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Cbus Code of Conduct May 2019

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Page 1: Cbus Code of Conduct...Cbus Code of Conduct | 3 Cbus was established in 1984 as the national industry super fund for Australians working in the construction, building and allied industries

Cbus Code of ConductMay 2019

Page 2: Cbus Code of Conduct...Cbus Code of Conduct | 3 Cbus was established in 1984 as the national industry super fund for Australians working in the construction, building and allied industries

Contents

Message from the CEO 3

Purpose of the Code 4

Culture and values 5

Compliance with regulatory and governance obligations

8

Personal and professional conduct 11

Dealing with external parties 16

Use of Cbus resources 19

Escalation and consequences 21

Where to get help 23

2 | Cbus Code of Conduct

Page 3: Cbus Code of Conduct...Cbus Code of Conduct | 3 Cbus was established in 1984 as the national industry super fund for Australians working in the construction, building and allied industries

Cbus Code of Conduct | 3

Cbus was established in 1984 as the national industry super fund for Australians working in the construction, building and allied industries. I am proud to be leading the superannuation fund that is helping to build our nation.

As an industry superannuation fund, our sole purpose is to serve our members to achieve good retirement outcomes. To achieve this goal, our everyday actions and decisions matter.

At Cbus, our culture is important for our success. Our culture is influenced by our values, which determines how we work at Cbus. Our five core values are: focus on members, acting with integrity and respect, seeking new ideas and innovative solutions to continuously improve, taking accountability for our own performance and as a team and collaborating to achieve a better outcome.

The Code of Conduct Policy (Code) brings our values and key policies to life by articulating the expected standards of behaviour for our staff and contractors.

By aligning our actions to the Code, we are able to do the right thing in line with both community expectations and the laws.

If you believe the behaviour of anyone at Cbus does not meet these standards, then I encourage you to talk to your manager or the relevant Group Executive. Alternatively, you can contact the external Faircall service on 1800 500 965 (24 hours).

I am proud to work at Cbus and I strive to uphold our values and the standards set out in this Code – I encourage you to do the same.

David Atkin CEO

Message from the CEO

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4 | Cbus Code of Conduct

Purpose of the Code

This Code of Conduct sets out the standards of behaviour expected for all Cbus staff and contractors. All staff and contractors are required to familiarise themselves and act in accordance with the Code.

The Code complements our policies, employment and industrial agreements, relevant legislation, and community expectations. It connects our values, culture and standards of behaviour to promote the highest standards of conduct to deliver great outcomes for our members.

This Code is broken up into the following sections:

n Culture and Values

n Compliance with regulatory and governance obligations

n Personal and professional conduct

n Use of Cbus resources

n Escalation and consequences

n Where to get help

Page 5: Cbus Code of Conduct...Cbus Code of Conduct | 3 Cbus was established in 1984 as the national industry super fund for Australians working in the construction, building and allied industries

Values

At Cbus, we create value for our members and help provide them with confidence, financial security and dignity in retirement. Our actions and decision-making are to be guided by the following values and behaviours to ensure decision-making is in the best interests of the collective membership:

Expected behaviours

We consider member impacts in our

day-to-day decisions

We do the right thing by the law and community expectations in

the best interests of the collective

membership over the long-term horizon

We are comfortable challenging the status quo and

implementing new ideas in a controlled

manner

We learn from our mistakes and build on our successes

We take accountability

for our own performance and as a team

We are open to new ideas and look for innovative solutions

We act with integrity

and respect

We put members at the heart

of everything we do

We are collectively accountable for

the ownership of organisation-wide

outcomes

We proactively escalate, resolve

and communicate issues in a timely

manner throughout the organisation regardless of the

complexity

We are skilled, knowledgeable and

capable to do our job to the best of

our ability

We collaborate to achieve a better

outcome

We share different perspectives through quality collaboration

with each other

We constructively challenge decisions

that do not align with Cbus values or our

members’ best interests without fear of reprisals.

