Governance, Ethics and Sustainability: Code of Conduct Report

This report presents a comprehensive Code of Conduct tailored for Retail Food Group, addressing critical aspects of governance, ethics, and sustainability. The report meticulously examines key areas including discrimination, exploitation, corruption, dishonest and fraudulent behavior, whistleblower protections, and enforcement mechanisms. It draws upon recent news articles, legislation, and examples from company codes of conduct such as Wesfarmers, Stockland, and Woolworths to inform its recommendations. The analysis delves into the legal and ethical implications of each area, offering practical guidelines and policies to ensure compliance and promote a responsible corporate culture. The report incorporates a minimum of fifteen references, with at least five sourced from academic journals and textbooks to support its arguments and recommendations. The Code of Conduct aims to provide a framework for Retail Food Group to uphold ethical standards, protect its stakeholders, and maintain a strong reputation.

GOVERNANCE, ETHICS AND
SUSTAINABILITY

Contents
Introduction...........................................................................................................................................2
Discrimination.......................................................................................................................................2
Exploitation...........................................................................................................................................3
Corruption.............................................................................................................................................4
Dishonest with the fraudulent behaviour...............................................................................................5
Whistle-blower protections....................................................................................................................6
Enforcement..........................................................................................................................................6
Conclusion.............................................................................................................................................7
References.............................................................................................................................................9

Introduction
Each company complies that it is the responsibility of everyone to follow the laid down rules
and regulations in the code of conduct. A code of conduct results into a disciplinary action
and also the termination of employment. If a person has been working for Aldi as a contractor
or one has been employed by any another company but still working for Aldi and the group
then the employee has to comply with some guidelines and principles (Australia Government,
2019).
Aldi is a German family owned supermarket chain in 20 countries over 10000 stores with a
combined sales turnover of nearly 50 billion euros. Aldi has first opened its store in Sydney,
2001 where it has grown rapidly by maintaining a market share of 12.6 percent in 2016.
Recently, the company has expanded its product portfolio by offering, easy to prepare meal,
specialisation in the staple food, discount pricing and other sanitary articles. The employees
of the company are expected to adopt the code of conduct in order to set guiding policies and
principles in the code (Australia Government, 2019).
Discrimination
Workplace discrimination against job applicants could lead to unfavourable on the basis of
race, colour, sex, disability, age, religion and national origin. There is a legislation based on
anti-discrimination laws and Fair Work Act, 2009. The law was implied when it was seen
different types of work behaviour at the workplace and being an employer, he will have to
prevent the discrimination, bullying, and harassment at workplace (Parliament of Australia,
2019). Other law implies Equal Pay Act, 1963 protects women, and men who actually
perform equal work from wage discrimination on the basis of sex (Australia Government,
2019). Other act of civil right Act, 1964 that prevents employee discrimination on the basis of
nationality, origin, race, religion, and sex. Discrimination can be based on indirect

discrimination as referred as “disparate impact,” where it applies to condition but at the same
time, it can be disadvantageous to particular group and unreasonable in every situation
(Parliament of India, 2019).
Aldi follows the prohibition based on discrimination in relation to employment, which is well
established and featured of Australian legal environment (Westgarth, 2017). Law prohibiting
the level of discrimination at workplace in Australia back to 1966 as South Australia has
introduced Prohibition of discrimination Act, 1966 in order to prohibit discrimination based
on race in the aspects of employment and provisions of goods. Every state and other
territories have led to the introduction of protections overlapping and extending protection
affordable under the federal regime. Aldi ensures that any of the employee does not face any
kind of harassment based on race, and sexuality. Racial harassment can be verbal, written,
and physical act that is purely based on individual colour, features, nationality, nationality,
which remain unwanted and offensive to person closely relating to the same person (Labour
Exploitation Accountability Hub, 2019). Sexual harassment leads to undue welcome, and
conducting offensive action based on sexual component.
Exploitation
The Australian government have been continuously relating to the concerns relating to risk of
labour exploitation especially in regards to the migrant workers. In order to combat this
exploitation, it can be related to exerting control while increasing the vulnerability to certain
modern offences and other exploitation (Labour Exploitation Accountability Hub, 2019).
This framework will examine to address some of the important concerns as being introduced
in UK complying to combat with Slavery exploitation. Migrant workers are vulnerable to
slavery exploitation so there are some legal protection in regards to domestic workforce. The
role of the labour exploitation are subject to series of territories inquiries (Victorian Equal
opportunity & human rights commission, 2019). The committee strongly support Australian

