It is the policy of the Company to comply fully with the Trade Practices Act 1974 and other fair trading legislation applicable to its operations. The Company is committed to the public policy goals embodied in these laws which include the protection and promotion of competition and free enterprise.

Non-compliance with trade practices law can expose individuals involved in the contravention to personal liability and substantial penalties. The Company may also be exposed to substantial criminal and civil penalties.

The Company is committed to observing, and ensuring that its employees observe obligations arising under trade practices legislation regarding:

• Restrictive trade practices (including price fixing and exclusionary provisions resulting in a division of territories).
• Market sharing (including allocation of customers), anti-competitive agreements, exclusive dealing and misuse of market power.
• Communication and promotion (including misleading or deceptive conduct, false claims and unsubstantiated predictions).
• Conscionable and fair business practices.
• Service, quality and safety.

The Company is committed to providing employees with appropriate resources and adequate education, training and operating procedures to facilitate compliance with trade practices legislation and the avoidance of both personal and corporate liability. The Company expects all employees to make proper use of the resources, education, training and procedures provided for the purposes of discharging legal obligations arising under trade practices legislation and avoiding both personal and corporate liability.

Non-compliance with trade practices legislation will be considered as sufficient grounds for disciplinary action, up to and including immediate termination of employment and may also be grounds for legal action by the Company. Employees breaching trade practices legislation will receive no financial or other support from the Company. Only employees who make genuine mistakes, or who follow advice from the Company’s legal advisor, will be supported by the Company in relation to any breach of trade practices legislation.

If a complaint is substantiated, you will be consulted in relation to a range of outcomes including:

• A written apology
• A disciplinary warning to the perpetrator
• Counselling
• Disciplinary action directed at the perpetrator, up to and including dismissal.