Cbus Code of Conduct | 5

We act professionally, honestly, transparently

and promptly when dealing with all

internal staff and external stakeholders (employers, members,

vendors, regulators)

We are open and inclusive by respecting

and encouraging a diversity of views

and thoughts

We have a safe and healthy environment (both physically and psychologically) to

perform at your best

Culture and values

Cbus Values

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6 | Cbus Code of Conduct

Risk culture

Culture is an important driver of our success and how we can add value for our members. Part of the organisational culture is how we act when faced with risks in the decision-making process.

The Risk Management Strategy and the Risk Culture Program outlines how we approach risk culture at Cbus. Cbus seeks to instil a culture whereby people are empowered to identify risks and opportunities and make decisions that supports the Fund’s ability to operate consistently within its risk appetite.

Cbus’ risk culture will be regularly reviewed and reported to Directors and Management to ensure continued alignment with our values.

The following ‘BUILD’ framework helps staff to practically incorporate risk management in decision-making to ensure decisions are consistent with our values and are within defined acceptable risk limits.

Sandra is unsure of the risksSandra is the project manager updating the online member portal. To ensure that she has captured all the risks, Sandra consults various teams to provide different views on potential risks and opportunities.

Through a risk workshop with various stakeholders, she identified the proposed changes

■■ required engagement and consultation with the regulator APRA■■ could potentially create an information security vulnerability

Also through the workshop, she also identified a number of opportunities to enhance the member experience. Opportunities that she may not have identified if she didn’t collaborate with other parts of the business.

By involving others, Sandra was able to ensure that project was delivered successfully whilst taking advantage of opportunities available.

Culture and values

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Cbus Code of Conduct | 7

B Be aware of risks and opportunitiesGood decisions starts with an awareness of both opportunities and things that could go wrong.

U Understand risks and opportunitiesNo risk should be too big, too complex or too obscure to understand. If we do not understand the risk, we should not take that risk.

IInvolve othersInvolving others from other parts of the business can increase your understanding of potential risks or opportunities, foster a collaborative approach for holistic and coordinated decision making.

LLive the valuesCbus is a values based organisation so you should behave consistently with our values and prioritise longer term results over short term gains. Follow all applicable laws, policies, guidelines and limits. Call out any behaviour inconsistent with our values.

DDecide in the members' best interestMembers are the only reason Cbus exists so it is important to make decisions that align with the best interest of the collective membership, including fairness between different groups.

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8 | Cbus Code of Conduct

Cbus operates in a highly regulated industry, with multiple key regulators, including:

■■ Australian Prudential Regulation Authority (APRA),■■ Australian Securities and Investments Commission

(ASIC) ■■ Australian Transaction Reports and Analysis Centre

(AUSTRAC).

■■ Australian Tax Office (ATO)

You should understand and comply with both the spirit and the letter of relevant laws and regulatory obligations. Where you are unsure, seek guidance from the Cbus Legal, Compliance, & Governance teams.

Fraud control & anti-money laundering, counter-terrorism financing Also, Cbus has obligations under Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) legislation to properly identify customers before paying benefits and monitor its AML/CTF risks appropriately.

Cbus actively encourages Cbus employees to report any suspected instances of fraud or suspicious matters to their manager or Cbus Risk Team promptly.

Refer to Cbus Fraud Control Plan and Cbus Anti-Money Laundering and Counter-Terrorism Financing Policy for further information.

Compliance with regulatory and governance obligations

Cbus, as a trustee, is responsible for all aspects of the Fund’s operations, including the management of fraud risk. As incidents of fraud, corruption and theft can have a potentially high impact on both Cbus members and the Fund itself, it is important that Cbus mitigates the risk of fraud effectively.

High risk roles may cause reputational and financial harm for Cbus through fraud or breach of AML/CTF laws. Therefore, after commencement of employment, the ‘high risk roles’ will undergo periodic bankruptcy and police checks to ensure they are of good character.

Jonah thinks before he actsJonah works in the accounts payable team. One day Jonah received an email from Derrick Smith, the CEO, asking him to urgently transfer $200,000 to pay Simon’s Consulting. Jonah was suspicious because this was not part of the accounts payable process, and there was no corresponding invoice.

