Introduction

Geforce Technologies Pty Ltd (“the Company) aims to deliver superior long-term total shareholder return, taking proper account of employees, customers and others with whom we do business, and the broader community. In striving to achieve these aims, we should not compromise our ethics or principles. The Company places great importance on honesty, integrity, quality and trust.

No matter what your role is, or your location of work, you are expected to:

Demonstrate the behaviours of honesty, integrity, quality and trust at all times
Set an example for others and recognise those around you who also demonstrate these behaviours
Speak out when you feel that these behaviours are threatened or compromised.

1- What is the code of conduct and ethics?

The Code of Conduct and Ethics (Code) sets standards for the way we work at Company.

The Code provides a practical set of guiding principles to help you make decisions in your day-to-day work, whatever you do and wherever you do it. The Code operates together with other policies, and procedures as part of a unified conduct and ethics policy framework. These policies and procedures include Company’s Anti-Bribery & Anti-Corruption Policy (ABAC Policy), Whistleblower Policy and internal Delegation of Authority (DOA) Policy.

The Company takes the Code, and all of the policies that make up the conduct and ethics policy framework, very seriously. As someone working with the Company, you are required to comply with the principles and the spirit of the Code and policy framework.

Where can I find a copy of the Code?

The current Code is available on Company’s Intranet and the Company website (https://www.geforce.com.au/codeofconduct/). A current copy may also be requested from your Human Resources Manager.

Who does the Code apply to?

This Code applies to anyone who is employed by or works at Company including directors, employees (both permanent and temporary), contractors and consultants.

When does the Code apply?

The Code applies to you whenever you are identified as a representative or are acting on behalf of the Company. In some circumstances, this will include times when you are outside your immediate workplace or working hours, for example at work functions, out of hours work activities or when you are out in the community on behalf of the Company.

What will happen if I breach the Code?

Failure to comply with the principles or the spirit of the Code or the policy framework will be considered a serious breach of Company policy and will be investigated. Breaches of the Code or the policy framework will result in an appropriate consequence being applied to you. This may range from a verbal warning through to the termination of your employment for serious breaches.

How can I be sure my conduct complies with the Code and policy framework?

While the Code provides general guidance and minimum expectations regarding your conduct, no code or policy can ever cover every conceivable circumstance you may face. In everything you do, you are expected to listen to and act upon your conscience to help build and maintain Company’s and your own reputation.

If you are in doubt about whether your conduct is consistent with this Code, it may help you to ask yourself the following questions:

Does it feel like the right thing to do?
What would a Company customer or shareholder expect or want me to do in this situation?
What would the reaction be if this was reported in the newspapers?
Would my colleagues or manager consider my behaviour appropriate?
What impact might this have on the Company and its commitment to shareholder value?

Who can support me in complying with the Code?

If you need more information or are unsure of the Company’s expectations or your obligations, we encourage you to speak with your manager.

Breaches of the Code

All breaches of the Code are required to be recorded and reported in line with the Company’s policies and procedures and in compliance with law.

2- Acting in Company’s best interests

The Company’s reputation as a trusted and respected organisation is one of its greatest assets.

Each of us has the ability to build and maintain the Company’s reputation, or to harm that reputation and undermine Company’s performance.

Company shareholders, customers and the community expect Company and everyone who works at Company to act professionally and ethically. We must do what we can to meet these expectations and support others to do the same. In everything you do, you should consider how your or someone else’s actions could impact on Company’s performance, reputation or other assets and take action to prevent or remedy anything that could adversely impact the Company.

What you must do

Undertake your duties with care and diligence. Remember, you are accountable for the decisions you make and the actions you take.
Deal fairly and honestly with all Company’s customers, suppliers, competitors and any other third parties or business partners.
Help protect Company and its customers against potential theft or fraud.
Comply with all laws where Company conducts business.
Exercise your authorities, including your expenditure commitment and payment discretions and corporate credit card funds, responsibly and within their limits. You are responsible for understanding your authorities, including any relevant limits, and are accountable for how they are used.
Behave in a way that takes into account our impact on the broader community and the environment in both the short and long term.
Use all of Company’s systems and equipment appropriately and for proper purposes. This includes email, messaging, Internet access, and technology and banking systems.

3- Honesty and integrity

Honesty and integrity are essential to everything we do at the Company.

Our success depends on the trust of our customers, which is earned by acting with honesty and integrity and by considering the Company, our shareholders, customers, colleagues and the general community when making decisions.

Honesty and integrity can be just as important in the things we fail to do. For example, failing to report the suspicious or dishonest conduct of a colleague reflects on your own honesty and integrity, and may ultimately affect Company’s reputation for honesty and integrity as well.

What you must do

Immediately report suspicions of individual instances of fraud, theft or other dishonest behaviour by others (including colleagues or customers).
Never improperly use your position with the Company, or any information you receive through your work at the Company, to further your own personal interests, or help others to do so.
Never help a customer or anyone else to break or evade the law.
Be honest and forthright in all of your communications and dealings with the Company, including with your manager, colleagues, customers, and the broader community. This includes communications and dealings as a customer, as well as someone who works with the Company.
Ensure all dealings (such as transactions or commitments) with customers, suppliers or third parties are properly recorded and transparent.
Use Company assets and funds (including corporate credit cards) for proper purposes and keep accurate and transparent records of all payments or receipts for transactions using Company funds.

4-Treatment of others

The Company values difference and is committed to achieving a truly diverse workforce that remains inclusive and respectful of each other’s differences. We are all expected to treat all people we deal with through our work at the Company with dignity and respect, whether they are colleagues, customers, suppliers or other third parties.

