AIRGROUP AUSTRALIA has continuously been dedicated to the principles of ethical and legal business conduct.  As part of the challenges faced on a daily basis, all employees and representatives of AIRGROUP AUSTRALIA will be faced with a variety of ethical challenges.  The concept of ethical considerations often goes beyond the question of what is lawful and it is occasionally difficult to determine whether an action is ethical or not.  This Code is intended to assist employees to address these challenges.


AIRGROUP AUSTRALIA will ensure that all employees receive a personal copy of this Code and be briefed to ensure they fully understand the content and intention of the Code.


It is likely this Code will be revised from time to time due to the changing legal, regulatory and market environments.  The latest version of the Code will be available from the office of the Managing Director.




This Code sets forth policies and procedures governing employee ethics, conflicts of interest, confidential information, and insider trading and related matters.  These business standards provide a general framework of values and obligations that should be adhered to at all times.  These standards guide AIRGROUP AUSTRALIA employee’s professional conduct in regards to actions, words, sense of fairness, honesty, and integrity.


The Code is intended to protect:

  • AIRGROUP AUSTRALIA’s reputation for integrity
  • AIRGROUP AUSTRALIA and its customers’ business interests, and
  • AIRGROUP AUSTRALIA and its employees from legal liability.




AIRGROUP AUSTRALIA’s business is conducted in a lawful and ethical manner, with honesty, integrity, and a firm commitment to comply with all laws.  This and AIRGROUP AUSTRALIA’s values form the fundamental basis for direction as a business and as individuals.


All Company employees / associates are expected to:

  • Be honest and accurate in what they say and write
  • Identify themselves in a professional manner whenever representing AIRGROUP AUSTRALIA
  • Observe and comply with all State and Federal regulations / legislation
  • Act legally, ethically, honestly, and morally at all times.




The Code is general in nature.  If you believe that any situation, action, or activity may be in violation of AIRGROUP AUSTRALIA’s code of conduct guidelines, or you feel you are being asked to compromise your values, it is your responsibility to communicate this to AIRGROUP AUSTRALIA.  You are encouraged to contact any of the Company Directors.





5.1 Laws and Regulations


All AIRGROUP AUSTRALIA’s employees are expected to comply with the laws and regulations of all jurisdictions where AIRGROUP AUSTRALIA conducts its business.  No individual shall encourage another individual to circumvent applicable laws or regulations, nor the rules of honest business conduct, nor shall they condone any such violation.


AIRGROUP AUSTRALIA and its employees will comply with all legal requirements applicable to our business.  Ignorance of the law is not a defence.  Each employee is responsible for understanding the laws that govern his or her work.  Unlawful conduct will not be tolerated.  All employees and representatives of AIRGROUP AUSTRALIA are to ensure that their conduct cannot in any way be interpreted as being in contravention of applicable laws and regulations governing the operations of AIRGROUP AUSTRALIA.


5.2 Dealing with Public Officials


Payments to or gifts for public officials whether direct or indirectly through a third party, are not permitted except under specific circumstances and with proper authority and approvals.  Participation, whether directly or indirectly in any bribe, kickback, contribution or similar payment is prohibited.


When employees participate in personal political activities, they should ensure that it is clear that they are acting on their own behalf and not as a representative of AIRGROUP AUSTRALIA.


5.3 Insider Trading


From time to time, employees or associates will have inside information that may not be known to the general public.  As a general rule, employees or associates who possess non-public information about an issuer of securities, and employees who receive such information should:

Refrain from passing such information on to others and from trading in or recommending the purchase or sale of the issuer’s securities, or

Disclose such information to the investing public.


The above activity is unethical, and in many jurisdictions illegal.  Penalties for violating insider-trading laws can be severe.


Specific confidential information that could be considered material includes unpublished information concerning a significant mineral discovery; operating and financial results, a stock split, a change in dividend policy, a major merger, acquisition or take over bid, or a technical advance of unusual economic significance.


If in any doubt, advice should be sought from the Company Directors.


5.4 Confidential Information


Information regarding the Company’s business, which is gained during employment, must not be passed on to external Parties where such action could be detrimental to the Company, or where it could be used for personal gain.

