Code of conduct

A code of conduct is a set of rules outlining the responsibilities of or proper practices for an
individual or organization. Related concepts include ethical codes and honor codes.

In its 2007 International Good Practice Guidance, "Defining and Developing an Effective Code
of Conduct for Organizations", the International Federation of Accountants[1] provided the
following working definition:

"Principles, values, standards, or rules of behavior that guide the decisions, procedures
and systems of an organization in a way that (a) contributes to the welfare of its key
stakeholders, and (b) respects the rights of all constituents affected by its operations."

Ethical code
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"Code of ethics" redirects here. For the band, see Code of Ethics (band).

An ethical code is adopted by an organization in an attempt to assist those in the organization

called upon to make a decision (usually most, if not all) understand the difference between 'right'
and 'wrong' and to apply this understanding to their decision. The ethical code therefore
generally implies documents at three levels:

Contents

• 1 Code of ethics (corporate or business

ethics)
• 2 Code of conduct (employee ethics)
• 3 Code of practice (professional ethics)
• 4 General notes
• 5 Examples
• 6 See also
• 7 References

• 8 External links

Code of ethics (corporate or business ethics)

A code of ethics: A code of ethics often focuses on social issues. It may set out general
principles about an organization's beliefs on matters such as mission, quality, privacy or the
environment. It may delineate proper procedures to determine whether a violation of the code of
ethics has occurred and, if so, what remedies should be imposed. The effectiveness of such codes
of ethics depends on the extent to which management supports them with sanctions and rewards.
Violations of a private organization's code of ethics usually can subject the violator to the
organization's remedies (such as restraint of trade based on moral principles). The code of ethics
links to and gives rise to a code of conduct for employees.

Code of conduct (employee ethics)

A code of conduct is a document designed to influence the behavior of employees. They set out
the procedures to be used in specific ethical situations, such as conflicts of interest or the
acceptance of gifts, and delineate the procedures to determine whether a violation of the code of
ethics occurred and, if so, what remedies should be imposed. The effectiveness of such codes of
ethics depends on the extent to which management supports them with sanctions and rewards.
Violations of a code of conduct may subject the violator to the organization's remedies which can
under particular circumstances result in the termination of employment.

Code of practice (professional ethics)

A code of practice is adopted by a profession or by a governmental or non-governmental

organization to regulate that profession. A code of practice may be styled as a code of
professional responsibility, which will discuss difficult issues, difficult decisions that will often
need to be made, and provide a clear account of what behavior is considered "ethical" or
"correct" or "right" in the circumstances. In a membership context, failure to comply with a code
of practice can result in expulsion from the professional organization. In its 2007 International
Good Practice Guidance, Defining and Developing an Effective Code of Conduct for
Organizations, the International Federation of Accountants [1] provided the following working
definition: "Principles, values, standards, or rules of behavior that guide the decisions,
procedures and systems of an organization in a way that (a) contributes to the welfare of its key
stakeholders, and (b) respects the rights of all constituents affected by its operations."

General notes

Ethical Codes are often not adopted by management because of some over-riding corporate
mission to promote a particular moral theory but accepted by management as pragmatic
necessities in running an organization in a complex society in which moral concepts inevitably
play an important part.

They are distinct from moral codes that may apply to the culture, education, and religion of a
whole society.

Of course, certain acts that constitute a violation of ethical codes may also violate a law or
regulation and can be punishable at law or by government agency remedies.

Even organizations and communities that may be considered criminal may have their own ethical
code of conduct, be it official or unofficial. Examples could be hackers, thieves, or even street
gangs.
Examples

• Code of Conduct for the International Red Cross and Red Crescent Movement
and NGOs in Disaster Relief
• Code of the U.S. Fighting Force
• Declaration of Geneva
• Eight Precepts
• Ethic of reciprocity (Golden Rule)
• Five Precepts
• Hippocratic Oath
• ICC Cricket Code of Conduct
• Institute of Internal Auditors, Code of Ethics
• International Code of Conduct against Ballistic Missile Proliferation (ICOC or
Hague Code of Conduct)
• Journalist's Creed
• Moral Code of the Builder of Communism
• Patimokkha
• Pirate code of the Brethren
• Israel Defense Forces - Code of Conduct
• Rule of St. Benedict
• Silver Rule
• Thomas Percival
• Ten Commandments
• Ten Indian commandments
• Ten Precepts (Buddhism)
• Ten Precepts (Taoism)
• Warrior code
• Bushidō
• Uniform Code of Military Justice
• Members' Code of Conduct
• Aviators Model Code of Conduct

CODE OF ETHICS

This Code of Ethics is a statement of the ethical principles, values and behaviours expected of
staff and students at The University of Western Australia. It flows from the following statement
in the University’s Strategic Plan:

The University fosters the values of openness, honesty, tolerance, fairness and responsibility in
social and moral, as well as academic, matters.

The Code of Ethics is intended to assist staff and students to identify and resolve ethical issues
that might arise during their employment or in the course of their studies. It is designed to guide
them in their dealings with colleagues, students, the University, and local, national and
international communities. The Code of Ethics puts forward a set of general principles rather
than detailed prescriptions. It stands beside, but does not exclude or replace, the rights and
obligations of staff and students under common law or legislation. The Code of Conduct then
provides more specific information about the University’s policies, rules and expectations based
on these principles.

The University is a complex organisation comprising diverse groups that have different
relationships to one another. These may be relations of power and/or status. It is essential in such
a community that all members recognise and respect not only their own rights and
responsibilities, but also the rights and responsibilities of other members of the community and
those of the University itself.