Unlawful discrimination, harassment of any kind, bullying or victimisation or other unacceptable or offensive conduct will not be tolerated.

The Company believes the safety, security and physical and mental health of our people lie at the heart of each person’s ability to contribute to our success. The Company respects the right of all individuals to work in a safe working environment that promotes wellbeing.

What you must do

Treat all people you deal with through your work at the Company with dignity and respect.
Make employment decisions based on merit, and not on attributes that are irrelevant to employment or performance.
Never unlawfully discriminate, harass or bully your colleagues, customers, Company visitors or anyone else in the workplace. This includes being aware that some behaviour may be acceptable to you but not to others and acting appropriately.
Contribute to promoting a safe working environment by taking responsibility for health and safety and reporting any issues as soon as possible.
Never treat somebody less favourably because they have brought or propose to bring a genuine complaint of unacceptable behaviour.

5- Conflicts of interest

Acting honestly and with integrity also means managing conflicts of interest and never putting yourself in a situation that puts, or appears to put, your own personal interests before those of the Company or our customers.

The perception of a conflict of interest can do as much damage to the Company’s reputation as an actual conflict of interest. You must be mindful of when a conflict may be perceived by others and take action to avoid or address this risk.

What you must do

Be alert to actual or potential conflicts of interest and disclose them to your manager, or human resources representative.
Never trade in securities if you have information that may affect the price of the security and this information is not publicly known or generally available.
Seek approval for any outside business interest including non-Company work (paid or unpaid), business ventures, directorships, partnerships or a direct or indirect financial interest which has the potential to be in conflict with your employment, the interests of the Company or the Company’s partners, customers or suppliers.
Keep an arm’s length relationship when dealing with customers or suppliers and obtain written approval of the Company to do business, hold accounts, transact with or hold a direct or indirect financial interest in customers or suppliers you deal with in the course of your work with the Company.
Never provide or maintain products or services for, or complete or approve transactions on behalf of, immediate family members or relatives in the course of your work.
Disclose to your manager any personal associations with a third party that you are involved in evaluating or negotiating with for the Company, whether for employment, as a customer or supplier or any other reason.

6- Privacy and confidentiality

In your work at the Company, you may come across private and confidential information relating to the Company, colleagues, customers, suppliers or other third parties. People provide us this type of information on the basis of trust. Misuse of confidential and private information can have severe commercial and reputational consequences for the Company and can also greatly affect those whose information is misused. If people feel they cannot trust us with their information they are unlikely to trust us with their business.

The Company is committed to maintaining the confidentiality and security of this information and you are expected to do your part to help honour this commitment.

What you must do

Do all you can to keep information secure. This includes not sharing private or confidential information with other employees unless they need it to perform their work at the Company.
Never release information about customers or colleagues to third parties outside of the Company unless the person the information relates to has agreed or if the Company is required to release the information under the law.
Follow procedures and requirements to protect information whenever you provide details over the phone, by email or fax.
Follow all protocols and procedures relating to the maintenance of passwords and user profile setup. Never allow someone else to log on to the Company systems using your individual details.
Collect, use, store, handle, update and destroy information, particularly personal information, in line with applicable policies and processes at all times.
Never disclose any information about the Company or any other company or individual (including a former employer) that is not already in the public domain without the proper authority to do so.
Never disclose any information about the identity of a person disclosing information under the Whistleblower Policy other than in accordance with law or the Whistleblower Policy.

7- Improper payments, benefits or gains

Integrity and trust are inconsistent with improper payments, benefits or gains of any kind.

There are certain situations that have a higher risk of an improper payment, benefit or gain being offered, made or received. These include rewards from current or potential customers or suppliers that are out of the ordinary, such as cash, cheques, gifts, gift certificates or travel of a high value.

Where rewards from a current or potential customer or supplier create any obligation or expectation that you will give preferential treatment to the person or company offering the reward, the reward is improper and must be refused.

What you must do

Never offer or accept any gift, reward or entertainment, including discounted products, free travel or accommodation, if it could create any obligation or expectation that could conflict with your work at the Company.
Never engage in, or induce another person/ party to engage in, or induce or facilitate another person or agent to engage in any form of bribery or corrupt conduct, including the offering, promising or giving, or requesting, agreeing to receive or accepting, directly or indirectly of bribes or “facilitation payments” (payments to speed up routine legal actions) to anyone. This applies irrespective of whether the conduct involves individuals, incorporated or unincorporated organisations and/ or public officials.
Only accept gifts or entertainment in line with applicable policies and processes – see the Delegation of Authority Policy (a current copy of which may be obtained from the HR Department and the ABAC (Attribute Based Access Control) Policy (a copy of which is located on the Company’s Intranet.
Never make, or offer to make, any donation or other financial contribution from the Company to a political party or candidate unless it has been approved by the Company’s CEO or Managing Director in accordance with the DOA Policy.
Only entertain customers and business associates with lunches, dinners or other appropriate events (such as football, cricket or the theatre) if the nature and value of the entertainment is reasonable and proportionate, in light of the nature and value of the business relationship with the Company and the seniority of the parties attending. Ensure that any entertainment accords with applicable business policy and is not of a nature that brings, or could possibly bring, Company into disrepute.
Obtain proper approval for and properly record any donations, sponsorships, charitable contributions, gifts and entertainment you accept from, or give to, a third party on behalf of the Company.

8- Commitment to the Code

The Company is subject to laws and regulations in all the locations in which we do business.

You must be familiar and comply with all relevant laws and regulations in the location or locations in which you work. Any breaches of the law can have serious consequences beyond your employment, both for the Company and for you as an individual.