Code of Conduct

1. Purpose

This Code of Conduct sets out the standards of behaviour expected of every person working for or on behalf of VelpasConn Pty Ltd. It translates our values into concrete, daily expectations covering integrity, respect, safety, lawful conduct, use of company resources, conflicts of interest, confidentiality, and public representation of the company.

The Code does not replace any specific policy; it is the umbrella under which all other VelpasConn policies and procedures sit.

2. Scope

This Code applies to:

• All VelpasConn directors, officers, and employees
• All contingent workers, consultants, and labour hire engaged by VelpasConn
• All subcontractor workers on VelpasConn-controlled sites, to the extent of their interactions with VelpasConn personnel, property, and clients
• All persons representing VelpasConn at client premises, industry events, and in the course of the business

It applies during work, at VelpasConn workplaces, in VelpasConn vehicles, at work-related social functions, when using VelpasConn systems and communication tools, and in any external forum where the person is identifiable as being associated with VelpasConn.

3. Definitions

Term	Definition
Conflict of Interest	A situation in which a personal interest could improperly influence, or be perceived to influence, a person’s decisions in their VelpasConn role.
Gift or Benefit	Any thing of value received from or given to a person outside VelpasConn, including meals, hospitality, products, services, tickets, discounts, or cash.
Confidential Information	Non-public information belonging to VelpasConn, our clients, or other parties, including commercial terms, designs, prices, methods, systems, personal information, and information marked or understood to be confidential.
VelpasConn Assets	Company property and resources, including vehicles, plant, tools, PPE, computing devices, software licences, credit cards, stationery, inventory, intellectual property, and brand.
Officer	As defined in WHS Act 2011 (Qld) s.9: a director, company secretary, or person who participates in key decisions that affect the whole or a substantial part of the business.

4. Our Values in Action

VelpasConn is built on five values. This Code describes how those values translate into daily conduct.

Value	In Practice
Integrity	Tell the truth. Keep promises. Act consistently whether or not someone is watching. Admit mistakes. Do not permit the use of substandard materials or practices: not for cost, not for programme, not to conceal a defect.
Safety	Refuse to compromise on safety to meet programme or cost. Exercise stop-work authority. Speak up for colleagues.
Respect	Treat every person fairly, regardless of role, trade, background, or seniority. Listen. Disagree respectfully.
Accountability	Own your decisions and their consequences. Deliver what you agreed. Escalate early when you can’t.
Excellence	Do the work properly the first time. Improve the system. Leave things better than you found them.

5. Policy Statement

Every person working for or on behalf of VelpasConn Pty Ltd will act honestly, lawfully, safely, and respectfully, and in the best interests of the company, its clients, and its workers.

Our commitments:

1. Lawful conduct. Comply with all Australian laws (Commonwealth, Queensland, and local) relevant to our work.
2. Safety first. Act at all times consistently with IMS-POL-001 Integrated Management System Policy and the WHS framework. Exercise stop-work authority when required.
3. Quality. Deliver work that meets specification, approved drawings, the National Construction Code, and the contract. Do not substitute materials, falsify tests, or take shortcuts that compromise the quality or durability of the finished work. Raise non-conformances promptly; never conceal them.
4. Honesty. Provide accurate information in timesheets, expense claims, project reports, tender submissions, client communications, and regulatory returns.
5. Respect for others. Uphold IMS-POL-004 Workplace Behaviour Policy: no bullying, harassment, discrimination, or victimisation.
6. Respect for property. Use VelpasConn and client assets only for authorised purposes and protect them from damage, loss, or misappropriation.
7. Conflicts of interest. Disclose any actual or perceived conflict of interest before it could influence a decision.
8. Confidentiality. Keep confidential information confidential.
9. No bribery or corruption. Do not give or accept bribes, kickbacks, or secret commissions. Gifts and benefits are only within the limits in section 6.5.
10. No insider dealings. Do not exploit information acquired at VelpasConn for personal or third-party benefit.
11. Fair dealing with clients, subcontractors, and suppliers. Act in good faith. Do not engage in misleading or deceptive conduct.
12. Proper representation. Represent VelpasConn only within your authority; refer matters beyond your authority to the appropriate delegate (per IMS-REG-011 Delegation of Authority Register).
13. Public communications. Leave official public statements to the Managing Director or an authorised spokesperson.
14. Environmental responsibility. Act consistently with IMS-PRO-81E Environmental Operational Control and the environmental commitments of IMS-POL-001 Integrated Management System Policy.
15. Compliance with this Code. Uphold this Code and cooperate with any investigation into conduct.

