Purpose
This code of conduct (Code) applies to all directors and employees (Employees) of Wave Swell Energy Limited (WSE) and its subsidiaries, as well as contractors (Contractors) and consultants (Service Providers).
All Employees, Contractors and Service Providers are required to operate and behave in accordance with WSE values of safety, respect, business excellence, teamwork and accountability.
Scope
Employees, Contractors, and Service Providers must be aware of, and adhere to company policies, especially those relating to health and safety, equal opportunity and privacy. In the course of their duties, they must comply with relevant legislation.
Work Ethic
Employees, Contractors, and Service Providers when conducting business and dealing with suppliers, colleagues, and other stakeholders, must:
- Act with integrity, professionalism and be scrupulous in the use of WSE information, funds, equipment and facilities;
- Exercise fairness, equity, courtesy and consideration in dealing with employees and other stakeholders;
- Avoid real or apparent conflict of interests;
- Promote the interests of WSE;
- Perform their duties with skill, honesty, care, and diligence, using authority in a fair and equitable manner;
- Demonstrate behaviours that align to WSE values of safety, respect, business excellence, teamwork and accountability;
- Abide by the policies, standards, procedures, legislative requirements, instructions, and lawful directions, that relate to their employment and duties; and
- Comply with the spirit as well as the letter of this Code of Conduct.
Health, Safety and Environment
Safety is a core value for WSE and is a core focus in our daily operation and the way we work. A safe workplace means our people are healthy and safe and this includes the health and protection of our environment. Employees, Contractors and Service Providers must comply with health, safety and environmental policies, standards, processes and procedures and any related instructions. These are also referred to as Sustainability and should be used interchangeably in this context. There is also an obligation to report any incident and authority is provided to pause any work where there is a sustainability issue, that is perceived or actual.
Environment
WSE incorporates environmental management into all areas of operations to manage the risks and potential impacts through all cycles of the business. We operate in a socially and environmentally responsible way to deliver on social licence obligations and to strive for leading practice to meet community expectations.
Employees are required to comply with environmental principles and processes at all times.
Communities
WSE operates in and with the co-operation and consent of local communities. In securing the co-operation of communities within which it operates, WSE has undertaken that all of its Employees, Contractors and Service Providers will respect and uphold the values of those local communities.
Employees, Contractors, and Service Providers, when interacting with local communities must:
- Demonstrate respect and courtesy towards each other and members of the local communities;
- Use constructive and inclusive language and not use abusive, offensive, hostile, or aggressive behaviour or use language that may cause offence;
- Cause no damage to community-owned or private facilities that through their connection to WSE, they are privileged to use;
- Abide by all laws, rules and regulations of the community and the local jurisdiction; and
- Generally, avoid any behaviour that could harm WSE’s reputation or relationship with its local communities.
Inclusion and Diversity
WSE is dedicated to growing an inclusive and diverse workforce, aligned with the company’s values of safety, respect, business excellence, teamwork and accountability where every person is treated fairly, feels respected and able to contribute to business success and realise their full potential.
WSE is committed to investing in its people, systems and processes to ensure that the workplace is inclusive and diverse and expect our people to work together to achieve an inclusive culture.
Harassment, Sexual Harassment, Bullying and Discrimination
WSE aims to provide an environment where our people are treated with respect. Harassment, including sexual harassment, bullying or discrimination of any kind is not acceptable in our workplace.
Employees, Contractors, and Service Providers, must never engage in actions or behaviours that entail harassment, (including sexual harassment), bullying or discrimination.
Harassment is an unwelcome action, conduct or behaviour that a reasonable person would find unwelcome, humiliating, intimidating or offensive.
Sexual Harassment is an unwelcome sexual advance or request for sexual favours to the person who is harassed and other unwelcome conduct of a sexual nature in relation to the person who is harassed.
Bullying is a repeated behaviour directed towards an individual or group of individuals that is unreasonable and creates a risk to health, safety and well-being.
Discrimination is making unlawful distinctions between individuals and groups on the basis of any of protected attributes.
Whistle blower Policy
WSE upholds a commitment to a work environment free of unethical, unlawful, or undesirable conduct or practices. Employees are protected and encouraged to raise concerns regarding such conduct in the first instance with a board member of WSE.
Personal Information and Privacy
Information obtained in the course of employment must not be used or disclosed to obtain financial reward or benefit, or to take advantage of another person.
Intellectual Property
Unless governed by law or otherwise agreed in writing, any intellectual property developed by an Employee, Contractor, or Service Provider during or as a result of employment with WSE is the sole property of WSE.
Conflict of Interest
Employees must avoid personal, financial, or other interest which may be in conflict with their duties and responsibilities to WSE.
Any interest which may constitute a conflict of interest must be promptly disclosed to a board member of WSE.
Accepting any external appointment, such as a board appointment (other than to the board of a non trading family company), working for another organisation or conducting a business is not permitted without the written permission of the Chief Executive Officer (CEO), or in the case of the CEO, the Board of WSE.
Bribery and Corruption
Employees must not offer, promise, give, demand, or accept any undue advantage, whether directly or indirectly, to or from:
- A public official
- A political candidate, party, or party official
- A community leader or other person in a position of public trust
- Any private sector employee
in order to obtain, retain or direct business or to secure any other improper advantage in the conduct of business.
Property
Company property, funds, tools, equipment, vehicles, facilities, and services must be used only for authorised purposes.
Communicating Externally
The company’s relationships with the community and media are to be conducted primarily by the CEO, or as delegated by the CEO.
Unless nominated as a WSE spokesperson, Employees, Contractors, and Service Providers are not authorised or permitted to act as an official spokesperson or to comment to the media or in any social media platform on behalf of WSE.
Employees must not disclose WSE Confidential Information to any third party, either verbally or in written form, without the prior consent of the CEO of WSE.
Employees and Contractors must not engage in social media activity that may damage or harm WSE’s reputation.
Gifts and Hospitality
WSE prohibits the giving or receiving of gifts, or invitations involving travel, accommodation and entertainment in circumstances which could be considered to give rise to undue influence. Any gifts should be disclosed to the CEO, or in the case of the CEO, to the Board of WSE.
Breaches of the Code
Employees have a duty to observe this Code and ensure that no breaches occur.
Employees have a duty to report known or suspected breaches of this Code to the CEO, or alternatively in the case of a suspected breach by the CEO, to the Board of WSE.
Any employee, who in good faith, makes a complaint or disclosure about an alleged breach of the Code will not be disadvantaged or prejudiced in the making of such a complaint or disclosure. All reports will be treated as confidential.
Employees found to be in breach of applicable laws, prevailing business ethics or aspects of this Code will be subject to disciplinary action, that may involve termination of employment.