Corporate Governance and Ethics: Code of Conduct

This document discusses the code of conduct for corporate governance and ethics, focusing on topics such as discrimination, exploitation, corruption, and fraudulent behavior. It emphasizes the importance of creating a healthy and ethical work environment. The code applies to all employees and stakeholders of the organization.

CORPORATE
GOVERNANCE AND
ETHICS

CODE OF CONDUCT 1
Introduction and applicability of the code of conduct
The code of conduct is the framework of the ethical guidelines and policies for the conduct of
the efficient business by the entity 7 Eleven. The aim of the following code of the conduct is
to lay down the principles that are in line with the various statutory regulations namely the
Corporations Act, 2001 (Cth), Australian Accounting Standards, and the applicable
regulatory requirements of the Australian Stock Exchange. These are in addition to the other
such regulations that are applicable on the entity, as per the nature of the business that is the
convenience stores chains. The following code of the conduct shall be applicable on all the
employees and the members of the management of the entity. In addition, the code of the
conduct is also applicable on the stakeholders while entering into the business relationships
with the company. Thus, the stakeholders like suppliers, service providers, external
professionals, agents, customers and others are expected to conduct the business within the
ambit of the legal and ethical requirements, to maintain the spirit and the main objectives of
the entity 7 Eleven.
Discrimination
The entity believes that the greatest strength and assets of the organisation are the employees.
As a result, the entity believes that every employee deserves the opportunity to work and
grow in an environment that is healthy and free of any sorts of discrimination and
harassment. In respect to the above belief, the entity has laid down certain guidelines, which
are on the lines of the Fair Work Act 2009 (Cth). These guidelines must be followed in
addition to the federal and the state anti-discrimination laws of the respective branch of the
organisation.
The Equal Opportunity Act 2010 states that the discrimination at the workplace can take
place on the lines of physical, cultural, or other such attributes (Victorian Equal Opportunity
and Human Rights Commission, 2018a). Some of the primary personal characteristics which
lead to the initiation of the discriminatory behaviour are the religious belief, origin, race,
mental or physical disability, age, parental status, marital status, colour, physical features,
nationality, sex, industrial activity, employment activity, political belief, and others (Cox and
Knoth, 2017).
Some forms of activities that the individuals can engage in which refer to the discrimination
are the treating co-worker badly because of the differences in the religious beliefs, marking
promotions or appraisals because of the cultural and ethnic similarities, hiring at job based on
the gender, race or nationality and other such activities (Roberts, Davies and Jupp, 2014). The
discriminatory acts also include the offering of the unfair terms and conditions during the
recruitment or the hiring procedures (Australian Human Rights Commission, 2018).
Thus, the entity is committed at ensuring that the workplaces are free from the discriminatory
behaviours, the examples of which are provided above. It is the responsibility of the
employees as well as the members of the organisation to create an environment that is based
on the pillars of mutual respect, dignity, cooperation, tolerance, and are free from personal
biases and unhealthy relationships (Fair Work Commission, 2018). If any employee or the

