict of Interest Form. ■ do business with a
■ WOW People
Discount Cards will be If you are concerned about your own situation it supplier because they
confiscated at the Point is recommended you talk to your line have given us a gift
manager so the issue can be clarified
of Sale if presented by an or benefit;
unauthorised person. and resolved. Failure to disclose or
resolve a conflict of interest is a
■ Employees leaving serious issue. ■ seek to run for, or, hold
the Company must return a public office that may
their card as well as any impact the Company;
subsidiary holder’s card to
their line manager on their
last day of work.
■ work for a competitor
while being employed
Failure to comply with by Woolworths Limited
these obligations may
result in disciplinary action,
or its subsidiaries;
including termination of
employment. ■ have an immediate
family member employed
Need more information?
See the WOW People by a direct competitor in
Discount Card Policy. a senior role.
16 17
HOW WE
DO
BUSINES
S At Woolworths Limited we retail
BUYING It
is up
to you:
RESPONSIBLY
a wide range of products and
services through our operations in
Australia, New Zealand, China,
Hong Kong and Bangladesh. When we buy for our ■ to commit to complying
We are committed to acting fairly and Company it must be done
fairly and responsibly. with the laws governing
honestly in all dealings with suppliers, customers and
the community. You are expected to uphold and support Our suppliers and trade competition;
this commitment. partners are key to our
It is your responsibility to commit to complying ongoing success and we must ■ to treat our customers
with the laws governing competition by: treat them with respect. fairly and with respect;
■ ensuring we trade independently of our competitors, Employees that are involved
by not discussing, agreeing or reaching understandings in buying goods, including ■ to treat product safety
with our competitors about our activities; non inventory items and
services for Woolworths as paramount.
■ ensuring we price our products and services to provide
Limited, need to do business
a compelling offer to our customers in the spirit of sound
fairly and ethically with
competitive behaviour.
suppliers by:
It is your responsibility to treat our customers
■ obtaining the best value
fairly and with respect by:
for money from all trade
■ valuing their feedback; arrangements but never
■ ensuring our marketing and promotional information at the expense of acting
as well as our product packaging and labelling is clear, ethically;
truthful and always carefully checked; ■ never accepting or
■ addressing our customers’ concerns regarding products demanding any form of
that are faulty, unfit or mislabelled inducement or bribe in return
It is your responsibility to treat product safety as for business;
paramount by: ■ never placing undue
■ ensuring the products we supply are safe and meet pressure upon our suppliers;
regulatory requirements, including safety warnings ■ never trying to influence
and labelling; competitor pricing or deals
■ taking accountability for your part in the delivery and offered by suppliers to our
quality of products; competitors;
■ treating product recalls as a priority by being thorough ■ never being influenced
in preventing their sale and informing our customers of by our suppliers to fix our
the recall. retail prices;
We regard any failure by our employees to comply ■ regularly reviewing our
with our Policies regarding how we do business as trade partners’ contractual
extremely serious. arrangements;
Need more information? ■ ensuring that our buying
See the Compliance Policy, Fair Trading Principles, Fraud and procurement processes
and Anti Bribery Policy, Environmental Claims Policy and are transparent and in
the Quality Assurance Methodology and Principles. line with our Fair Trading
Principles.
18 19D
GIFTS AN
You must IES
GRATUIT
Woolworths Limited is
WHAT
committed to ensuring all
ensure that: business relationships with
suppliers are legal and based
on professional integrity.
■ if you receive a gift or As a matter of Company principle we do not
invitation you should declare receive gifts and gratuities. We understand,
SHOULD
it immediately to your line however, that small tokens of goodwill may be
manager; exchanged between us and our suppliers on
special occasions, such as Christmas, and that
from time to time you may be offered an invitation
I DO IF I
■ you inform any current or
to a social, sporting or cultural event because of
potential suppliers with the job that you do. Gifts such as these can be
whom you work, that it is accepted provided they do not exceed A$100/
a condition of our business NZ$100 in value or result in personal gain for the
relationship that we only
GET OFFERED
recipient, or favourable treatment for the giver
accept and give modest if they are someone from whom we buy, sell or
A GIFT
receive goods and services.
and discreet gifts when
appropriate. Suppliers should also be informed that we do
not believe in supplier paid lunches during
Failure to do so is a working hours.
serious matter
Accepting some types of gifts and gratuities like
bribes, inducements, special personal discounts
Ensure the intention of the gift or merchandise, however small, could embarrass
is in keeping with the Company an employee, the supplier, and compromise
policy on Gifts and Gratuities: Woolworths Limited. In some cases these gifts
could be interpreted as fraud and be illegal.