The University recognises that many of its staff are also bound by codes of conduct or ethics
defined by learned or professional societies or groups. Staff may have multiple allegiances: to
their disciplines or profession at national and international levels (the invisible colleges), to the
academic profession, to the community at large and to the University. Staff and students may
also have allegiances to particular religious or cultural traditions. It is recognised that these
allegiances are not always in harmony. It is an obligation of a staff member or student to weigh
the importance of these allegiances in each particular set of circumstances and to notify an
appropriate officer of the University where such conflict does or may arise.

The Code of Ethics is based on three universal ethical principles. These are:

Equity and Justice

People are to be treated fairly – not discriminated against, abused or exploited. Justice is
concerned with power sharing and preventing the abuse of power. In a just community all
members can access opportunities that allow for their full participation in that community.

Respect for People

People should be treated as individuals with rights to be honoured and defended. Respect
empowers others to claim their rights and to achieve their potential. Respect for the rights of
other people is the basis on which individuals become members of a community and accept their
social responsibilities to behave with integrity.

Membership of a community means that individuals not only have rights but also duties and
responsibilities to others to act openly and honestly. Demonstrating respect for persons requires,
for example, dealing with disagreements by reasoned argument rather than by using language
(words, style and tone) that have the effect of inappropriately attacking or demeaning the
listener.

Personal and Professional Responsibility

The principle of taking personal and professional responsibility requires not only that people
avoid doing harm to others but that they exhibit courteous behaviour upholding the standards
expected of all members of the University community as part of achieving a common good. In so
doing they are expected to protect the rights of others and respect the diversity of cultures and
peoples. Those well-positioned to assert their rights have a reciprocal duty to exercise care
towards those who depend on them for their well-being. This principle involves stewardship of
assets, resources and the environment.

When a conflict arises between a staff member’s or student’s self-interest and duty to the
University, the issue should be disclosed to an appropriate officer of the University. Wherever
feasible the staff member or student should not play a role in decision-making that might be
associated with that issue.

The Code of Ethics underpins a Code of Conduct that outlines the actions or procedures
applicable to employees and students at The University of Western Australia for a range of
specific ethical issues.

CODE OF CONDUCT

The Code of Conduct is based on principles, values and behaviours outlined in the Code of
Ethics. This Code applies to all staff and students of the University. Contractors, their employees
and representatives, and visitors engaging in any University-related activity are expected to
conduct themselves in a manner consistent with this Code.

The Code of Conduct underlines:

• The rights of employees to be treated fairly and equitably in the workplace;

• Avenues for resolving complaints or breaches of policies and Codes; and
• The legal and ethical obligations and expectations of all students and staff to
act in accordance with the expressed standards of conduct, integrity and
accountability contained in relevant legislation, University policies and
Agreements.

The objectives of the Code are to:

• Provide direction to staff and students around expected conduct whilst

affiliated with the University;
• Assist staff and students in dealing with ethical issues in ways that reflect the
University’s values and standards;
• Promote professionalism and excellence;
• Express shared assumptions and organisational values;
• Provide staff and students with direction in ethically ambiguous situations;
• Detail the University’s social responsibilities; and
• Provide a statement on public accountability and corporate governance.

The Code does not supersede other policies or agreements that The University of Western
Australia has in place. Appendix 1 contains a list of Acts relevant to the Code of Conduct, and
reference is made to relevant University policies and agreements throughout this document.
Appendix 2 provides a list of contact positions for further information on specific matters
contained in the Code of Ethics and Code of Conduct.

The Code of Conduct does not and cannot cover every possible situation. You can, however, test
yourself on whether your behaviour is ethical by asking yourself three questions:

• Would I be happy to have what I am saying or doing appear on the front page
of the newspaper?
• Does what I am saying or doing serve a purpose beyond self-interest?
• Would I like to be spoken to or treated in this way?

Members of this University should be aware that any breach of this Code may result in
disciplinary action being taken.

1. Equity and Justice

The University has adopted the following Equal Opportunity Policy Statement:

The University of Western Australia is committed to a policy of equal opportunity in employment

and education. The University accepts that it has a responsibility to create an environment free
from discrimination, and to ensure that the principle of merit operates unhindered by regard to
irrelevant criteria. To this end the University will act to ensure that its structures are free from
direct or indirect discrimination on the grounds of sex, marital status or pregnancy, race, age,
sexual orientation, gender identity, religious or political beliefs, impairment, family
responsibility or family status. (Senate 1993, amended 2002)

Equal Opportunity and Affirmative Action Policy Statement

1.1 Equity of access to employment and programs

The University is committed to providing an environment of equal opportunity, free from

discrimination, for existing and prospective staff and students in the pursuit of their academic
and professional goals and the realisation of their potential to contribute to the achievement of
the University’s mission. This objective is supported by an employment philosophy of providing
job security through ongoing employment where possible, and encouraging flexible work
practices that accommodate a range of needs in a diverse workforce. The University seeks to
remove any barriers that may impede full access to the benefits and conditions of employment
and the delivery of University services.

Flexible Work and Leave Practices Policy

The UWA Disability Access and Inclusion Action Plan 2007-2011

Policy and Procedures for Dealing with Equity Enquiries and Grievances

1.2 Harassment

The University is committed to maintaining a campus culture of inclusivity and respect.

Harassment of any form such as sexism, racism or bullying has no place in such a culture, as it
denies respect for the rights of staff and students to fair treatment. Harassment can be extremely
detrimental to the University’s effectiveness as an institution of higher learning, as an employer,
and as a responsible organisational and community citizen. Harassment is contrary to the
principles developed in the University’s Code of Conduct and to the University Equal
Opportunity policy. It may also be unlawful.

Discrimination

Under Equal Opportunity legislation, discrimination occurs when a person, or a group of people,
are treated less favourably than another person or group, in the same or similar circumstances,
because of irrelevant attributes including their age; race, colour, descent, national or ethnic
origin; sex; marital status, pregnancy, or family responsibilities; disability; political or religious
conviction; or sexual orientation or gender history.