Jonah asked his manager for a second opinion. His manager was also suspicious and asked Jonah to confirm with the CEO directly. The CEO did not write the email. Further investigation identified that the sender’s email address was not the CEO’s actual email address.

Because Jonah did not immediately act and followed defined processes, he prevented a fraud which could have cost the fund $200,000.

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Cbus Code of Conduct | 9

Privacy and confidentiality Cbus takes privacy and confidentiality very seriously and has privacy policies and procedures in place to manage our members' personal information. You must become familiar with these policies and procedures and ensure that you follow them carefully.

Before sending personal or confidential information to third parties, you are required to get approval from the Cbus Compliance Team, by completing a Release of Confidential Information Form. Projects and initiatives which involve handling of personal information may require the completion of a Privacy Impact Assessment.

Upon joining Cbus you signed a confidentiality agreement. You need to be aware of, and continually comply with, your obligations under this agreement and ensure that you keep Cbus’ confidential information confidential.

If you have any questions or concerns in respect of privacy or confidential related matters, you should seek further guidance from the Cbus Compliance Team.

Compliance with regulatory and governance obligations

Vladimir leaves member information on his deskIt was late on a Friday afternoon and Vladimir was running late to meet his friend Donald. In his haste to leave work, Vladimir didn’t have time to tidy his desk. Papers left on his desk included personal information about a Cbus member.

Over the weekend, a team of removalists had access to the floor to finish up their work following a staff relocation. One of the removalists saw the paperwork on Vladimir’s desk and took a photo of the member’s account details. On Monday, the removalist passed a three-point security check and rolled out the entire balance of the member’s account.

Vladimir’s failure to keep member information safe equipped the fraudster with everything he needed to empty the member’s account.

In this scenario, Vladimir was terminated from his role because he had prior formal warnings about leaving personal information carelessly. You should handle our member’s personal information as if it were your own.

Page 10: Cbus Code of Conduct...Cbus Code of Conduct | 3 Cbus was established in 1984 as the national industry super fund for Australians working in the construction, building and allied industries

Personal securities trading All Cbus employees need to be aware of their obligations in relation to applicable trading laws, regulations and market practices. Cbus employees are prohibited from misusing inside information, including communicating this information to others who may use the information.

The Cbus Personal Securities Trading Policy (Trading Policy) provides further details about specific obligations in relation to personal securities trading including guidelines around purchasing Cbus Property

residences and the Cbus Self-Managed Investment Option as well as other investment related prohibited activity.

Cbus employees classified under the Trading Policy as “Access Persons” also have other compliance requirements when it comes to disclosing personal securities held and the trading of those securities.

It is important that you familiarise yourself and comply with your trading obligations if you work in the Cbus Investments Team, or due to your role's involvement with the Investments Team, you are designated an "Access Persons".

Delegations – executing documents on behalf of Cbus You can act on behalf of Cbus in line with your delegated authority under the Cbus Delegations Registers. This includes, but is not limited to, approving the spending of money, signing legal documents, hiring employees and making public statements).Exceeding your delegated authority may put Cbus at risk.

10 | Cbus Code of Conduct

You should become familiar with the extent of your delegated authority and if you have any questions about whether you have authority to act on behalf of Cbus, you should speak to the Cbus Governance or Legal teams to seek clarification.

For further information, you should review the Investments Delegations Register, Management Delegations Register and ARMC Delegations Register.

Ted uses inside information to make a monetary gainWhilst in the lunch room, Jenny and Peter, part of the Investment team discussed a potential company takeover which they were working on to their friend Ted, a member of the IT team.

That day Ted bought $20,000 worth of shares. Later that week, when the takeover was publicly announced, those shares went up 40% due to an announcement of the takeover. Ted sold his shares and made $8000

After a thorough investigation, it was found that Jenny, Peter and Ted breached Cbus’ Personal Securities Trading Policy. All three people were terminated from their role. The insider trading incident was also reported to ASIC.