An employee will not at any time either during his/her employment or after the termination of his/her employment for any reason divulge any of the affairs or secrets of AIRGROUP AUSTRALIA to any other company, person or persons without the consent in writing of the Managing Director, AIRGROUP AUSTRALIA.  Employees may not use or attempt to use any information which he/she may acquire in the course of his/her employment in any manner which may injure or cause loss or be calculated to injure or cause loss to AIRGROUP AUSTRALIA.


An employee shall not make improper use of AIRGROUP AUSTRALIA’s resources or information for personal use or to gain direct or indirect advantage or benefit for the employee or for others. Documents or systems containing confidential information or which could be subject to abuse, e.g. minutes, certificates, reports, cheques, computer data, etc are to be kept secured at all times and seen to be confidential.  Unless there is a “need to know”, this information should be kept out of sight, and not disclosed whether it is at work, home, in public, or elsewhere.


AIRGROUP AUSTRALIA respects and is committed to protecting the privacy of all employees.  AIRGROUP AUSTRALIA is bound by and will comply with the National Privacy Principles as set out in the Privacy Act 1988 and as amended.  AIRGROUP AUSTRALIA will only use personal information regarding employees in accordance with the National Privacy Principles.  AIRGROUP AUSTRALIA will use personal information to provide services to employees, to fulfil administrative functions associated with these services, to enter into contract and for marketing and client relationship purposes.  (See AIRGROUP AUSTRALIA’s Privacy Policy, Appendix 4)


5.5 Conflicts of Interest


All employees are expected to adhere to the highest codes of conduct with respect to conflicts of interest, outside activities, the acceptance of gifts and hospitality, and in all dealings with both AIRGROUP AUSTRALIA’s customers and the public.


To ensure that an employee’s personal interests do not conflict, or appear to conflict, with the interests of AIRGROUP AUSTRALIA or its customers, employees should:

Perform their duties and arrange their private affairs in such a manner that the public’s confidence and trust in the integrity, objectivity and impartiality of AIRGROUP AUSTRALIA and its employees are conserved and enhanced.

Act in a manner that will bear the closest public scrutiny.

Arrange their private affairs in such a manner as to prevent, real, apparent or potential conflicts of interest from arising.

Get AIRGROUP AUSTRALIA Director approval before accepting a directorship or position as an officer or partner in an entity.

Not accept outside employment unless approved by an AIRGROUP AUSTRALIA Director in writing.

Not step out of their official roles to assist private entities or persons in dealings with AIRGROUP AUSTRALIA where this would result in preferential treatment to any such entity or person.


5.5.1 Disclosure and Approvals


On commencing employment with AIRGROUP AUSTRALIA, and thereafter as may be necessary, all employees have to disclose all outside employment or other activities, assets and direct or contingent liabilities, which would or might give rise to a real, apparent or potential conflict of interest with the employee’s duties and responsibilities.

An employee shall not commence participation in outside employment or other business activities unless he/she receives the approval of an AIRGROUP AUSTRALIA Director.  In addition, an employee should discontinue or modify his/her participation in outside activities, if at any time the AIRGROUP AUSTRALIA Directors determine that these activities constitutes a real, apparent or potential conflict of interest; results in a decrease in performance or a decline in the quality of work produced at AIRGROUP AUSTRALIA; affects that employee’s capacity to perform his/her duties and responsibilities objectively and impartially


5.5.2 Gifts and other Benefits


AIRGROUP AUSTRALIA employees or associates will not give or offer, directly or indirectly, anything of significant value to a business associate or government official to influence or reward an action.  The receiving or giving of gifts, hospitality or other benefits will only be permitted if:

They are of a nominal value and within the bounds of propriety, or a nominal expression of courtesy, or within the normal standards of hospitality, or offered generally to the public as part of a promotional plan,

They are not such as to bring suspicion on the employee’s objectivity and impartiality,

They will not compromise the integrity of AIRGROUP AUSTRALIA,

It would not influence the employee in his/her judgment or performance of his/her duties and responsibilities at AIRGROUP AUSTRALIA,

The actions are authorised by AIRGROUP AUSTRALIA Directors.


The solicitation of any gifts, hospitality or other benefits is not permitted.