Indirect discrimination occurs when an apparently neutral requirement, condition or rule has a
negative effect on a substantially higher proportion of people with a particular attribute or
characteristic (for example, race) compared to people without that attribute or characteristic, and
the rule or requirement is not reasonable in the circumstances.

In addition to the University policies on Equal Opportunity, Conduct in the Workplace, Racial
Harassment and Sexual Harassment, the University is bound by legislation which makes
discrimination unlawful. This legislation includes the WA Equal Opportunity Act, Disability
Services Act and Lesbian and Gay Law Reform Act, Commonwealth Age Discrimination Act,
Disability Discrimination Act, Disability Standards for Education Act, Equal Opportunity for
Women in the Workplace Act, Racial Discrimination Act and Sex Discrimination Act.

Equity and Diversity Lectopia: Workplace Discrimination Series

Bullying

Due to the effect on the safety and health of employees and others at the workplace, violence,
aggression and bullying are unacceptable under the Occupational Safety and Health Act.
WorkSafe Western Australia advises that bullying in the workplace should be treated like any
other workplace hazard. Bullying is a term used to describe behaviour that undermines an
individual’s right to dignity and respect at work. At The University of Western Australia it is
also used to describe similar inappropriate behaviour towards or from a student. Bullying
behaviour can be described as:
The repeated less favourable treatment of a person by another or others on the campus, which
may be considered unreasonable and inappropriate practice. It includes behaviour that
intimidates, offends, degrades, threatens or humiliates. (Conduct in the Workplace Policy)

The general 'duty of care' provisions embedded in legislation apply to all staff, and every
employee must be aware of their duty not to place the safety and health of others at risk by
engaging in violence, aggression or bullying behaviour. This behaviour contravenes the ethical
values underpinning the University’s Code of Ethics and is addressed in the University’s
Conduct in the Workplace Policy. Bullying behaviour will not be condoned by the University
and sanctions will apply to any staff member or student who is found to have bullied another
member of the University community.

Conduct in the Workplace Policy

Statute 17 Student Discipline and Regulations for Student Conduct and Discipline

Equity and Diversity Lectopia: Workplace Bullying Prevention Series

Racial Harassment

Racial harassment is any verbal, physical or written act which is based on a person’s colour,
physical characteristics, descent, country of origin, ethnic background or nationality, and is
unwanted, unacceptable and offensive to the person, or those related to, or closely associated
with, that person. The WA Equal Opportunity Act and Commonwealth Racial Discrimination
Act make racial harassment in employment and education unlawful. Racial harassment conflicts
with the University’s Equal Opportunity and Affirmative Action Policy and with the rights of all
staff and students to receive fair and equitable treatment.

Racial harassment is a serious issue that undermines morale and can adversely affect the ability
of staff and students to achieve their full potential within the University. Such behaviour is
unacceptable and all complaints will be dealt with fairly and promptly. Sanctions will apply to
any staff member or student who is found to have racially harassed another member of the
University community.

Racial Harassment

Sexual Harassment

Sexual harassment is any form of conduct of a sexual nature that is unwanted. Such conduct can
be in the form of words or actions. Sexual harassment is not about sexual attraction: it is about
inappropriate and unacceptable behaviour towards a member of the University’s staff or student
body, or towards a visitor to the University.

Sexual harassment conflicts with the University's Equal Opportunity Policy and denies respect
for the rights of staff and students to fair treatment. Under the WA Equal Opportunity Act and
the Commonwealth Sex Discrimination Act, sexual harassment in employment and education is
unlawful.

Sexual harassment is a serious issue that undermines morale and can adversely affect the ability
of staff and students to achieve their full potential within the University. Such behaviour is
unacceptable and all complaints will be dealt with fairly and promptly. Sanctions will apply to
any staff member or student who is found to have sexually harassed another member of the
University community.

Sexual Harassment

Charter of Student Rights and Responsibilities

Equity and Diversity Lectopia: Introduction to Sexual Harassment in the Workplace

1.3 Academic Freedom

Academic freedom is recognised and protected by this University as essential to the proper
conduct of teaching, research and scholarship. Freedom of intellectual thought and enquiry and
the open exchange of ideas and evidence are a UWA core value. All academic and research staff
should be guided by a commitment to freedom of inquiry and exercise their traditional rights to
examine social values and to criticise and challenge the belief structures of society in the spirit of
a responsible and honest search for knowledge and its dissemination. In this context students
have the right to participate in political activities on campus. (See also 3.8 Public Comment)

1.4 Union Membership

University staff and students have the right to choose whether or not to join a trade union or
association. Similarly, those who choose to join may also choose whether or not to participate in
union activities.

1.5 Lawful Obedience

All members of the University must act lawfully, comply with all relevant legislative and
industrial requirements, act within their delegations of authority, and comply with University
policies. See the list of the relevant Acts at Appendix 1.
2. Respect for People

2.1 Confidentiality

Staff members who have access to official University documentation and information must take
care to maintain the integrity, confidentiality and privacy of such information to protect any
individual concerned. Members of the University should also undertake to maintain the privacy
of oral communications where that has been requested.

Staff files are highly confidential records relating to staff members. It is essential that staff
members feel confident that information relating to them is treated in an appropriate manner,
with due attention paid to the need for non-disclosure of file contents outside normal University
business transactions. Staff must take care to respect the confidentiality and privacy of students
and only provide information when authorised by the Registrar’s Office or for legitimate
purposes.