Compliance with regulatory and governance obligations

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Cbus Code of Conduct | 11

You are expected to always act in a professional manner while interacting with Cbus colleagues as well as all external parties.

This includes

■ maintaining professional standards of behaviour, attendance and dress,

■ being open, honest and diligent in dealing with all stakeholders,

■ being accountable for your decisions and actions.

Diversity & inclusion Cbus is committed to workplace diversity and inclusion. We value and respect the diversity of our employees and provide a workplace that is fair, accessible, flexible, inclusive and in which unlawful discrimination, bullying, harassment or victimisation are not tolerated.

Further information can be found in our Diversity and Inclusion Policy and in Respect in the Workplace Policies.

Personal and professional conduct

Internal Audit discovers a fraudsterInternal Audit performed a review of the benefit payment process. Management was not aware of a fraudster taking advantage of control gaps. During the review, the manager, George, was too busy to meet and provide requested documentation to Internal Audit.

This resulted in the audit taking two weeks longer than expected and the fraudster was able to take an extra $300,000 from a member’s account.

We should act professionally at all times because all stakeholders play an important part to deliver positive member outcomes.

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12 | Cbus Code of Conduct

Occupational health & safety Cbus is committed to providing safe workplaces, implementing safe work practices and promoting employee wellbeing. We seek input from our people on health and safety matters through our consultative forums and work collaboratively to resolve any health and safety issues.

All Cbus employees are accountable for their own safety and the safety of others. Further information can be found in the Cbus Workplace Health & Safety Policy.

Learning & professional development Cbus is committed to all employees continually adding to their skills and knowledge and building their capability.

All employees are encouraged to undertake at least seven hours of professional development and training per year. However, some training is mandatory for all employees, and where this is the case, you need to ensure that you complete this training by the due date.

If you are a Representative or Responsible Manager under Cbus’ AFSL, you are required to spend a minimum of 30 hours on professional development per year. This is to ensure you keep up with industry trends and issues, so you can provide the best possible experience to our members.

The Cbus Learning and Professional Development Policy and Guidelines provides further information about learning and professional development at Cbus.

Conflicts As part of our values, as well as being a legal obligation, you need to immediately declare all perceived, actual and potential conflicts to your manager, Group Executive or the Governance Team.

A conflict is a situation where your external circumstances, contracts or connections may or have the potential to inappropriately influence your obligations to Cbus, Cbus members or their beneficiaries.

If you are unsure about whether something needs to be declared as a conflict, you should consult the Governance Team for advice. You can find further information about conflicts and conflicts management at Cbus in the Cbus Conflicts Management Policy.

Beatrice gives business to a relativeBeatrice is responsible for purchasing printer cartridges. She asks her brother in law, who owns a printer cartridge business to supply cartridges. Beatrice did not declare this conflict because she knew that it was not the best value cartridges.

This intentional breach of the Conflicts Management Policy did not contribute to positive member outcomes, and resulted in Beatrice’s termination.

Personal and professional conduct

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Cbus Code of Conduct | 13

Respect in the workplace Cbus does not tolerate any form of discrimination or harassment (including sexual harassment) based on race, disability or sexual orientation.

This includes conduct outside of work hours which relates to your employment with Cbus (such as events, functions organised by Cbus as well as conferences, seminars and other social functions where you have been invited to attend as a representative of Cbus).

Further information can be found in the Complaint Resolution Procedure in Respect in the Workplace Policy.

Nigel feels uncomfortable with Tamara’s behaviourOne day, Tamara made inappropriate suggestions to her colleague Nigel. He politely declined and explained he wasn’t interested and he requested that she stop. Tamara continued to make inappropriate suggestions so Nigel raised a complaint to People and Culture.

Following a full investigation into the matter, Tamara was found to have breached Cbus’ Respect in the Workplace Policy because her conduct was unsolicited, unwelcome and was intimidating towards Nigel. In this scenario, Tamara was given a formal written warning. However, this could have resulted in termination.