CODE OF CONDUCT 2
member is found to be engaged in above-mentioned practices, disciplinary actions shall
follow, as described in the last segment of this code.
Exploitation
The harassment or exploitation can be verbal, physical, or even the visual behaviour
(Victorian Equal Opportunity and Human Rights Commission, 2018b). The behaviour is
injurious to the policies and spirit of the company objectives as it results in the creation of an
offensive and intimidating environment at the workplace. The acts of exploitation, bullying,
or harassment are capable of violating one’s dignity and thereby creating a humiliating
environment for one another.
Some of the examples of the harassing acts are the passing of the threatening remarks,
Causing physical injury to another, causing someone else to fear injury or verbal abuse,
carrying weapons at the stores, coercing or forcing behaviour on customers or other
employees at the workplace, stalking someone and more such acts.
The harassment also includes the sexual harassment (Einarsen et. al, 2010). Sexual
harassment occurs when there is a request for unwelcomed sexual behaviour, in
circumstances like the condition of the employment, or the continuity of the same, or in the
cases of the employment evaluations (Austlii, 2018). The intimidating environment based on
sexual harassment can be created because of acts like passing on obscene comments,
offensive jokes and or insulting physical or verbal behaviour (Booth and Leigh, 2010).
As per the definition laid down in Fair Work Amendment Act, 2013, any reasonable
behaviour that is being consistently posed towards an individual, which is harmful in terms of
health and safety, is called as bullying (Australian Government, 2018).
The entity is committed to abide by the regulations like Racial Discrimination Act 1975, Sex
Discrimination Act 1984, Disability Discrimination Act 1992, and other such regulations.
Any exploitation or bullying, which is based on the above-mentioned disabilities would be
liable to disciplinary action.
Some examples of the acts that are referred to as bullying and exploitation are as follows.
Excluding certain employees, screaming, not providing sufficient information for an
assignment given, isolating disabled employees are certain examples (Disabled World, 2018).
Corruption
The Corruption and Crime Commission defines corruption as the conduct that involves an
improper and deliberate intention while performing the official functions, and thus involves
the use of dishonesty (Corruption and Crime Commission, 2018). The ASX 200 principles
also state that corruption and bribery are the major factors that unfavourably impact the
success and goodwill of an enterprise.
The bribery is referred to as the acts of influencing a person to avail a certain business
advantages, which will not be available otherwise (Cubbage and Brooks, 2016). The
employees and stakeholders must be careful of entering into inducing arrangements and
behaviour towards one another.

CODE OF CONDUCT 3
The entity accords the above principle and follows a zero tolerance policy towards the issues
of corruption and bribery. The entity expects that all the stakeholders, employees, and
members are expected to be aware of the anti- corruption and anti-bribery laws, in every
business transactions. In response to this, employees must be careful while accepting or
offering improper payments bribe or such incidental payments.
The members of the organisation are expected to perform their duties with due diligence,
integrity, and utmost honesty, in order to provide the best products and services (Gaze and
Smith, 2016).
Some of the examples of corrupt behaviour are extending unusual requests for the payments
to the third parties belonging to different countries, especially in cash (Loudon, McPhail and
Wilkinson, 2015). This also includes the requesting arrangements with no written records,
requesting or providing extra commission or the fees, without supporting documents. The
request for donation, gift, or any other business courtesy and entertainment are referred to as
the examples of the corruption and bribery (Vickers, 2014).
Thus, it is the duty of the members, employees and the stakeholders to not to engage in the
above-mentioned activities and others that fall in the framework of corruption. The breach of
the same would result in the disciplinary action being initiated that has been explained in the
enforcement section of the code. In addition to the above, the entity is committed towards the
compliance of the anti- money laundering laws. Therefore, the employees must be aware of
the persons or transactions, the proceeds of which are related to activities of criminal and
illegal nature.
Dishonest and Fraudulent Behaviour
The fraudulent behaviour generally includes placing of individual interests over the interest
of the entity (Zgheib, 2014). The entity accords its belief and expects the employees and
members to never engage into the activities like fraud, misrepresentation to obtain and pass
on the information to the competitors or third parties. Some examples of other fraudulent
activities are non-disclosure or confidentiality agreements, entering into third party
agreements while on employment with the entity, asking employees to discuss information
pertaining to the previous employment, and many such activities. The list is not exhaustive
and therefore employees must be aware all the times, to maintain the integrity of the
profession and performing the duties to the best of the manner.
The failure to exercise the honest and ethical behaviour while at the premise, or the stores of
the entity would result in the imposing of the disciplinary actions.
Whistle-blower Protections
Any employee who wish to disclose or bring into light the activities if any, occurring or
taking place at the organisation can do so, and the same are most welcome. The employees
and members must be aware of the fraudulent and illegal activities that detriment the
objectives of the organisation 7 Eleven. The issue may be related to any of the principles
mentioned in the previous parts of the code. The reporting must be done as per the framework
provided for the same.