Access to and Use of Staff Files

Professional and Consultative Work: Policy Requirements

About the Freedom of Information Act

2.2 Complaints

Staff and students of this University are entitled to fair and equitable complaint procedures. The
University has a number of avenues for assistance with complaints and disputes, depending on
their nature. These include the Equity and Diversity Adviser Scheme, Employee Relations and
Management Services, Equity and Diversity, Complaints Resolution, and the UWA Student
Guild. Contact details are listed in Appendix 2.

Complaints Policy and Procedures

Procedures for Settlement of Grievances (Academic Staff)

Grievance Settlement Procedures (Professional Staff)

Dispute Settling and Grievance Procedures (ELICOS Teachers)

Dispute Settling Procedures (Childcare Employees)

Policy and Procedures for Dealing with Equity and Diversity Enquiries and Grievances

Code of Good Practice for Graduate Research Supervision

Charter of Student Rights and Responsibilities

2.3 Intellectual Property

Intellectual Property is recognised by this University and stipulates that the benefits should
provide equitable returns to the originators of intellectual property, both as an incentive and
reward, as well as to the University. Regulations provide for the ownership of intellectual
property created by students and staff of the University. Intellectual Property includes inventions
and copyright in various types of work.

University Policy on: Intellectual Property

3. Personal and Professional Responsibility

3.1 Fraud and Corruption

The University Policy on Fraud and Corruption, in conjunction with the Guidelines for Dealing
with Fraud and Corruption at UWA, clarifies the responsibilities of all University staff in
creating an honest, ethical and professional workplace, and outlines the requirements and
protocols for raising issues of suspected fraud and corruption and the conducting of
investigations, including referral to the Corruption and Crime Commission of Western Australia.

Fraudulent and corrupt conduct generally involves behaviour that is deliberately dishonest or
deceitful and involves the abuse of trust which leads to a person gaining a benefit from these
types of actions. The Guidelines for Dealing with Fraud and Corruption at UWA may assist in
identifying activities considered as fraudulent or corrupt conduct within the University.
Examples include unauthorised use of University property, undeclared conflicts of interest,
falsifying or manipulating research data, misrepresenting a person’s involvement in
research/projects, or making false claims of expenses or leave entitlements.

Employees at all levels within the University have a duty to report any act or situation that may
be suspected as fraudulent or corrupt as soon as they are aware of these circumstances. If you
believe that a person is involved in fraudulent or corrupt activities, you should follow the
University’s normal channels for reporting misconduct. However in some circumstances, or if
you are afraid of repercussions, it may be necessary to raise an issue directly with a senior
manager, or one of the University’s Public Interest Disclosure Officers to discuss the matter. See
3.2 below for further information and Appendix 2 for contact details.

University Policy on: Fraud and Corruption

3.2 Public Interest Disclosure

The University is bound by the WA Public Interest Disclosure Act which permits complaints
about University staff to be investigated on a protected and, if necessary, anonymous basis.
Because the University falls under this Act, staff and students who report such behaviour to one
of the University’s Public Interest Disclosure Officers are provided with protection for doing so.
Those who are alleged to have committed corrupt or other improper behaviour are also protected
by the Act’s provisions on confidentiality. The UWA Public Interest Disclosure Officers are the
Director of Legal Services, Director of Human Resources, and Manager, Complaints Resolution.
Contact details are in Appendix 2.

3.3 Ethical Conduct of Research

The University expects all those engaged in research to observe high ethical standards in the
conduct of that research and, when relevant, to comply with the obligations imposed by the
codes of practice as outlined by the relevant funding bodies. Ethical clearances must be gained
where appropriate.

Guidelines on Research Ethics and Research Conduct

3.4 Use of University Facilities and Equipment

Members of the University are expected to use all University facilities and equipment efficiently,
carefully and honestly. Resources should be used economically, secured against theft or misuse
and waste avoided. These resources should not be used for personal purposes unless express
permission has been granted in accordance with University policy.

University Finance Manual, Equipment Management

Professional and Consultative Work: Policy Requirements

University Information Technology and Communications Policies

Sustainability Operation Action and Policy

3.5 Information Technology

The University places a high value on integrity, professionalism and respect for others. While the
University does permit moderate use of UWA IT facilities for private use, members of the
University must be particularly conscious of these values when accessing the internet, sending
and receiving email, and using social networking sites. Inappropriate use of information
technology, in particular, accessing or disseminating offensive material via the internet or email
contravenes University Regulations and may be unlawful. The University has formally adopted a
number of IT Policies and, unless otherwise indicated, they are binding upon all members of and
visitors to the University. Disciplinary action may apply to staff or students found in breach of
the University’s IT Policies and the Computer and Software Use Regulations.

University Information Technology Regulations

University Information Technology and Communications Policies

Email Policy

3.6 Risk Management

Risk Management is a formal process for identifying, analysing, evaluating and treating the
uncertainty associated with any activity, process, function or service undertaken by the
University. Formal Risk Management aids decision-making by taking account of uncertainty and
the effect this may have on achieving the University’s objectives. It is an integral part of day to
day operations and is an important element of effective internal control. Managers and staff at all
levels are responsible for developing an understanding of and becoming competent in the
implementation of risk management principles and practices in their work areas. ISO 31000 is
the international standard which guides the University’s approach to risk management.

Risk Management Division

3.7 Conflicts of Interest

A conflict of interest includes any circumstance, whether actual or perceived, arising from
conflict between the performance of public duty and private or personal interests. It arises where
there is a reasonable expectation of direct or indirect benefit or loss for an individual employee
with a particular personal interest that could be influenced in favour of that interest, in the
performance of their duties. The benefit or loss may be financial or non-financial.