■ if it is under A$100/NZ$100 in
value, advise your line manager The Company has an obligation to fully cooperate
and record it in your departments with any investigation by law enforcement or
Gift Register; regulatory authorities in cases where employees
knowingly accept a gift that has been interpreted
■ if it exceeds A$100/NZ$100 as a bribe. If you are unclear about what is
in value, you need to seek prior acceptable behaviour in relation to gifts and
approval from your General gratuities you should talk to your line manager.
Manager before you accept it.
Need more information?
See the Gifts, Gratuities and Entertainment Policy.
20 21ND
MEDIA A To ensure that you do
L
EXTERNA RS not inadvertently risk the
LDE
STAKEHO As a large
and highly
Company’s reputation,
visible Company it is important that you
in Australia and
New Zealand, Woolworths do not:
Limited is often closely watched
by media, politicians, industry ■ make statements or provide
POLITICAL
associations, community groups information to media;
and regulators.
■ provide information to politicians
ACTIVITIES
The way in which we conduct or government officials;
ourselves at work and the decisions
we make can have a direct impact ■ post inappropriate, false or
on the Company’s reputation. malicious comments or materials Woolworths Limited respects
Our aim is to always ensure that our online regarding the Company, the rights of its employees
impact is a positive one, rather than
a negative one. It is therefore your
your workplace and/or your to participate in the political
process but is mindful of any
responsibility to behave in a manner colleagues;
potential conflicts of interest.
that represents Woolworths Limited
■ reference the Company negatively It is important for us all to
as a good corporate citizen. know that the Company is not
in any online social medium or
allowed to offer or give gifts,
After all, a good reputation is very public forum.
loans, rewards or favours to
hard to earn but very easy to damage.
any government official or
We strive to have a positive government employee with a
relationship with all our stakeholders view to favourable treatment
and to help them to better understand in return. You are expected to
retailing and how our businesses respect the Company’s stance
operate. To ensure we communicate on this issue particularly in
most effectively to our stakeholders, cases where you work with
it is important that stakeholder local or overseas government
enquiries are dealt with quickly representatives.
and appropriately. If you have any concerns or
questions you should contact
Failure to follow these guidelines
the Director – Corporate and
may result in disciplinary action,
Public Affairs.
including termination of employment.
Need more information?
See the Social Media Guidelines
22 23INFORMATION To ensure Woolworths Limited aims to ensure you have the necessary
information to perform your job. This means that during the
we remain normal run of business you may be trusted with
SYSTEMS ACCESS
documents and information that belongs to:
competitive in ■ t he Company;
the marketplace
AND
Anyone who requires access to our employees;
PRIVACY LITY
■
Woolworths Limited Information
you must not: our customers;
NTIA
■
CONFIDE
Systems is required to sign a ■ our suppliers; or
declaration accepting the terms
■ our shareholders.
and conditions of the Acceptable
■ share any company
Use of Information Systems Policy. Personal information
information to which
Under privacy laws, Woolworths Limited has
Anyone with access to the you have access, with a number of obligations concerning personal
Woolworths Limited Information any person who is information it collects from individuals, such as our customers.
Systems should be aware that:
not authorised to These laws cover disclosures Woolworths Limited must make to
users are provided with
■
see that information. our customers when it collects their personal information, how
unique accounts (IDs) and it may use that information (including restrictions on sharing it
passwords which must not be
This applies both
with others), what Woolworths Limited must do to protect the
shared with others; during your
information and when it must delete or de-identify it.
■ legally any information stored, employment and
Suppliers
received, communicated or sent on after you leave
Usually when Woolworths Limited receives information from
information systems is owned by Woolworths Limited. another party such as a supplier, it has agreed to keep that
the Company;
information confidential. This means you must:
■ material stored, received,
■ o nly use the information for the reason it was given to
communicated or sent on the
Woolworths Limited;
Company’s system including email,
■ only share it with other employees on a need-to-know
internet and intranet may be
basis;
monitored.