Personal and professional conduct

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14 | Cbus Code of Conduct

Bullying and workplace violence Cbus has a policy that workplace bullying or occupational violence will be prevented wherever possible and will not be tolerated under any circumstances.

Workplace bullying is repeated and unreasonable behaviour directed towards an employee or group of employees that creates a risk to health or safety.

Cbus treats all complaints of workplace bullying or violence seriously, empathetically, promptly and confidentially and will act to ensure that workplace bullying or violence stops and that any person who reports bullying or violence is not victimised for acting in good faith.

If you experience or witnesses bullying or violence, you should intervene wherever it is safe and appropriate to do so to prevent harm, and in any event, report it as soon as possible. When bullying is reported it will be investigated quickly and in accordance with the Respect in the Workplace Policy Complaints Resolution Procedure.

Further information about Cbus’ policy about workplace bullying and violence can be found in the Cbus Workplace Bullying and Violence Prevention Policy.

Jade excludes a colleague from team activitiesJade, a Team Assistant was organising a team building activity day for her team. During the planning process, she excluded Garry, predominantly as she felt he was not very well liked by the team.

It was later discovered that Jade and the team had breached the Cbus Workplace Bulling & Violence Prevention Policy by excluding Garry from workplace activities repeatedly.

After an investigation of the incident, Jade and the team were given a formal written warning because the exclusion of Garry from the team happened repeatedly.

Personal and professional conduct

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Cbus Code of Conduct | 15

Drugs and alcohol Cbus encourages a healthy and safe environment in relation to alcohol and drugs. Where approval for alcohol consumption is provided, Cbus will provide an environment where moderation and a responsible approach towards the consumption and serving of alcohol is encouraged, and inclusiveness of staff who choose not to consume alcohol.

You must ensure that you do not attend work if you are adversely affected by alcohol or drugs and you should not be adversely affected by alcohol or drugs whilst engaged in Cbus business. If you are at work under alcohol or drug impairment, it is a risk to your own safety and others, and this may result in disciplinary action ranging from a verbal warning to termination.

If you require assistance with personal issues related to drug and alcohol related issues, you should contact the Cbus Employee Assistance Program, via one of the below methods:

1300 326 941 – 24hrs

[email protected]

www.fbggroup.com.au

Personal and professional conduct

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16 | Cbus Code of Conduct

Dealing with external parties

Maintaining a professional and transparent approach with external parties such as service providers, auditors and regulators and most importantly our members and employers is fundamental for ensuring Cbus maintains its good reputation. You should always communicate and provide information in a timely manner.

Gifts You are able to accept gifts, hospitality or benefits from external parties, if you follow the below guidelines:

Holiday Season

Gifts

No matter value, need to be placed

into national pool of gifts for

distribution

On pre-approval

list

No matter value need

PRIOR approval by Group Executive

Over $50 & not on

pre-approval list

Must be registered on

the Gifts Register.

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Cbus Code of Conduct | 17

Dealing with external parties

Wayne seeks advice about gifts from a service providerWayne, a Manager in the Marketing Team, received two Corporate Box tickets to the Australian Open Finals from a Service Provider.

Wayne wasn’t sure whether he needed to declare the two Corporate Box tickets in the gifts register so he consulted Patty from the Governance team.

Patty knew that the Service Provider was tendering for consulting work so she advised Wayne that he could not accept the tickets because there was a tender currently in process. Wayne was grateful for Patty's advice because had he accepted the tickets he would have breached the Cbus Gifts Policy because there was a tender in progress. He would have received a formal written warning because he was not part of the tender and was not able to influence the tender process.

Gifts from an external party if the Fund has commenced a tender process cannot be accepted under any circumstances – including the acceptance of gifts by your spouse or children.

You are prohibited from soliciting gifts in relation to the performance of your role at Cbus and the acceptance of monetary gifts such as cash, cheques, money order, travellers’ cheques, direct deposits and the like is strictly forbidden.

You should consult the Cbus Gifts Policy for more information, prior to accepting any gifts. If you are unsure, seek advice from the Governance team.