Staff members should take suitable measures to avoid, or appropriately deal with, any situation
or relationship in which they may have, or be seen to have, a conflict of interest that could,
directly or indirectly, compromise the performance of their duties. When staff members become
aware of such a situation they should take appropriate steps to disclose the conflict or potential
conflict. Failure to do so and continuation of such a conflict of interest will lead to disciplinary
action.
The following questions may assist in identifying whether a situation or relationship is
potentially a conflict of interest:

• Do I have personal or private interests that may conflict, or be perceived to

conflict, with my public duty?
• Could there be benefits for me now, or in the future, that could cast doubt on
my objectivity?
• How will my involvement in the decision or action be viewed by others?
• Does my involvement appear fair and reasonable in all the circumstances?

Research Conduct

Disclosure of any potential conflict of interest is essential for the responsible conduct of
research. Researchers have an obligation to disclose any affiliation with, or financial
involvement in, any organisation or entity with a direct interest in the subject matter or materials
of researchers. A conflict of interest may also arise if any organisation or entity with a direct
interest in the subject matter provides direct benefits to the researchers such as sponsorship of the
investigation, or indirect benefits such as the provision of materials or facilities, or the support of
individuals such as provision of travel or accommodation expenses to attend conferences.

Guidelines on Research Ethics and Research Conduct

Professional and Personal Relationships

Examples of relationships that may cause conflicts of interest are: family relationships, positive
and negative emotional relationships (including all sexual relationships, antagonisms, close
friendships), and financial relationships, including sponsorships.

Professional Relationships in the University of Western Australia: Workplace Policy

Employment of Close Relatives

The employment of relatives is only acceptable when the appointment is made in line with
University policy regarding appointment of new employees. Prior approval must be sought from
the Dean, or Executive Director where a staff member is required to directly supervise a relative.
A member of staff should not take any direct part in the selection process for an appointment for
which a family member is a candidate. The relationship to which this policy applies includes
those of parent and child, wife and husband, including de-facto relationships, same sex partners
and siblings.

Employment of Close Relatives

Outside Employment and Private Practice

Professional and consultative work carried out by members of staff in their area of expertise may
be of benefit to the University, the individual and the community, provided certain conditions are
met. Professional and consultative work should be related to the work of the University and
should not conflict with the interests of the University. Consulting is a privilege not a right and
requires approval by the Head of School or equivalent.

Professional and Consultative Work: Policy Requirements

Private Practice

Procurement

It is the responsibility of every staff member of the University involved in the supply of goods or
services, to or for the University, to declare in writing all relevant interest that the staff member
may have in any proposed transaction.

In particular, those staff who deal directly with suppliers must:

• Ensure that their processes are open and transparent;

• Not engage in misleading or deceptive conduct;
• Not transact with suppliers for private or unauthorised use; and
• Not compromise the University’s standing or integrity of its purchasing
activities through the acceptance of gifts or hospitality.

All Business Units should ensure that employees and their agents are aware of the requirements
to not disclose confidential information and to properly manage the information they receive as
part of the procurement process.

In the event of doubt or perceptions of conflict, further advice should be sought from Strategic
Procurement. (See also Gifts or Benefits and Hospitality below).

University Finance Manual, Expenditure Policy

Conflicts of Interest in University Business

Professional and Consultative Work: Policy Requirements

Gifts or Benefits

Staff members should not solicit, encourage or accept gifts or benefits if it could be reasonably
seen as an inducement to act in a particular way, or to place a staff member under an obligation
that may either directly or indirectly compromise or influence them in their official capacity. In
particular, University employees should indicate to the prospective givers that gifts cannot be
accepted from those with whom the University has, or potentially has, commercial dealings.

Gifts of a nominal value (under $100) used for promotional purposes by the donor, or ones in
accordance with social or cultural practice are acceptable. Staff members who receive small gifts
or tokens of appreciation may retain those items as personal property or donate them to the
University. Substantial gifts and benefits received by staff members should be declared to the
relevant Dean or Executive Director.
As a general guide, expenditure may be authorised on floral tributes, small gifts and other tokens
of appreciation for guest speakers and important official visitors; on retirement or resignation of
a staff member; and in the event of serious illness or death of a staff member, or other person
with an identifiable relationship with the University.

University Finance Manual, Floral Tributes, Small Gifts and Tokens of Appreciation

Hospitality

The University recognises that the provision of hospitality can result in significant benefits to the
institution through promoting its activities. The extension of hospitality by University staff in the
furtherance of University objectives is therefore regarded as a legitimate professional activity.
Hospitality is defined as the provision of meals or refreshments to persons who are visiting the
University for business reasons, tourist activities and entertainment events which relate to the
activities of the University, and light refreshments for internal meetings, conferences, workshops
and seminars.

Appropriate occasions for the provision of hospitality at functions attended only by University
staff include celebration of a notable achievement by a staff member or a group of staff,
farewells to retiring staff, training programmes, and recognised festivals such as Christmas.
Hospitality may only be authorised by Deans, Heads of School and equivalent staff with
delegated authority. It is their responsibility to determine the nature and extent of hospitality
provided. In all cases there is an expectation of ‘reasonableness’ which is established in the
University Finance Manual.

University Finance Manual, Hospitality Expenditure Policy

3.8 Public Comment

Public comment includes public speaking engagements, comments on radio or television, and
expressing views in letters to newspapers or in books, journals or notices, or where it might be
expected that the publication or circulation of the comment may spread to the community at
large, such as through social networking websites.

Staff members are encouraged to comment publicly in relation to their area of professional
expertise. When staff members are representing the University the highest ethical and
professional standards are expected of them primarily due to the sensitivity of some issues within
the community.

Staff members in their capacity as private citizens have a right to make public comments. If a
staff member is publicly commenting on an issue not within their professional expertise, the staff
member must make it clear that the comment is being made in a private capacity.

Guidelines on Public Comment by University Staff

3.9 Professional Development

All staff must maintain and develop knowledge and understanding of their area of expertise or
professional field. They should continuously seek to improve work performance with an
emphasis on quality skills. All staff should actively seek out ways to bring about improvements
in their workplaces. Students should endeavour to take full value of their learning opportunities
while at The University of Western Australia.