■ not share it with someone else without the owner’s
Simple rules for internet
and email: permission.
Customers
■ if in doubt, don’t!;
Woolworths also places great importance on protecting our
■ do not download customers’ credit card information.
inappropriate material;
Company information
■ do not send, forward Company information is equally sensitive as it often includes
or save inappropriate
detail about operations, Company strategy and finances.
information;
Depending on your job, you may come across this during
■ be aware our system is training, a conversation, in documents or on your computer.
monitored;
Employees who, as part of their job, have access to sensitive
■ the system and information or confidential Company information on computer must be
is owned by Woolworths familiar with their obligations as set out in the Woolworths
Limited. Limited Acceptable Use of Information Systems Policy.
Failure to comply may result in Sharing Company information without permission
disciplinary action, including is a very serious issue and may result in termination of
termination of employment. employment. This extends to sharing confidential
Need more information? information regarding our employees. If you are unclear
See the Acceptable Use of about what this means for you, you should speak to your
Information Systems Policy. line manager.
24 25WHAT IS
RTHS
WOOLWO You are
LIMITED
During your employment,
SECURIT
IES
you may be given
not allowed:
INSIDE
the opportunity to
share in the Company’s
growth through various ■ use “inside
to
Woolworths Limited Employee
Plans, as well as buying Company information” to trade
Securities in your own right. Being a Company in Securities if the
information you know
INFORMATION?
shareholder brings a responsibility to comply
with the laws governing companies and
may generally effect
employees who own Securities, including
insider trading laws and the Company’s the price or value of
Securities Trading Policy as amended from Inside information is any information those Securities.
time to time. In practical terms, importantly, known by an employee that is not
you need to be aware that, at certain times generally available and that, if it were
generally available, a reasonable person
■ trade during
to
of the year, you must not trade securities.
These times are call “Blackout Periods would expect it to have a material effect Blackout Periods.
on the price or value of Woolworths
The insider trading laws do not allow anyone
Limited Securities or the securities of
with “inside information” to:
any other company. In simple terms, this
■ trade in (i.e. apply for, buy or sell or agree means information which might influence
to apply for, buy or sell) the Company’s someone to decide whether or not to buy
Securities or influence another person to trade or sell Securities.
in the Company’s Securities; or
A reasonable person would
■ communicate the “inside information” to
expect information to have a ‘material
another person who may trade in Woolworths
effect’ on the price or value of Securities
Limited Securities.
if the information would, or would
You are not allowed to use “inside be likely to, influence someone when
information” to trade in Securities in other deciding whether or not to buy or sell
companies if the information you know may those Securities.
generally effect the price or value of those
Examples of information that might be
Securities.
inside information include information
These prohibitions apply to a person’s conduct relating to:
anywhere in the world, not just in Australia.
Other countries also have similar laws. ■ financial performance;
These prohibitions also apply to anything ■ a material acquisition or disposal of
you do on your own behalf or on behalf of assets, a takeover or merger;
another person. These prohibitions cannot be ■ an actual or proposed takeover or
avoided by another person doing things on merger;
your behalf. ■ an actual or proposed, new share
If you are uncertain about what owning the issue or change to capital structure;
Company’s Securities means for you, seek ■ the entry into or termination of a
independent advice or contact the material contract;
Chief Legal Officer or Company Secretary. ■ a material claim or other unexpected
Need more information? liability; or
The Securities Trading Policy is available on ■ a significant change in senior
the company’s website. management.
26 27It is your Y
COMPAN
responsibility to: KEEPING In your role you may be given
PROPERT
Y
ACCURATE
access to assets that belong to the
■ protect and care for
Company such as:
Company assets. We all
RECORDS
cash;
need to ensure that our ■
■ plant and equipment, including motor vehicles;
actions in relation to
■ stock and merchandise;
Company property are ■ Company information;
honest at all times. ■ computers and software, including passwords.