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18 | Cbus Code of Conduct

Social Media When using social media (such as LinkedIn, Twitter, Facebook, You Tube) you should have regard to the Cbus Social Media Mindfulness Principles contained in the Cbus Social Media Policy.

There are restrictions about certain releases you can make via social media before official Cbus announcements released by the CEO, or their delegate. Refer to the Cbus Social Media Policy for more information.

Leila posts an inappropriate Instagram post about her managerLeila was at a colleague’s birthday lunch on Friday. While at lunch she took a selfie with her workmates and uploaded the picture on Instagram with the caption ‘Having lunch with my mates. My manager doesn’t know what I’ m doing. Then again, he doesn’t know what he’s doing either !!!’’

On the Monday morning, Leila’s manager saw the Instagram post and reported this to the People and Culture team. After a thorough investigation, Leila was found to have breached the Cbus Social Media Policy and given a verbal warning because it was not considered a serious breach.

Leila gave a formal apology to her manager whilst the post was deleted from Instagram. She was provided further training on Cbus’ Social Media Policy.

Dealing with external parties

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Cbus Code of Conduct | 19

Use of Cbus resources

Byron uses his corporate card to buy personal groceries Byron was given a Corporate Card as he was required to travel to Sydney and Brisbane a few times a year for work purposes.

One Sunday afternoon he used the Corporate Card to purchase $89 of his personal groceries at the grocery store. When he returned home, he realised that he had used the wrong card. On the Monday morning, he immediately went to payroll to notify them of his mistake and how he could reimburse the fund.

Had Byron not confessed to his mistake, he would have been in breach of the Cbus Corporate Card Policy. If you think that you have made an honest mistake, it is better to own up earlier rather than be disciplined for the action.

To ensure that we keep operational costs as low as we can, we need to ensure that we are only using Cbus funded resources, such as printers, phones, information systems, corporate cards and motor vehicles in line with relevant Cbus policies.

Corporate Cards If you have a Corporate Card, you need to use this card to purchase goods and services that are of a genuine business purpose only. Charging personal transactions to your Corporate Card is not acceptable under any circumstances. Other purchases that are not allowed to be made using your Corporate Card are listed in the Cbus Corporate Card Policy.

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20 | Cbus Code of Conduct

Information Systems Cbus allows personal use of its information systems (computer systems such hardware, software, laptops, tablets, telephones, internet, email), where this use is of a reasonable duration, frequency, cost and does not interfere with the performance of your duties and functions as a Cbus employee.

The Cbus Acceptable Use Policy establishes the acceptable use of Cbus Assets and Information by providing clear examples and statements of what is acceptable and what is not.

If you have any questions or become aware of inappropriate use of a Cbus Asset or Information, you must report the incident to the Cbus IT Support team as soon as possible.

TravelCbus has a Travel & Expense Policy in place that seeks to provide a definitive guide to Cbus employees and directors about the rules and procedures connected to work related travel expenses. Cbus uses an external travel service provider to book all its travel, to obtain volume discounts and to record travel information in the interests of employee safety.

If you are travelling for work, refer to the Cbus Travel & Expense Policy for more details of acceptable travel related expenses.

Roula starts a personal businessRecently, Roula started an online Wellness business at home.

Roula’s business began to grow, requiring her to spend more time on it. Unfortunately, this caused Roula to fall behind in her Cbus duties. Concerned, Roula’s manager Betty discussed the situation with Roula. Roula agreed she would refocus at work and get back on top of things.

Unfortunately, Roula’s Cbus duties slipped again. This made Betty look into the situation further. And after a thorough investigation, it was discovered Roula had been using her Cbus laptop and mobile to operate her business. She had also used Cbus printers to print her business flyers.

Roula’s actions had breached Cbus’ Acceptable Use Policy. Her outside activities interfered with her official Cbus duties, and the use of Cbus Assets for personal use had far exceeded a reasonable amount.

Roula received a formal written warning and was required to reimburse Cbus for the costs incurred.

Use of Cbus resources

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Cbus Code of Conduct | 21

Escalation of misconductCbus encourages its employees, directors and contractors to report any serious misconduct or breach of policy through the usual reporting and escalation lines.