Golden rules to Professional code of conduct

The workplace is a home away from home where individuals build, nurture and sometimes even end
relationships. It is not surprising to know that most important deals that are to remain within confide doors
are laughed upon over a cup of coffee in the cafeteria by juniors because of the strong grapevine that
floats in companies.

Most of the times the employees become so comfortable with what is happening around them that they
become lazy and start detesting change. A workplace must be a place that talks about professionalism in
all fronts. It must be a place where every employee feels safe, respected, and responsible for his acts and
feel secure.

An organization is made of different kinds of people with different nature. At times what one would like the
other would not. A topic might not be offending for one but might be the biggest embarrassing factor for
the other. Since it is always difficult to identify and draw a line, its best to avoid certain topics altogether.

The golden rules of professional code of conduct must be designed to help employees avoid behavior
that might be looked down upon by the others. Rules of professional code of conduct:

• Respect for all: The minimum professional behavior expected from employees is to respect all
who work n the company, irrespective of the level they are in.
• Respect difference of opinion: Since no two employees are the same. Hence, they must keep
their egos out of the office premise and respect the other one's point of view.
• Comply to policies and procedures: The best example to share would be the in and out log
time. To depict professional behavior employees must depend full eight to nine hours in the
office. Only take scheduled breaks
• Contribute qualitative on productivity.
• Behave within the legal boundaries of the professional code of conduct.
• Avoid all topics related to religion, especially when he has a team of heterogeneous mix.
• Must not voice his opinion in public about what he does not like about the organization. The best
way would be to go the grievance department and settle it theirs.
• Avoid all assorts of sexual harassment conducts like

1. Commenting and looking at someone or his/her specific body parts.

2. Commenting about sexual activity
3. Getting gender different in the organization and spoiling the atmosphere
 4. Narrating adult and sexual jokes

• Be helpful to co-workers
• Must come well dressed to the office & must comply to all kinds of etiquette
• Must not over commit to the cuter and under deliver both in terms of quality and against time.
• Must stay away from Eve and Adam teasing and overhearing of conversations
• Must not share passwords and comply to other security norms
• Must never sell company information to outsiders.
• No fraudulent related to past experience, past salary package and generation of fake bills

Every employee must be trained on corrective and preventive actions that can have an alarming effect not
only on him but also on the organization he/she works for.

Tata Code of Conduct

This comprehensive document serves as the ethical road map for Tata
employees and companies, and provides the guidelines by which
the group conducts its businesses.
Clause 1 Clause 2 Clause 3 Clause 4 Clause 5

Clause 6 Clause 7 Clause 8 Clause 9 Clause 10

Clause 11 Clause 12 Clause 13 Clause 14 Clause 15

Clause 16 Clause 17 Clause 18 Clause 19 Clause 20

Clause 21 Clause 22 Clause 23 Clause 24 Clause 25

Clause:1
National interest
The Tata group is committed to benefit the economic development of the countries in which it
operates. No Tata company shall undertake any project or activity to the detriment of the wider
interests of the communities in which it operates.
A Tata company’s management practices and business conduct shall benefit the country,
localities and communities in which it operates, to the extent possible and affordable, and shall
be in accordance with the laws of the land.

A Tata company, in the course of its business activities, shall respect the culture, customs and
traditions of each country and region in which it operates. It shall conform to trade procedures,
including licensing, documentation and other necessary formalities, as applicable.

Clause:2
Financial reporting and records
A Tata company shall prepare and maintain its accounts fairly and accurately and in accordance
with the accounting and financial reporting standards which represent the generally accepted
guidelines, principles, standards, laws and regulations of the country in which the company
conducts its business affairs.

Internal accounting and audit procedures shall reflect, fairly and accurately, all of the company’s
business transactions and disposition of assets, and shall have internal controls to provide
assurance to the company’s board and shareholders that the transactions are accurate and
legitimate. All required information shall be accessible to company auditors and other authorised
parties and government agencies.There shall be no willful omissions of any company
transactions from the books and records, no advance-income recognition and no hidden bank
account and funds.

Any willful, material misrepresentation of and / or misinformation on the financial accounts and
reports shall be regarded as a violation of the Code, apart from inviting appropriate civil or
criminal action under the relevant laws. No employee shall make, authorise, abet or collude in an
improper payment, unlawful commission or bribing.

Clause:3
Competition
A Tata company shall fully support the development and operation of competitive open markets
and shall promote the liberalisation of trade and investment in each country and market in which
it operates. Specifically, no Tata company or employee shall engage in restrictive trade practices,
abuse of market dominance or similar unfair trade activities.

A Tata company or employee shall market the company’s products and services on their own
merits and shall not make unfair and misleading statements about competitors’ products and
services. Any collection of competitive information shall be made only in the normal course of
business and shall be obtained only through legally permitted sources and means.
Clause:4
Equal opportunities employer
A Tata company shall provide equal opportunities to all its employees and all qualified
applicants for employment without regard to their race, caste, religion, colour, ancestry, marital
status, gender, sexual orientation, age, nationality, ethnic origin or disability.

Human resource policies shall promote diversity and equality in the workplace, as well as
compliance with all local labour laws, while encouraging the adoption of international best
practices.

Employees of a Tata company shall be treated with dignity and in accordance with the Tata
policy of maintaining a work environment free of all forms of harassment, whether physical,
verbal or psychological. Employee policies and practices shall be administered in a manner
consistent with applicable laws and other provisions of this Code, respect for the right to privacy
and the right to be heard, and that in all matters equal opportunity is provided to those eligible
and decisions are based on merit.