Employees should note that prohibited gifts and benefits include: cash, goods or services, reduced prices, work performed gratuitously, preferred treatment of any kind in a business enterprise, and loans of money, material or equipment on a preferential basis.


No gift or entertainment should be of such value as to constitute a real personal enrichment of the recipient or to be perceived as such.  Cash or cash value vouchers are not to be given.  Gifts or entertainment given on behalf of AIRGROUP AUSTRALIA should be of such a nature and amount that avoid embarrassment and would not reflect unfavourably on AIRGROUP AUSTRALIA or the recipient, if subjected to public scrutiny.


Acceptance by employees of hospitality in the form of receptions, business luncheons or dinners for the purpose of broadening business contacts or facilitating the discussion of matters of importance to AIRGROUP AUSTRALIA is not prohibited, where such hospitality is clearly within the bounds of propriety and not liable to cast doubt on the employees’ objectivity.


Where it is not possible to decline unauthorised gifts, hospitality or other benefits, or where such action is likely to be construed as discourteous, employees shall immediately report the matter to the AIRGROUP AUSTRALIA Directors who will decide how best to deal with the situation.


 5.5.3 Bribes

Basic criminal statutes of virtually all countries prohibit extortion and bribery.  Under no circumstances shall employees, directly or indirectly accept, offer or give a bribe.


 5.6 Truthfulness

Employees are expected to make all reasonable efforts to avoid errors in, or misunderstandings of, statements made by AIRGROUP AUSTRALIA or its representatives even when omissions or misunderstandings might be to AIRGROUP AUSTRALIA’s short-term advantage.  Particular care must be taken not to make promises or commitments, which AIRGROUP AUSTRALIA does not intend to, or cannot keep.  AIRGROUP AUSTRALIA expects all employees to use only fair and honest negotiating methods and scrupulously avoid any practice that may adversely affect AIRGROUP AUSTRALIA’s reputation for integrity and honesty.

5.7 Substance Abuse


The care, diligence and creative energy that individuals employed by AIRGROUP AUSTRALIA are expected to provide requires that all employees exercise reasonable care in matters concerning their health and well-being.


A safe and productive workplace requires an environment free from the effects of illegal or illicit use of drugs and alcohol.  Employees have an obligation to AIRGROUP AUSTRALIA and their fellow employees to report at their regularly scheduled times fit for their duties.  Therefore, any use, sale, distribution, possession, manufacture, transportation or promotion of illegal drugs or drug paraphernalia, or any sale or transfer of prescription drugs on AIRGROUP AUSTRALIA premises or while conducting AIRGROUP AUSTRALIA business or activities, is strictly prohibited.  In addition, it is strictly prohibited for employees to be impaired by the consumption of alcohol while on AIRGROUP AUSTRALIA premises or sites or while conducting AIRGROUP AUSTRALIA business or activities.


Further, employees are not permitted to consume alcohol while on AIRGROUP AUSTRALIA premises or while conducting AIRGROUP AUSTRALIA business or activities except in connection with business or corporate functions. (See Alcohol and other Drugs policy, Appendix 2).


5.8 Fair Treatment of Individuals


AIRGROUP AUSTRALIA will not tolerate discrimination, sexual or workplace harassment amongst its employees or associates.


Discrimination, referring to treating someone less favourably than another, in the same or similar circumstances, because of, Gender, Sexual Preference, Age, Pregnancy, Nationality, Political Conviction, Disability, Religious Conviction and Race is not permitted.


Sexual Harassment is the disrespectful, embarrassing, humiliating or intimidating treatment of a person generally with a sexual connotation. This type of behaviour is unlawful harassment when the act or conduct is unwelcome, has the effect of being offensive, humiliating or intimidating to the recipient.  Behaviour that can be considered as Sexual Harassment is:

Unwelcome sexual advances, requests for sexual favours and comments, jokes or suggestive remarks of a sexual nature.

Unwelcome displays of pornographic or erotic pictures.

Unwelcome and unreciprocated sexually suggestive leering, ogling and staring, can also be considered as sexual harassment.

Some examples of unsolicited and unreciprocated physical contact can be: pinching, patting or touching.


Workplace Harassment could be behaviour such as:

Racist name-calling, abuse or jokes.  Joking about another person’s disability, age or religion.

