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Code of Business Conduct and Ethics

 

Code of Business Conduct and Ethics 

Multipack provides an extensive range of contract packaging and manufacturing services for the FMCG and small owners. Using our extensive experience, skilled management team, trained production staff, and vast array of specialist equipment our goal is to ensure that our clients have their product transformed at the right price. Affordable innovation for our customers. That is what drives Multipack.

This code of business conduct and ethics demonstrates that we are an ethically driven company that aims to meet our own and our customer standards in this area.

This Code should be used to guide the behaviour of everyone in Multipack – all employees including managers as well as the organisations owners as it clearly states the organisations commitment to behaving honestly and fairly.

Within two months of commencing employment with Multipack, and thereafter on an annual basis, all workers are required to sign up to the principles of the Multipack Code of Business Conduct and Ethics to show that they have understood and agree to comply with their obligations.

Values

The Code is grounded in Multipack's fundamental values, which derive from our obligations to give proper regard to the interests of people and organisations that have a stake in Multipack's activities, including:

Workplace Health, Safety Environment - we care for and protect each other, our business and our environment

Working Together – we respect and trust each other and achieve more by working together across Multipack

Customers – we listen to our customers to understand and meet their needs

Innovation – we strive to develop new ideas and continuously improve the way we do business

Results – together we achieve positive and sustainable results for each other and our stakeholders

Such a set of principles as this Code cannot be comprehensive. If in doubt, Multipack people should ask themselves:

  • do I believe the action I am taking is right – am I being fair and honest?
  • is the action legal? (If in doubt, do not do it.)
  • would I or Multipack be embarrassed if my action was disclosed publicly?

If employees are not sure that a proposed action is appropriate, they should ask their manager, for guidance before acting.

By following the Multipack Code of Business Conduct and Ethics, Multipack people will ensure that our reputation for high ethical standards is protected.

Signatures

 Responsibilities of Multipack People

Employee Responsibilities

It is the responsibility of all Multipack employees to comply with this Multipack Code of Business Conduct and Ethics. Everyone must:

  • act with integrity – being honest, fair and trustworthy in all business dealings and relationships;
  • avoid conflicts between Multipack's interests and personal interests;
  • protect Multipack's business assets;
  • respect and abide by our obligations to fellow employees, shareholders, customers, suppliers, competitors and the communities in which Multipack operates; and
  • act within the laws and regulations affecting business conduct.

It is the responsibility of all Multipack people, including managers and other leaders, to ensure ethical conduct is recognised and valued throughout Multipack.

Multipack employees are required to acknowledge a certificate of compliance signifying that they have read this Code and have complied with it. This is currently done on a yearly basis.

We are committed to open and frank communication in Multipack workplaces. No employee will be subject to retaliation by Multipack for reporting in good faith a possible violation of this Code.

If employees are in doubt about any action, they should contact their manager for approval or guidance.

Responsibility and Accountability of the Multipack Shareholders and Managers

The Multipack Executive Team is responsible for the contents of the Code and its continuous updating. The Managing Director and managers at all levels of Multipack are responsible for ensuring that all employees are aware of, understand and follow this Code. Any significant deviation from the Code must be reported by management to the Directors / Shareholders with a report of action taken to correct the situation.

Contractors' Responsibilities

Individuals or organisations contracting to, or representing Multipack, must comply with this code in the same way as company employees. Multipack employees who engage contractors should ensure that they are provided with a copy of relevant Multipack policies, including this Code.

Responsibility to Protect Multipack's Business and to Use Company Resources Correctly

All Multipack employees must use their best efforts to protect Company assets and other resources including plant, equipment and other valuable property including confidential information and intellectual property such as patents, trademarks and copyrighted material, from unauthorised use, loss, theft and misuse.

Managers are responsible for maintaining controls which:

  • prevent, detect and correct problems;
  • ensure that Multipack attains its business objectives; and
  • ensure compliance with laws, regulations and Company policies.