government measures in order to address the exploitation by improvements in order to
strengthen Australia`s response while relating to improve visa protections and conditions,
information and awareness and licensing hiring organisations (Holden, 2018). Aldi has taken
the responsibility where it is risk-based approach exercising through auditing the high risk
because it is practically not implied that resources will be sufficient in order to support audits
while addressing the issue on the structural level (Tunley, Whittaker, Gee, and Button, 2015).
It will provide education on the obligation and rules, as it does not address few reasons where
people often remain in exploitation work nature such as debt, powerlessness, shame, and fear
(Bormann, 2018).
Corruption
Aldi personnel should not engaging with the activities relating to the bribery, facilitating
payments, and money laundering (Tunley, Whittaker, Gee, and Button, 2015). These
activities is a contradiction to the principles of integration and fairness, which is harmful to
the reputation of Wesfarmers among suppliers, shareholders, customers, and the investment
community (Bormann, 2018). The company has to comply with all the laws against
corruption in jurisdiction as Aldi operate (Parliament of Australia, 2019). The company
should not accept any kind of bribes, similar payments, kickbacks, and irregular payment to
attain success and induce business decisions in the favour of Aldi (Bormann, 2018). Aldi
personnel must not accept any kind of offer and gifts in regards to entertainment and
hospitability in regards to the moderate value as per the usual practises of business
(Parliament of Australia, 2019). As per the Aldi`s anti-bribery policy, gifts, entertainment and
hospitality are not acceptable. Any kind of political donations cannot be done at divisional or
business unit level (Tunley, Whittaker, Gee, and Button, 2015). The company must take
steps to ensure that third party has been dealing on the behalf of the Aldi, which do not
engage any conduct and contravention relating to code of conduct and anti-bribery policy

(Tunley, Whittaker, Gee, and Button, 2015). They must ensure that every business dealing
must accurately document to the reflection of true nature of business transaction. All the
dealings and business actions with the government officers relating to Aldi and its business
actions. It must ensure that it is conducted with utmost professionalism so that it could avoid
several perceptions while attaining advantage in any form (Draper, Ibezim, and Newton,
2017).
Dishonest with the fraudulent behaviour
The law states that an organisation should engage in honest and professional business
relationships. Aldi must not deal, pass, and communicate any kind of inside information
when looking at the possession of inside data in relation to securities (Draper, Ibezim, and
Newton, 2017). Aldi personnel hold both securities under Aldi`s share plan and securities
trading policy while dealing with Aldi`s securities must be aware and complying with the
rules and regulations of the plans (Tunley, Whittaker, Gee, and Button, 2015). Aldi complies
and commits to competition and consumer Act (CCA) in the country where it is equivalent to
the legislations in jurisdiction of Aldi operates. The main aim of CCA is to maintain and
promote fair competition at the marketplace (Draper, Ibezim, and Newton, 2017). In order to
protect the consumers, it is important to deal in business as inequality in relation to the
bargaining power. It is important to note that there is a need to store and handle its data to
ensure that there should be accomplishment with the legal obligations and also prevent the
documents for several historical reasons (Cruz, DAVIDSON, and TAYLOR, 2019).
Aldi is committed to protect the data complying with government legislations, government
privacy, customer privacy, and its personal information that has been stored, updated,
handled, and with line to private policy of the division, corporate office and the business unit
(Cruz, DAVIDSON, and TAYLOR, 2019).

Whistle-blower protections
This protection ensures whether the employee is treated well as per the value diversity,
respect and within a safe business environment. Aldi does not bear any types of unlawful
discrimination, whistle-blowing, harassment and also other unacceptable conducts (Raff, and
Earnhart, 2019). Aldi tries to create such environment where they support each other by
working collaboratively. It will ensure that company does not unlawfully differ against
bullying, harassment of other colleague (Draper, Ibezim, and Newton, 2017). Creating safe
working environment and making such an environment, which is based on merit and their
performance (Raff, and Earnhart, 2019). The company will avail safe working environment
and complying with local and mandatory laws in relation to safety at workplace (Raff, and
Earnhart, 2019). The company strictly prohibits the misuse of company`s property, funds,
services and facilities for any of the authorised goals not for any personal benefit and any
other benefit from the unauthorised third party (Wollner, 2019). Any transaction and disposal
related to Wesfarmers property should be approved by top-level management and it has been
recorded in the financial recordings (Raff, and Earnhart, 2019).
Aldi`s personnel can report health and safety issues that takes the responsibility for safety for
reporting health and other safety issues (Campana, and Varese, 2016). It has to abide by
many health and safety policies as abided by Aldi`s policies constructed on following safety
instruction (Wollner, 2019). Aldi make sure that no body smokes near the business divisions,
activity, premises, and sponsored function (Campana, and Varese, 2016).
Enforcement
All the directors and the employees of Aldi are expected to act in a consistent manner with
given principles. It should act with honesty, fairness, integrity and accountable for the
decisions (Campana, and Varese, 2016). It is important to observe the responsibilities to the
financial market and shareholders. It acts will comply with the laws, policies and procedures

