Code of Conduct

CODE OF CONDUCT

Purpose SMEC’s Code of Conduct establishes a common understanding of the

standards of behaviour expected of all SMEC Group Employees in the
performance of their duties.

SMEC operates in a global context and aims to ensure that any initiatives
develop under this Code of Conduct will be managed in accordance with
the laws in that jurisdiction.

The Code of Conduct is supported by more detailed policies, standards,

procedures and guidelines and should be read in conjunction with the
Code of Conduct for Directors and Executives.

Applicable To This policy is applicable to:

• All SMEC Group employees

• All third party contractors, volunteers and consultants engaged

by SMEC

Definitions, Employee - means all those who work for, act on behalf of or represent
Abbreviations and the SMEC Group including SMEC Group employees, directors and other
Acronyms officers, contractors and consultants (where they are under a relevant
contractual obligation) and Third Party/Representatives.

LHRM - Local Human Resources Manager

OHS - means Occupational Health and Safety

SMEC - means SMEC Holdings Pty Ltd.

SMEC Group - means SMEC and any of its controlled subsidiaries.

Content Statement of Core Values

Responsibilities of Those Working Across the SMEC Group

Occupational Health and Safety (OHS) Policy

Equal Employment Opportunity and Diversity

Confidentiality and Privacy

Child Protection

Drugs and Alcohol Policy

Appropriate Use of SMEC Assets Including Electronic Communication

Code of Conduct www.smec.com 2 of 9

 Media Comment and Social Networking Sites

Complying with the Code of Conduct

Reporting a Contravention or Suspected Contravention of this Code of

Conduct

Safeguarding Against Retaliation

Disciplinary Action for Breaches of the Code of Conduct

Encouragement of Associated Companies to Adopt this Code of Conduct

TOPIC DETAILS

Statement of Core SMEC’s mission is to partner in the economic development of nations by

Values meeting the needs of a diverse range of clients and communities through
professional excellence and innovation, and deliver rewards to SMEC
shareholders and rewarding careers for SMEC employees.

SMEC seeks to achieve its mission by:

• requiring staff to act with integrity, honesty, and in an ethical

manner at all times, promoting a diverse and inclusive
organisational culture with high management accessibility,

• a “can do” approach, where SMEC employees take pride in their

achievements and

• creating a place where employees are proud to work.

Responsibilities of SMEC employees must:

Those Working Across
the SMEC Group • comply with this Code and other SMEC policies and procedures,
and any legislation applicable to their role

• provide advice or services that is honest, impartial and

comprehensive, irrespective of their personal views on a matter

• perform their duties to the best of their ability and be

accountable for their performance

• follow reasonable instructions given by a supervisor or manager

• comply with a lawful direction

• carry out their duties in a professional, competent and

conscientious manner, while seeking suitable opportunities to
improve their knowledge and skills, including through
participation in relevant professional development

Code of Conduct www.smec.com 3 of 9

 • maintain any credentialing, qualifications and registration
requirements relative to their role

• be courteous and responsive in dealing with colleagues, and

clients

• work collaboratively with their colleagues

• be mindful of their duty to the safety of themselves and others

• inform SMEC of any act of dishonesty or unlawful act.

In addition to the above responsibilities, managers are also expected to:

• demonstrate behaviours that are consistent with this Code

• ensure that employees understand their responsibilities under

this Code and other SMEC policies and procedures

• promote collaborative and collegial workplaces by developing a

positive working environment in which all employees can
contribute to the ongoing development of SMEC

• exercise leadership by working with their employees to

implement performance and development processes that are
consistent with the employee’s conditions of employment

• provide ongoing support and feedback to their employees

• establish systems within their area of responsibility which

support effective communication and consult with and involve
their employees in appropriate decision-making

• take appropriate action if a breach of this Code or any other

SMEC policies and procedures may have occurred.

SMEC is a United Nations Global Compact (UNGC) Corporate participant

incorporating the UNGC’s principles into business activities to help create
a more sustainable global economy.

Occupational Health The health and safety of all Employees and those visiting the organisation
and Safety (OHS) are considered to be of the utmost importance. The SMEC Group is
Policy committed to providing and maintaining a working environment that is
safe and without risk to health so as to comply with all relevant
legislative requirements.