To keep control of our
business affairs it is important You should remember to always:
that we operate within the ■ seek permission from a senior manager to take
relevant legislation and Company property from the workplace and ensure its
generally accepted accounting removal is documented;
principles. ■ always use Company property and business tools
for their intended business use and not for personal
This means:
use unless authorised;
■ we need to keep our books ■ ensure every sale is processed through the point of
and records with accuracy; sale in the correct way;
■ never assume that damaged or expired stock is not
■ all of our financial wanted or valuable to the Company;
transactions and funds need ■ return all Company property, for employees leaving
to be recorded truthfully the Company, including documents held in hard and
and supported by proper soft copy.
paperwork so they can be
If you believe that theft or damage is taking place in
audited reliably and reported
your workplace you should report it immediately to
honestly;
your line manager or a loss prevention representative
■ no employee should in your area. Theft or wilfully damaging Company
deliberately keep or help property is a criminal offence.
another employee to keep Woolworths Limited sites use Closed Circuit Television
records that intentionally (CCTV) video surveillance equipment.
mislead or hide the true nature This equipment is required to protect staff and
of a transaction; customers and to ensure their safety and security as
well as the security of the site. Surveillance is used
■ all funds and bank accounts
in an ethical manner and is not installed in bathroom
need to be reflected in the
areas, change rooms or locker rooms located within
Company books and no off
the workplace. The video cameras are clearly visible
book transactions are allowed.
and signs are displayed at sites notifying of the
We are open and honest surveillance. On rare occasions additional surveillance
and will disclose relevant may be introduced for the purpose of supporting
information to authorities an investigation.
when required Where such actions are taken, we are committed
to carrying out these operations in accordance
with the relevant legislation.
28 29“SPEAK UP” DE
YOUR CO CT
FLI
AND CON ION
DECLARA
T
“DOING THE RIGHT THING”is demonstrated by acting with
As an employee of I understand that failure to comply with the
the Woolworths Limited Code or to disclose a Conflict of Interest is a
integrity, honesty and trust at all times it is important when you Group (“Woolworths Limited”), serious matter and may result in disciplinary
see something that is not right, you Speak Up. I acknowledge that I have read and understood action including termination
my obligations to Woolworths Limited as of employment
In the first instance, employees are expected to raise matters with their Line Manager. detailed in the Policies and Procedures outlined
Line Managers are expected to treat the concern with the utmost seriousness and address the in our Code of Conduct (“Code”).
matters raised. Employee name
In the day-to-day performance of my job I will:
This escalation process is generally referred to as a Complaint Guideline or Grievance Procedure. ■ always act with integrity to the highest
These are long-standing and accepted procedures for raising concerns in respect to the standard; Payroll No. or ID
Woolworths Code of Conduct. ■ comply with the Code;
If you are unable to escalate a serious issue through the normal processes, or you have strong ■ adopt any new or changed Policy and seek
Division/Region
reason to believe that a reported issue has not been investigated, you may access Speak Up. clarification if I do not understand how it may
affect me;
Examples of concerns that should be raised to Speak Up are;
■ abide by ‘’My personal commitment Employee signature
■ Imminent risk to the health and safety of a person to safety’’.
■ Suspected fraud I declare and agree that:
■ Corruption ■ I am not in a Conflict of Interest situation Date
affecting Woolworths Limited as described in
■ Illegal activity our Code of Conduct;
■ I will not knowingly become involved in
Employees should understand, the Speak Up service is not designed for the
purpose of resolving interpersonal disagreements. a Conflict of Interest unless I have the prior For office use only
written approval of the CEO or his designate; Payroll code = WLCOC5
CONTACT SPEAK UP - 24/7
■ if I become aware of a Conflict of Interest, Please return your signed declaration to your;
I will: ■ Cashier/Pay office - EBA/Award employees
Telephone: Australia – 1800 334 319 New Zealand – 0800 393 76736 i a dvise my HR Representative that my ■ Remuneration Officer - Salaried employees
Website: www.speakup.deloittedigital.com User name: Woolworths Password: SpeakUp10# circumstances have changed;
Email: speakup@deloittedigital.com ii seek clarification as to the steps I must
Fax: +61 3 9691 8182 take arising from the Conflict of Interest.
Post: Speak Up, Reply Paid 12628, A’Beckett Street, Melbourne VIC 8006
Speak Up is an independent service run by a third party that gives you an opportunity to report matters anonymously.
The Company is committed to investigating all raised matters where there is sufficient information to warrant an investigation.
EMPLOYEES WHO HAVE ACCESS TO SUCCESS FACTORS
Please Note: For employees on the Success Factors Payroll System, you are required to accept the
Code and Conflict Declaration through Success Factors.
30 31You can also read