Deliberate exclusion of people from normal work activities because of their race, sex, religion or disability.

Physical assault or threats of physical assault.

Interference with a person’s equipment or work area.

Unwarranted, unjustified and continual comments about a person’s ability to work.


Discrimination and / or harassment imposed on an employee of AIRGROUP AUSTRALIA, whether by another employee, a customer, or a supplier, is not acceptable and will not be tolerated.


5.9 Punctuality and Absenteeism


Each employee is expected to attend work regularly and punctually at the hours established in their contracts and agreed upon with management.  In the event circumstances arise which prevent an employee from reporting to work as scheduled, it is the responsibility of the employee to notify his / her supervisor promptly and if possible beforehand to allow for alternative arrangements to be made.


No employee shall absent himself / herself from work without prior authorisation, except for unforeseen circumstances that cause the employee to be unable to attend work.  Where leave of absence has been granted, such leave must not be used for any purposes other than for which it was granted.


5.10 Dress Code


AIRGROUP AUSTRALIA has a right to expect all employees to dress in a way which is suitable for the situation and type of work they do.  Employees should at all times be dressed in such a way that it reflects on the professionalism and image of the Company.  The dress code is conservative professional when meeting with clients or representing AIRGROUP AUSTRALIA.


5.11 Health and Safety


AIRGROUP AUSTRALIA recognises that excellence in managing Health, Safety and Environmental responsibilities is essential to long term success.  Through effective management practices AIRGROUP AUSTRALIA aims to ensure the health and safety of its employees, to minimise any adverse impact its activities may have on the environment and to make a positive contribution to the local communities.

AIRGROUP AUSTRALIA is vitally interested in the health and safety of its employees and AIRGROUP AUSTRALIA and its employees will make every effort to provide a safe and healthy work environment.  Every employee must protect his / her own health and safety by working in compliance with the law and according to safe work practices and procedures.


Safety in the workplace is not negotiable and the responsibility of all employees and associates entering AIRGROUP AUSTRALIA premises.


5.12 Use of Information Systems


AIRGROUP AUSTRALIA encourages the use of information systems as one mode of information acquisition, processing and sharing, to improve communication.


Any misuse of information systems due to unauthorised access or offensive, defamatory, sexist or discriminatory content may result in the employee being held liable, and may also lead to disciplinary action including dismissal.  All e-mails sent to or received at Company Information Stations are perceived as Company property.  E-mails are centrally recorded and monitored in the Company. (See Internet and Communications Policy, Appendix 3).


5.13 Use of Company Resources


All Company resources are to be used for Company Business only.  Employees using Company Resources for private business endeavours or private use may lead to disciplinary action including dismissal.  (This include the providing of Company stationary to family members for use at School, TAFE or Universities)


5.14 Recruitment


AIRGROUP AUSTRALIA requires that all recruitment / selection and appointment to roles are conducted fairly and with respect to the rights and dignity of individuals.

AIRGROUP AUSTRALIA’s recruitment and selection process is based on an open and transparent approach that is designed specifically to ensure the most suitable applicant is appointed.  The selection process is open to scrutiny to ensure fairness.


All positions are advertised except when an existing employee has been identified through the career development and succession planning process.


Equal employment opportunity applies to all employment practices including (but not limited to) recruitment, appointment, selection, promotion, redundancy, conditions of service, and training and development.


5.15 Reporting of Violations


It is expected from all employees to report any violation of this Code of which they become aware.  In any case where such a report has been made, the report will be treated confidentially to the extent possible and consistent with AIRGROUP AUSTRALIA’s responsibility to address the issue raised.  No person will be subject to retaliation for reporting in good faith a violation of this Code.


5.16 Failure to Comply


Employees who fail to comply with any provision of this Code may be subject to disciplinary action, including the possibility of termination of employment.

It is also important to understand that a violation of certain provisions of this Code may also be a violation of law and may subject the individual employee involved and / or AIRGROUP AUSTRALIA to criminal prosecution or civil liability.


5.17 Reference to corresponding Company Policies


This Code of Conduct must be read in conjunction with the AIRGROUP AUSTRALIA Policy and Procedures Manual.