Bullying and occupational violence are identified as a form of harassment

based on the misuse of power in human relationships and can be defined
as behaviours intended to disturb, threaten or upset.

Code of Conduct www.smec.com 4 of 9

 Workplace bullying and occupational violence are health and safety
hazards which are not tolerated within the SMEC Group.

Equal Employment The SMEC Group, is committed to promoting an inclusive organisational

Opportunity and culture, and strives to drive a workplace where people are treated with
Diversity dignity, respect and consideration at all times.

SMEC does not condone any behaviour which may be perceived as

bullying, intimidation, discrimination, or any form of sexual or workplace
harassment. As such SMEC encourages the development of an inclusive
and diverse workforce and believes that diversity is a strength for our
people, our clients, our partners and our communities.

SMEC’s people strategy is underpinned by a commitment to attract the

best talent and engage in recruitment and selection processes that are
based on merit. SMEC expects all recruitment activities to be undertaken
free of bias or discrimination, and to comply with relevant local
legislation.

Confidentiality and SMEC is bound by the privacy legislation of the country in which it
Privacy operates. A set of strict policies to provide Employees with guidelines for
collection, storage, use and disclosure of personal information has been
developed.

Maintaining confidentiality is vitally important to SMEC’s business. The

reputational consequences of failing to maintain confidential information
of a third party are disastrous and may lead to SMEC being disqualified
from bidding for certain types of work and with a large range of clients.

It is the responsibility of each Employee to be aware that any personal

information they come across is highly confidential and will only be used
for that purpose for which it was collected.

Under no circumstances may any Employee pass on any personal

information unless they have the client’s consent to do so. Employees
may however disclose personal information where they are under a legal
duty to do so.

Employees will not collect sensitive information about a client which

includes such things as information about a client’s health, racial or
ethnic origin, political opinions or membership of political associations
unless the client has given their consent.

Child Protection As a global corporate citizen, SMEC recognizes the role it can play in
supporting local communities, including through sharing in the collective
responsibility of all adults to prevent child exploitation and abuse.

SMEC maintains a zero-tolerance policy in relation to child abuse and

exploitation, including unacceptable behaviour directly involving children
or observed by children, and any form of child exploitation material.

Code of Conduct www.smec.com 5 of 9

 SMEC commits to preventing a person from working with children if they
pose an unacceptable risk to children.

Employees are expected to familiarize themselves with the SMEC Child

Protection policy and if assigned, complete the online training module.
All Employees are encouraged and expected to report any behaviour that
they suspect may be child exploitation or abuse, including possession of
child exploitation material.

Drugs and Alcohol In line with SMEC’s commitment to providing a safe and healthy
Policy workplace, employees are expected to be able to function at an
acceptable level of performance and not be impaired by illegal or legal
drugs, including alcohol.

SMEC prohibits the possession or use of illegal substances and requires

all employees to act responsibly in their consumption of alcohol at all
work related function including (but not limited to) staff functions,
conferences, group and farewell lunches, events organised by the social
club, client function or end of financial year and Christmas celebration.
Excessive consumption of alcohol is to be avoided – this is both a safety
and social responsibility.

Action will be taken in instances where an employee’s ability to perform

their duties is impaired or other employees are placed at risk.

Any illegal drugs found on SMEC property or in the possession of any

person on SMEC property will be reported to the Police.

Employees must report incidents involving illegal drug use to their LHRM.

Appropriate Use of Employees have access to a wide range of tools including information
SMEC Assets Including technology and communication systems to assist them in performing
Electronic their roles. Employees must protect SMECs assets which must not be
Communication used for unethical or illegal purposes, or for purposes not related to
SMEC business or in a manner that breaches SMEC’s Business Integrity
Policy.

SMEC provides electronic communication facilities for its employees for

work purposes. Employees must, therefore, comply with SMEC’s Social
Media procedure.

SMEC reserves the right to monitor and view any data stored or
transmitted using SMEC’s facilities.

It is a criminal offence to breach the ownership rights of any other person

or company. No employee should therefore use software that they know
is unlicensed or pirated or pirate software themselves. Substantial
penalties can be imposed upon both the company and you if you breach
somebody else’s copyright.