CODE OF CONDUCT 4
It is duty of the managers and the leaders, to provide adequate support and assistance to bring
forth the issues and concerns for the entity. It must be noted that the entity has employed the
Whistle-blower Protection Officer (WPO) and the Whistle-blower Investigations Officer
(WIO) as part of the reporting framework. While the former is responsible for the compliance
with the legal rules, and the consultations with the financial and other experts, the latter is
responsible for the conducting investigations. The investigating officer is also responsible
towards the collection of the evidences, conducting interviews and consulting third parties.
Thus, the officer should conduct the investigations until the same is regarded as baseless.
The reporting can be done through the mail, call or posts, at the contact details provided in
the latter part of the code.
Enforcement
In addition to the above, the employees must follow the basic dress code guidelines,
information technology guidelines, and the non-engagement in alcoholism, smoking and
littering while in the stores or the other workplace. In addition, the required records,
documents and vouchers must be prepared and maintained to comply with the accounting
frameworks.
The disciplinary action can be one or more of the following. The penalties may be levied, the
initial warning would be given. This would be followed by the actions like enquiry,
investigations, trials, demotion, withholding of promotion, termination of services, and other
as per the discretion of the management, depending upon the concern and the intensity of the
situation.
The abidance of the code of conduct falls in the terms and conditions of the employment and
are the mandatory part of the employment. Thus, every employee is required to comply with
the above five principles of the code of conduct.

CODE OF CONDUCT 5
References
Austlii. (2018) Sex Discrimination Act 1984. [online] Available from:
http://www5.austlii.edu.au/au/legis/cth/consol_act/sda1984209/index.html [Accessed on
01/01/19].
Australian Government (2018) Fair Work Amendment Act 2013. [online] Available from:
https://www.legislation.gov.au/Details/C2013A00073 [Accessed on 01/01/19].
Australian Human Rights Commission (2018) Workplace discrimination, harassment and
bullying. [online] Available from: https://www.humanrights.gov.au/employers/good-practice-
good-business-factsheets/workplace-discrimination-harassment-and-bullying [Accessed on
01/01/19].
Booth, A. and Leigh, A. (2010) Do employers discriminate by gender? A field experiment in
female-dominated occupations. Economics Letters, 107(2), pp. 236-238.
Corruption and Crime Commission (2018) What is Corruption? [online] Available from:
https://www.ccc.wa.gov.au/what-is-corruption [Accessed on 01/01/19].
Cox, M. and Knoth, J. (2017) Australia: 4 Examples of Workplace Discrimination - MDC
Legal. [online] Available from:
http://www.mondaq.com/australia/x/566138/employee+rights+labour+relations/
4+Examples+of+Workplace+Discrimination+MDC+Legal [Accessed on 01/01/19].
Cubbage, C. J., and Brooks, D. J. (2016) Corporate Security in the Asia-Pacific Region:
Crisis, Crime, Fraud, and Misconduct. United States: CRC Press.
Disabled World. (2018) Australian Disability Discrimination Act Information. [online]
Available from: https://www.disabled-world.com/disability/australia/ [Accessed on
01/01/19].
Einarsen, S., Hoel, H., Zapf, D. and Cooper, C. (2010) Bullying and harassment in the
workplace: Developments in theory, research, and practice. United States: CRC Press.

CODE OF CONDUCT 6
Fair Work Commission. (2018) Anti-bullying. [online] Available from:
https://www.fwc.gov.au/disputes-at-work/anti-bullying [Accessed on 01/01/19].
Gaze, B., and Smith, B. (2016) Equality and Discrimination Law in Australia: An
Introduction. Australia: Cambridge University Press.
Loudon, R., McPhail, R. and Wilkinson, A. (2015) Introduction to Employment Relations.
Australia: Pearson Higher Education AU.
Roberts, C., Davies, E. and Jupp, T. (2014) Language and discrimination. UK: Routledge.
Vickers, M. H. (2014) Towards reducing the harm: Workplace bullying as workplace
corruption—A critical review. Employee Responsibilities and Rights Journal, 26(2), pp. 95-
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Victorian Equal Opportunity & Human Rights Commission. (2018) Discrimination –
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workplace/workplace-discrimination [Accessed on 01/01/19].
Victorian Equal Opportunity and Human Rights Commission. (2018a) Discrimination –
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workplace/workplace-discrimination [[Accessed on 01/01/19].
Victorian Equal Opportunity and Human Rights Commission. (2018b) Types of
discrimination [online] Available from:
https://www.humanrightscommission.vic.gov.au/discrimination/discrimination/types-of-
discrimination [Accessed on 01/01/19].
Zgheib, P. W. ed., (2014) Business ethics and diversity in the modern workplace. United
States: IGI Global.

CODE OF CONDUCT 7