This would normally be through your manager in the first instance. If your manager is the subject of your concerns, you should go directly to the Head of Legal, Governance and Compliance, CEO, or through the external Whistleblowing Hotline:

The hotline is monitored by trained and experienced forensic professionals who interview the caller to ensure all available and relevant facts are obtained.

Cbus is committed to confidentiality and fairness in all matters raised by Whistleblowers. You will not be personally disadvantaged at Cbus if you raise a Whistleblowing incident provided you follow the Whistleblower process. Refer to the Whistleblowing Policy for more information.

Consequences of misconduct We acknowledge that the vast majority of staff and contractors will follow the Code. However, if you fail to comply with the Code, it will be considered a serious breach and will be fully investigated.

If the investigation reveals a breach, appropriate disciplinary and remedial action will be taken.

This action will vary depending on the significance of the harm or potential harm and behavioural context of the breach. The consequences will range from a verbal warning all the way to termination. Refer to the Performance Improvement Policy.

Escalation and consequences

1800 500 965 – 24hrs 02 9335 7466

[email protected] www.kpmgfaircall.kpmg.com.au/Cbus

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22 | Cbus Code of Conduct

Misconduct types

Minor misconduct

Minor misconduct is considered any misconduct in which the harm or potential harm is not significant for Cbus and the behavioural context is careless or negligent. Any misconduct will be investigated and if proven will lead to disciplinary action such as a verbal or written warning depending on the nature and extent of the incident.

Examples may include:

■■ Accepting a once off $100 gift voucher from a service provider that is not in a tender process and not disclosing this in the Gift Register due to an honest mistake.

■■ Claiming a work reimbursement that you’re not entitled to due to an honest mistake or oversight.

■■ Completing 1 mandatory online learning module 5 days late due to the inability to access the internetwhilst away on holidays.

Gross misconduct

Gross misconduct is the most serious type of misconduct because there are significant reputation and financial impacts to Cbus and the behavioural context is deliberate and malicious. This type of misconduct may result in termination. Examples include:

■ not taking any action or failing to take action that may breach this Code, the law or Cbus’ policies and procedures.

■ not completing all relevant reading, training and awareness programs to build and maintain awareness and understanding of relevant laws and policies.

■ engaging in behaviours defined as serious misconduct that contravenes the Cbus Performance Improvement policy explicitly:

- committing an act of dishonesty, theft or an indictable offence;

- engaging in conduct that causes an unacceptable loss to the reputation of Cbus or may be reasonably likely to do so;

- assault or engaging in threatening behaviour towards a colleague, or conduct that creates a serious risk to the health and safety of another person;

- improper sexual conduct including any form of sexual harassment, such as explicit conversation

- failing to hold any licence, qualification or certificate necessary for the performance of employee duties and responsibilities;

- providing false or misleading information to Cbus during your employment or any stage of the recruitment process;

- disobeying a lawful and reasonable direction of Cbus;

- committing any act of insolvency or being declared insolvent or bankrupt;

- being convicted of any serious criminal offence or being disqualified from managing a corporation;

- the use of illicit drugs or excessive consumption of alcohol.

Escalation and consequences

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Cbus Code of Conduct | 23

If you have any questions about your obligations under the Cbus Code of Conduct and require further assistance, here is where you should go to seek advice and guidance:

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Bullying, harassment, workplace violence and inappropriate workplace behaviour

Conflicts of interest

Corporate cards & travel

Drugs and alcohol

Delegations

Occupational health & safety

Fraud

Gifts

Learning & professional development

Money laundering & terrorism financing

Privacy & confidentiality

Personal securities trading

Social Media

Use of information systems

Where to get help

Page 24: Cbus Code of Conduct...Cbus Code of Conduct | 3 Cbus was established in 1984 as the national industry super fund for Australians working in the construction, building and allied industries

Cbus’ Trustee is United Super Pty Ltd. ABN 46 006 261 623 AFSL 233792 Cbus ABN 75 493 363 262 04-19