Code of Conduct www.smec.com 6 of 9

Media Comment and Public comments about SMEC should only be made by the CEO. If an
Social Networking employee inadvertently makes a public comment (including sensitive
Sites information) the employee must immediately inform their direct
Manager and the General Manager, Corporate Affairs.

Employees are not authorised to comment to the media on any aspect of

SMEC’s business.

If approached by media, employees must refer all enquiries to the

Manager Stakeholder Relations via email.

Complying with the The principles contained in this policy provide employees with a clear set
Code of Conduct of standards on which to base their behaviour across all areas of
professional activity. However, SMEC’s Code of Conduct is not intended
to be exhaustive and cannot anticipate every situation which may
morally or ethically compromise the employee, or SMEC.

In the instance where employees are faced with situations that are not
specifically addressed in this code, asking the following questions can
assist in determining an appropriate course of action:

• Is it legal and in line with SMEC values, principles, policies,

procedures and guidelines?

• Do my actions put anyone’s health and safety at risk?

• If the story appeared in the media, would I feel comfortable with

the decision?

• Do I have all the information that is significant to the decision I

am about to make?

• Would you be confident explaining your actions to senior

management or external authorities?

• Are my actions transparent? Is there anyone else who I should

make aware of my actions?

• What will the consequences be for my colleagues, SMEC, other

parties and me?

• Would I be happy if I were treated this way?

Employees who fail any of the above tests or have any doubts about
appropriate course of action need to discuss their concerns with their
manager or supervisor or local HR Manager.

Code of Conduct www.smec.com 7 of 9

Reporting a If any Employee becomes aware of any breach or suspected breach of
Contravention or this Code of Conduct (or any procedures to which it refers) or has
Suspected concerns about how it is being applied, the breach, suspected breach or
Contravention of this concern must be reported in the first instance to their supervisor or
Code of Conduct manager.

Where this is not possible or it is inappropriate to do so, the Employee

should contact their Regional Manager or Regional Director.

Reports of suspected contraventions of SMEC’s Business Integrity Policy

or related Procedures should be reported through the reporting channels
in the Business Integrity Policy.

While all Employees are encouraged to raise their concerns, such action
should be genuine and must not be done with mischievous or malicious
intent. Non-genuine concerns raised with mischievous or malicious intent
can be used as grounds for disciplinary action, which may include
dismissal.

Safeguarding Against Retaliation is any direct or indirect detrimental action recommended,

Retaliation threatened or taken against an individual for officially reporting
suspected misconduct in good faith or otherwise cooperating with duly
authorised audits or investigations. SMEC prohibits any such Retaliation
by its Employees.

Retaliation is grounds for disciplinary action, which may include dismissal.

Disciplinary Action for Failing to comply with required behaviours outlined in this Code of
Breaches of the Code Conduct (and the procedures to which it refers) is viewed as a serious
of Conduct matter that must be addressed by management and may lead to
disciplinary action, up to and including termination of employment.
Supervisors and managers will be held accountable not only for their own
conduct, but also for that of their staff.

Where, following an inquiry, SMEC is satisfied that a breach has occurred,

the nature of any disciplinary or other action will be determined by
relevant management, in consultation with other appropriate sources of
advice.

The nature of any action will depend on the seriousness of the breach
and other relevant circumstances. Examples of disciplinary action that
may be taken include a discussion with a manager about desired
behaviour, a verbal or written warning, counselling, transfer to a position
with a lower level of responsibility, suspension and dismissal.

If the situation involves a violation of law, the matter may also be

referred to the appropriate law enforcement authorities for
consideration.

Code of Conduct www.smec.com 8 of 9

 The following misconduct may also result in discipline:

• requesting others to breach this Code of Conduct and/or the

procedures to which it refers;

• failing to raise promptly, known or suspected breaches of this

Code of Conduct and/or the procedures to which it refers;

• failing to co-operate in investigations of possible breaches

regarding your own behaviour;

• failure to demonstrate leadership and diligence to ensure

compliance with this Code of Conduct and the law.

Encouragement of Associated Companies, such as joint ventures, not under SMEC Group
Associated Companies control are strongly encouraged to adopt this Code of Conduct and any
to Adopt this Code of procedure or guideline associated with it.
Conduct

Code of Conduct www.smec.com 9 of 9