6. Specific Expectations

6.1 Workplace Safety

• Comply with all IMS procedures, Safe Work Instructions, and SWMSs
• Do not work under the influence (see IMS-POL-002 Drug and Alcohol Policy)
• Report hazards, near-misses, and incidents
• Do not take a safety shortcut for cost, convenience, or programme

6.2 Quality in the Work

• Deliver work that meets the specification, the contract, approved drawings, and the National Construction Code
• Do not substitute materials or change construction methods without written approval from the principal or superintendent (see IMS-PRO-856 Changes and Variations Control)
• Use only materials and products that conform to specification: no substandard, damaged, expired, or unapproved products
• Conduct inspections, tests, and witness points honestly; do not skip, pre-sign, or misrepresent them
• Raise non-conformances immediately via IMS-PRO-807 Nonconforming Outputs and Defects; never conceal, paint over, or defer reporting
• Cooperate with quality assurance inspections, hold points, and Inspection and Test Plan (ITP) witness requirements
• Do not take a quality shortcut for cost, convenience, or programme
• If you see substandard work by another worker or subcontractor, raise it with your supervisor or the Managing Director

6.3 Honesty in Records and Reporting

• Submit accurate timesheets and expense claims
• Record work, inspections, and tests faithfully (no “pencil whipping”)
• Report project status honestly, including problems
• Do not falsify, alter, or destroy records to conceal a problem

6.4 Conflict of Interest

A conflict of interest exists where a personal interest could influence, or appear to influence, a VelpasConn decision. Common examples:

• Family members employed by a subcontractor, supplier, or client
• A personal financial interest in a subcontractor, supplier, competitor, or client
• A secondary employment or business interest that competes with, or provides services to, VelpasConn
• Accepting a role (paid or unpaid) with a VelpasConn client, subcontractor, or competitor
• Using a VelpasConn position to benefit a related person

Your obligation:

1. Disclose actual and perceived conflicts in writing to your direct manager (or to the Managing Director if the manager is involved) as soon as the conflict arises or is foreseen.
2. Do not participate in any decision or process affected by the conflict unless and until the company’s written response is in place.
3. Cooperate with any management plan for the conflict (recusal, reassignment, oversight).

6.5 Gifts, Benefits, and Hospitality

Type	Limit	Declaration Required
Promotional items of token value (pen, cap, calendar)	Up to $50	No
Gift or hospitality from a supplier, subcontractor, or client	Up to $150 per event, and up to $500 a year from any one source	Yes: register entry
Hospitality at industry events (lunch, drinks, tickets)	Must be proportionate and incidental to a legitimate business purpose	Yes: register entry
Cash, cash equivalents, gift cards	Prohibited: refuse and report	Immediate report to the Managing Director
Anything approaching or above $500 in value	Decline, or seek Managing Director approval in writing	Managing Director approval required
Gifts offered during a tender or subcontract selection	Decline, even if below limits	Report to the Managing Director

You must not offer or accept any gift intended, or that could be perceived, as influencing a business decision. Where in doubt, decline and report.

The Gift and Benefit register is maintained by the Managing Director.

6.6 Use of VelpasConn Assets

• Use assets for authorised work purposes
• Personal use that is minor, infrequent, and does not interfere with work (e.g., brief personal phone use) is accepted within reason
• Do not remove assets from VelpasConn premises without authorisation
• Return assets on cessation of employment or at any earlier request
• Report damage, loss, or theft
• Do not install unlicensed software on VelpasConn devices
• Do not use VelpasConn assets for activities that are illegal, offensive, or inconsistent with this Code

6.7 Confidentiality

VelpasConn confidential information includes, without limitation:

• Commercial terms of contracts and tenders
• Client information, pricing, designs, and specifications
• Financial information
• Personal information of workers, clients, and others
• Systems, methods, proprietary know-how
• Information marked confidential, privileged, or commercially sensitive

Your obligations:

• Handle confidential information only for VelpasConn business purposes
• Store physically (locked cabinets) and electronically (controlled systems) with appropriate security
• Do not disclose to anyone outside VelpasConn without authorisation
• Do not disclose to anyone inside VelpasConn without a legitimate need to know
• On cessation of employment or engagement, return all documents and media containing confidential information
• Confidentiality obligations continue after the end of employment; they do not expire

Personal information is additionally subject to IMS-POL-008 Privacy Policy and the Privacy Act 1988.

6.8 Intellectual Property

Work product created in the course of VelpasConn employment (drawings, designs, reports, code, documents, photographs) is owned by VelpasConn unless otherwise agreed in writing.

6.9 External Communications

• Only authorised persons may speak on behalf of VelpasConn to media, regulators, or the public
• Public-facing statements on the VelpasConn website, social media pages, or in press releases require Managing Director approval
• Personal social media activity that identifies the worker as a VelpasConn employee must not bring VelpasConn into disrepute, reveal confidential information, or breach this Code
• Refer media, regulator, and client-escalation enquiries to the Managing Director

6.10 Anti-Bribery and Corruption

VelpasConn does not offer, give, accept, or receive bribes. This applies to private parties and public officials, in Australia and overseas. A bribe is any thing of value given or received with the intent to improperly influence a business decision.