Clause:5
Gifts and donations
A Tata company and its employees shall neither receive nor offer or make, directly or indirectly,
any illegal payments, remuneration, gifts, donations or comparable benefits that are intended, or
perceived, to obtain uncompetitive favours for the conduct of its business. The company shall
cooperate with governmental authorities in efforts to eliminate all forms of bribery, fraud and
corruption.

However, a Tata company and its employees may, with full disclosure, accept and offer nominal
gifts, provided such gifts are customarily given and / or are of a commemorative nature. Each
company shall have a policy to clarify its rules and regulations on gifts and entertainment, to be
used for the guidance of its employees.

Clause:6
Government agencies
A Tata company and its employees shall not, unless mandated under applicable laws, offer or
give any company funds or property as donation to any government agency or its representative,
directly or through intermediaries, in order to obtain any favourable performance of official
duties. A Tata company shall comply with government procurement regulations and shall be
transparent in all its dealings with government agencies.

Clause:7
Political non-alignment
A Tata company shall be committed to and support the constitution and governance systems of
the country in which it operates.

A Tata company shall not support any specific political party or candidate for political office.
The company’s conduct shall preclude any activity that could be interpreted as mutual
dependence / favour with any political body or person, and shall not offer or give any company
funds or property as donations to any political party, candidate or campaign.

Clause:8
Health, safety and environment
A Tata company shall strive to provide a safe, healthy, clean and ergonomic working
environment for its people. It shall prevent the wasteful use of natural resources and be
committed to improving the environment, particularly with regard to the emission of greenhouse
gases, and shall endeavour to offset the effect of climate change in all spheres of its activities.

A Tata company, in the process of production and sale of its products and services, shall strive
for economic, social and environmental sustainability.

Clause:9
Quality of products and services
A Tata company shall be committed to supply goods and services of world class quality
standards, backed by after-sales services consistent with the requirements of its customers, while
striving for their total satisfaction. The quality standards of the company’s goods and services
shall meet applicable national and international standards.

A Tata company shall display adequate health and safety labels, caveats and other necessary
information on its product packaging.

Clause:10
Corporate citizenship
A Tata company shall be committed to good corporate citizenship, not only in the compliance of
all relevant laws and regulations but also by actively assisting in the improvement of quality of
life of the people in the communities in which it operates. The company shall encourage
volunteering by its employees and collaboration with community groups.

Tata companies are also encouraged to develop systematic processes and conduct management
reviews, as stated in the Tata ‘corporate sustainability protocol’, from time to time so as to set
strategic direction for social development activity.
The company shall not treat these activities as optional, but should strive to incorporate them as
an integral part of its business plan.

Clause:11
Cooperation of Tata companies
A Tata company shall cooperate with other Tata companies including applicable joint ventures,
by sharing knowledge and physical, human and management resources, and by making efforts to
resolve disputes amicably, as long as this does not adversely affect its business interests and
shareholder value.

In the procurement of products and services, a Tata company shall give preference to other Tata
companies, as long as they can provide these on competitive terms relative to third parties.

Clause:12
Public representation of the company and the group
The Tata group honours the information requirements of the public and its stakeholders. In all its
public appearances, with respect to disclosing company and business information to public
constituencies such as the media, the financial community, employees, shareholders, agents,
franchisees, dealers, distributors and importers, a Tata company or the Tata group shall be
represented only by specifically authorised directors and employees. It shall be the sole
responsibility of these authorised representatives to disclose information about the company or
the group.

Clause:13
Third party representation
Parties which have business dealings with the Tata group but are not members of the group, such
as consultants, agents, sales representatives, distributors, channel partners, contractors and
suppliers, shall not be authorised to represent a Tata company without the written permission of
the Tata company, and / or if their business conduct and ethics are known to be inconsistent with
the Code.

Third parties and their employees are expected to abide by the Code in their interaction with, and
on behalf of, a Tata company. Tata companies are encouraged to sign a non-disclosure
agreement with third parties to support confidentiality of information.

Clause:14
Use of the Tata brand
The use of the Tata name and trademark shall be governed by manuals, codes and agreements to
be issued by Tata Sons. The use of the Tata brand is defined in and regulated by the Tata Brand
Equity and Business Promotion agreement. No third party or joint venture shall use the Tata
brand to further its interests without specific authorisation.

Clause:15
Group policies
A Tata company shall recommend to its board of directors the adoption of policies and
guidelines periodically formulated by Tata Sons.

Clause:16
Shareholders
A Tata company shall be committed to enhancing shareholder value and complying with all
regulations and laws that govern shareholder rights.The board of directors of a Tata company
shall duly and fairly inform its shareholders about all relevant aspects of the company’s business,
and disclose such information in accordance with relevant regulations and agreements.

Clause:17
Ethical conduct
Every employee of a Tata company, including full-time directors and the chief executive, shall
exhibit culturally appropriate deportment in the countries they operate in, and deal on behalf of
the company with professionalism, honesty and integrity, while conforming to high moral and
ethical standards. Such conduct shall be fair and transparent and be perceived to be so by third
parties.

Every employee of a Tata company shall preserve the human rights of every individual and the
community, and shall strive to honour commitments.

Every employee shall be responsible for the implementation of and compliance with the Code in
his / her environment. Failure to adhere to the Code could attract severe consequences, including
termination of employment.

Clause:18
Regulatory compliance
Employees of a Tata company, in their business conduct, shall comply with all applicable laws
and regulations, in letter and spirit, in all the territories in which they operate. If the ethical and
professional standards of applicable laws and regulations are below that of the Code, then the
standards of the Code shall prevail.
Directors of a Tata company shall comply with applicable laws and regulations of all the relevant
regulatory and other authorities. As good governance practice they shall safeguard the
confidentiality of all information received by them by virtue of their position.