which do not receive improper payment (Shields, and Letourneau, 2015). For the
enforcement, every improper action on the behalf of employees should lead to imposition of
penalty so that respect, confidentiality, and maintenance of private information with accurate
business records (Shields, and Letourneau, 2015). Treating many employees with respect,
and diversity with safe environment. Identification and managing the conflicting interests
should be done fairly. It is seen that the Australian government introduced Fair work
Amendments in 2017 in the parliament, which is amended form of 2009 (Shields, and
Letourneau, 2015). This amendment will address underpayments with other methods of
exploitation as identified in several corporate companies (Campana, and Varese, 2016). If
any employee or Aldi itself could not comply with any of the laid down rules and regulations
then as per this bill, several actions can be taken-
Introduction of higher penalties for any serious contraventions related to workplace laws,
addressing several concerns and imposition of civil penalties relating to FW act (Parliament
of Australia, 2019). Earlier, clarification and prohibition relating to cash back arrangement
where employers need to make certain payments (Pinson, 2018). Aldi complies with zero
tolerance policies towards the illegal drug possession, misuse of prescription drugs, whether
it is there at the company`s premises while conducting businesses on the behalf of Aldi and
other sponsored activities (Shields, and Letourneau, 2015).
Conclusion
From the above discussion, it can be seen that Aldi has been truthfully complying with the
laid down Australian laws in regards to corruption, enforcement, dishonest with fraudulent
behaviour, exploitation, discrimination, and whistle blowing protections, which are laid down
in modified Fair Act, 2017. The government has released that the Fair Act, 2009 was not
enough to control the unethical corporate actions. Australian immigrant workers have
suffered a lot due to exploitation, wage payment, dishonesty, whistle blowing, and

discrimination. Aldi`s shareholders, employees, and management are needed to maintain high
standards of code of conduct. Government relations, securities trading, human rights, fraud
corruption, diversity, and anti-competitive behaviour have supported this code of conduct.
This is inclusive of whistleblowing, safety, and work health. Aldi follows corporate
governance policies relating to risk management, privacy, dispute resolution, and certain
principles.

References
Australia Government, (2019) Rights, restrictions and help. Available on:
https://immi.homeaffairs.gov.au/visas/working-in-australia/work-rights-and-exploitation
[Accessed on: 26/08/2019]
Bormann, A., 2018. Dealing with digital social networks: The German"
Netzwerkdurchsetzungsgesetz"(Network Enforcement Act)-A challenging balance between
combating hate crimes and protecting the freedom of expression. Bulletin of the Transilvania
University of Braşov, Series VII: Social Sciences and Law, 11(2-Suppl), pp.25-30.
Campana, P. and Varese, F., 2016. Exploitation in human trafficking and
smuggling. European Journal on Criminal Policy and Research, 22(1), pp.89-105.
Cruz, K., DAVIDSON, J.O.C. and TAYLOR, J.S., 2019. Tourism and sexual violence and
exploitation in Jamaica: contesting the ‘trafficking and modern slavery’frame. Journal of the
British Academy, 7(s1), pp.189-214.
Draper, M.J., Ibezim, V. and Newton, P.M., 2017. Are Essay Mills committing fraud? An
analysis of their behaviours vs the 2006 Fraud Act (UK). International Journal for
Educational Integrity, 13(1), p.3.
Holden, J.T., 2018. The Unlawful Internet Gambling Enforcement Act and the exemption for
fantasy sports. J. Legal Aspects Sport, 28, p.97.
Labour Exploitation Accountability Hub, (2019) National context. Available on:
https://accountabilityhub.org/country/australia/ [Accessed on: 26/08/2019]
Parliament of Australia, (2019) Labour exploitation and Australia's visa framework.
Available on:
https://www.aph.gov.au/Parliamentary_Business/Committees/Joint/Foreign_Affairs_Defence

_and_Trade/ModernSlavery/Final_report/section?id=committees%2Freportjnt
%2F024102%2F25425 [Accessed on: 26/08/2019]
Pinson, M.H., 2018. Caught in the Act: Law-Enforcement Feedback on Video Surveillance
Recordings. IEEE Consumer Electronics Magazine, 8(1), pp.82-86.
Raff, Z. and Earnhart, D., 2019. The effects of Clean Water Act enforcement on
environmental employment. Resource and Energy Economics, 57, pp.1-17.
Shields, R.T. and Letourneau, E.J., 2015. Commercial sexual exploitation of children and the
emergence of safe harbor legislation: implications for policy and practice. Current psychiatry
reports, 17(3), p.11.
Tunley, M., Whittaker, A., Gee, J. and Button, M., 2015. The Fraud Act 2006 and fraud
related legislation. The Accredited Counter Fraud Specialist Handbook, p.17.
Victorian Equal opportunity & human rights commission, (2019) Sexual harassment in the
workplace. Available on:
https://www.humanrightscommission.vic.gov.au/the-workplace/sexual-harassment-at-work
https://accountabilityhub.org/country/australia/ [Accessed on: 26/08/2019]
Westgarth, C. C., (2017) How Australia is combatting worker exploitation. Available on:
https://www.lexology.com/library/detail.aspx?g=7915aa86-7b25-4913-8fcf-cd13be602ca2
[Accessed on: 26/08/2019]
Wollner, G., 2019. Anonymous exploitation: non-individual, non-agential and
structural. Review of Social Economy, 77(2), pp.143-162.