• Refuse any bribe offer; report to the Managing Director
• Do not offer any payment, gift, or benefit to a public official outside the narrow limits permitted by law
• Facilitation payments are not permitted
• Third parties (agents, consultants, representatives) are required by contract to comply with equivalent standards

Serious bribery and corruption is a criminal offence (Criminal Code Act 1995 (Cth); Criminal Code Act 1899 (Qld)).

6.11 Political and Charitable Activity

• Political donations on behalf of VelpasConn require Managing Director approval
• Charitable sponsorships on behalf of VelpasConn require Managing Director approval and are not linked to any current or prospective commercial relationship
• Personal political and charitable activity is your own and must not be represented as VelpasConn’s

6.12 Dealing with Regulators

• Cooperate fully with lawful requests from QBCC, WorkSafe Queensland, the Department of the Environment, Tourism, Science and Innovation (DETSI), the Australian Taxation Office, Fair Work Ombudsman, and other regulators
• Immediately notify the Managing Director of any regulator contact
• Do not destroy records that may be subject to regulator interest
• Do not provide false or misleading information

6.13 Outside Employment

Secondary employment or self-employment is permitted where it does not:

• Conflict with your VelpasConn duties
• Create a conflict of interest
• Impair your fitness for work
• Use VelpasConn confidential information, clients, or resources

Secondary employment must be disclosed to your manager. Directors must obtain written consent.

7. Responsibilities

7.1 Managing Director and Officers

• Model behaviour consistent with this Code
• Exercise Officer due diligence including staying informed of legal and ethical obligations
• Approve exceptions (e.g., gift above threshold; political donation)
• Review conduct matters arising

7.2 Managers and Supervisors

• Communicate this Code to their teams
• Model the Code
• Address low-level breaches promptly; escalate serious matters
• Consider the Code in recruitment, performance, and promotion decisions

7.3 All Workers

• Read, understand, and sign acknowledgement of this Code
• Raise concerns through the channels in section 8
• Cooperate with investigations
• Declare conflicts, gifts, and outside employment as required

7.4 Subcontractors

• Comply with the Code while on VelpasConn workplaces or engaged in VelpasConn work
• Subcontract terms require compliance with this Code

8. Raising Concerns

If you see, suspect, or experience a breach of this Code, raise it through one of these channels:

Channel	Contact
Direct supervisor or manager	First point for most matters
Managing Director	Where the supervisor is involved or unsuitable, and for serious or escalated matters
IMS-POL-007 Whistleblower Policy	For disclosures qualifying under Corporations Act Part 9.4AAA
External: Fair Work Ombudsman	For Fair Work Act matters: 13 13 94
External: Australian Human Rights Commission or Queensland Human Rights Commission	For discrimination matters
External: QBCC, WorkSafe Queensland or DETSI	For licensing, safety, environmental matters

Reports made in good faith are protected from reprisal. See IMS-POL-007 Whistleblower Policy for disclosures that meet the Corporations Act criteria.

9. Breach of This Code

A breach of this Code is a serious matter. Consequences depend on severity, intent, pattern, and impact, and may include:

Severity	Typical Response
Minor	Verbal or written counselling; training; formal reminder
Moderate	Written warning; behavioural review; temporary reassignment
Serious	Final written warning; demotion; significant role change
Very serious, wilful or repeated	Termination of employment (summary or on notice); referral to regulator or Police as appropriate; civil recovery
Breach by subcontractor	Removal from VelpasConn site; review of subcontract; possible termination

All disciplinary action is subject to procedural fairness: the person is informed of the allegation, given an opportunity to respond, and decisions are documented. Actions comply with the Fair Work Act, applicable modern awards, and the person’s employment contract.

10. Records

• Signed acknowledgement of this Code (on commencement, on material change, and annually)
• Conflict of interest declarations
• Gift and benefit register
• Outside employment disclosures
• Records of investigations and outcomes (confidential, restricted access)
• Training records (IMS-REG-004 Training Register)

Retention: 7 years minimum from separation of the worker or closure of the matter, longer if legal or regulatory proceedings arise.

11. References

Legislation:

• Work Health and Safety Act 2011 (Qld): s.19, s.27, s.28
• Fair Work Act 2009 (Cth)
• Corporations Act 2001 (Cth)
• Criminal Code Act 1995 (Cth): bribery offences
• Criminal Code Act 1899 (Qld)
• Privacy Act 1988 (Cth)
• Queensland Building and Construction Commission Act 1991 (Qld)
• Anti-Discrimination Act 1991 (Qld); Sex Discrimination Act 1984 (Cth) (and related)

VelpasConn documents:

• IMS-POL-001 Integrated Management System Policy
• IMS-POL-002 Drug and Alcohol Policy
• IMS-POL-003 Fatigue Management Policy
• IMS-POL-004 Workplace Behaviour Policy
• IMS-POL-007 Whistleblower Policy
• IMS-POL-008 Privacy Policy
• IMS-PRO-503 Organisational Roles, Responsibilities and Authorities
• IMS-REG-011 Delegation of Authority Register

This policy is part of the VelpasConn Pty Ltd Integrated Management System.