Clause:19
Concurrent employment
Consistent with applicable laws, an employee of a Tata company shall not, without the requisite,
officially written approval of the company, accept employment or a position of responsibility
(such as a consultant or a director) with any other company, nor provide freelance services to
anyone, with or without remuneration. In the case of a full-time director or the chief executive,
such approval must be obtained from the board of directors of the company.

Clause:20
Conflict of interest
An employee or director of a Tata company shall always act in the interest of the company, and
ensure that any business or personal association which he / she may have does not involve a
conflict of interest with the operations of the company and his / her role therein. An employee,
including the executive director (other than independent director) of a Tata company, shall not
accept a position of responsibility in any other non-Tata company or not-for-profit organisation
without specific sanction.

The above shall not apply to (whether for remuneration or otherwise):

a) Nominations to the boards of Tata companies, joint ventures or associate companies.
b) Memberships / positions of responsibility in educational / professional bodies, wherein such
association will benefit the employee / Tata company.
c) Nominations / memberships in government committees / bodies or organisations.
d) Exceptional circumstances, as determined by the competent authority.

Competent authority, in the case of all employees, shall be the chief executive, who in turn shall
report such exceptional cases to the board of directors on a quarterly basis. In case of the chief
executive and executive directors, the Group Corporate Centre shall be the competent authority.

An employee or a director of a Tata company shall not engage in any business, relationship or
activity which might conflict with the interest of his / her company or the Tata group. A conflict
of interest, actual or potential, may arise where, directly or indirectly…
a) An employee of a Tata company engages in a business, relationship or activity with anyone
who is party to a transaction with his / her company.
b) An employee is in a position to derive an improper benefit, personally or to any of his / her
relatives, by making or influencing decisions relating to any transaction.
c) An independent judgement of the company’s or group’s best interest cannot be exercised.
The main areas of such actual or potential conflicts of interest shall include the following:
a) An employee or a full-time director of a Tata company conducting business on behalf of his /
her company or being in a position to influence a decision with regard to his / her company’s
business with a supplier or customer where his / her relative is a principal officer or
representative, resulting in a benefit to him / her or his / her relative.
b) Award of benefits such as increase in salary or other remuneration, posting, promotion or
recruitment of a relative of an employee of a Tata company, where such an individual is in a
position to influence decisions with regard to such benefits.
c) The interest of the company or the group can be compromised or defeated.

Notwithstanding such or any other instance of conflict of interest that exist due to historical
reasons, adequate and full disclosure by interested employees shall be made to the company’s
management. It is also incumbent upon every employee to make a full disclosure of any interest
which the employee or the employee’s immediate family, including parents, spouse and children,
may have in a family business or a company or firm that is a competitor, supplier, customer or
distributor of or has other business dealings with his / her company.

Upon a decision being taken in the matter, the employee concerned shall be required to take
necessary action, as advised, to resolve / avoid the conflict.

If an employee fails to make the required disclosure and the management of its own accord
becomes aware of an instance of conflict of interest that ought to have been disclosed by the
employee, the management shall take a serious view of the matter and consider suitable
disciplinary action against the employee.

Clause:21
Securities transactions and confidential information
An employee of a Tata company and his / her immediate family shall not derive any benefit or
counsel, or assist others to derive any benefit, from access to and possession of information
about the company or group or its clients or suppliers that is not in the public domain and, thus,
constitutes unpublished, price-sensitive insider information.

An employee of a Tata company shall not use or proliferate information that is not available to
the investing public, and which therefore constitutes insider information, for making or giving
advice on investment decisions about the securities of the respective Tata company, group, client
or supplier on which such insider information has been obtained.

Such insider information might include (without limitation) the following:

• Acquisition and divestiture of businesses or business units.

• Financial information such as profits, earnings and dividends.
• Announcement of new product introductions or developments.
• Asset revaluations.
• Investment decisions / plans.
• Restructuring plans.
 • Major supply and delivery agreements.
• Raising of finances.

An employee of a Tata company shall also respect and observe the confidentiality of information
pertaining to other companies, their patents, intellectual property rights, trademarks and
inventions; and strictly observe a practice of non-disclosure.

Clause:22
Protecting company assets
The assets of a Tata company shall not be misused; they shall be employed primarily and
judiciously for the purpose of conducting the business for which they are duly authorised. These
include tangible assets such as equipment and machinery, systems, facilities, materials and
resources, as well as intangible assets such as information technology and systems, proprietary
information, intellectual property, and relationships with customers and suppliers.

Clause:23
Citizenship
The involvement of a Tata employee in civic or public affairs shall be with express approval
from the chief executive of his / her company, subject to this involvement having no adverse
impact on the business affairs of the company or the Tata group.

Clause:24
Integrity of data furnished
Every employee of a Tata company shall ensure, at all times, the integrity of data or information
furnished by him/her to the company. He/she shall be entirely responsible in ensuring that the
confidentiality of all data is retained and in no circumstance transferred to any outside
person/party in the course of normal operations without express guidelines from or, the approval
of the management.

Clause:25
Reporting concerns
Every employee of a Tata company shall promptly report to the management, and / or third-party
ethics helpline, when she / he becomes aware of any actual or possible violation of the Code or
an event of misconduct, act of misdemeanour or act not in the company’s interest. Such reporting
shall be made available to suppliers and partners, too.

Any Tata employee can choose to make a protected disclosure under the whistleblower policy of
the company, providing for reporting to the chairperson of the audit committee or the board of
directors or specified authority. Such a protected disclosure shall be forwarded, when there is
reasonable evidence to conclude that a violation is possible or has taken place, with a covering
letter, which shall bear the identity of the whistleblower.

The company shall ensure protection to the whistleblower and any attempts to intimidate him /
her would be treated as a violation of the Code.