Workers should refer requests from any external organisation to the Sales / Marketing Director.

The use of Multipack time, material, or facilities for purposes not directly related to company business, or the removal or borrowing of Company property without permission is prohibited. Incidental personal use of such Company resources as computers, phones, faxes, copiers and internet access is permitted, but employees must ensure that Multipack's interests are not harmed.

Protecting Confidential Information

Multipack employees are responsible to ensure that confidential information relating to customers, work colleagues and Multipack operations and suppliers is properly protected. Such information cannot be disclosed to third parties, unless allowed or required under relevant laws or regulation – or agreed by the person or organisation whose information it is.

Responsibility to Individuals

Multipack is committed to the fair and equal treatment of all its employees and abides by the employment laws of Australia in which it operates. Employees and candidates for employment shall be judged on the basis of their behaviour and qualifications to carry out their job without regard to race, gender, religion, sexual orientation, disability, age, marital status or political belief or any other aspect protected by law.

Multipack does not tolerate discrimination, including sexual, physical or verbal harassment or other demeaning behaviour against any individual or group of people. Multipack does not tolerate violence or threats of violence.

Multipack's privacy policy is designed to protect privacy of personal information and other rights of individuals in accordance with law. The Company will only acquire personal information that is required to be effective in its business or is required by law.

Acting Responsibly on Workplace Health, Safety and the Environment

In Multipack, we regard management of workplace health, safety and the environment (WHSE) as an integral and very important part of our business.

We believe that all injuries, occupational illnesses and environmental incidents can be prevented. Management is accountable for safety and environment performance, and all workers are expected to take personal responsibility and be involved in setting standards and improvement initiatives.

Employees are responsible for reporting safety hazards and work-related accidents and injuries.

Our WHSE procedures apply to contractors as well as for employees to ensure the safety and well-being of all people on Multipack sites.

As part of providing a safe and healthy workplace, Multipack will not tolerate employees or anyone else taking illegal drugs on to our sites, nor employees carrying out Company business while impaired by drugs including alcohol. Smoking is only allowed in identified areas on the the site.

More information is available at Multipack's WHSE Management System available from the main office.

Avoiding Conflicts of Interest

Employees must avoid any situations involving divided loyalty or a conflict between their personal interests and those of Multipack. Employees faced with conflicting interest must report it to their manager.

In particular:

  • employees and any organisation in which they or their family have a significant interest must not compete with, or have business dealings with Multipack;
  • employees must not work or consult for, or have any other key role in, an outside business organisation which has dealings with Multipack or is a competitor of Multipack;
  • employees must not use Multipack's assets for any purpose other than for Multipack's business purposes or interests;
  • employees must not make improper use of their employment with Multipack, their position or role in the Company, or information obtained because of their position, to gain an advantage for themselves or anyone else, to Multipack's detriment; and

Gifts, Gratuities and Entertainment

We do not give nor take bribes, kickbacks or gratuities or any other payments for favourable treatment or as an inducement for doing business. However, the Company allows the acceptance of token gifts and entertainment provided they are appropriate to the intended business purpose and consistent with local business practice and laws.

Employees should not seek to gain special advantage for Multipack or themselves through the use of business gifts, favours or entertainment, if it could create even the appearance of impropriety. Business entertainment should be modestly scaled and clearly for business purposes. Gifts and entertainment should not be offered to a customer or supplier whose organisation does not allow this.

Employees may accept or give gifts, favours, or entertainment only if they would not create embarrassment, and:

  • are a common courtesy associated with normal business relationships;
  • are minor in value (under $500) and cannot in any way be construed as a bribe, pay-off, or business inducement; and
  • do not commit any employee, Multipack, or any other party to an obligation concerning business.

Any item in excess of $500 must not be accepted, or if that causes embarrassment, the item should be given to the Company for disposal.

If an employee has any doubts about an issue, they should discuss it immediately with their manager who will if necessary, refer it in writing to their General Manager.

Acting Responsibly with Customers, Suppliers, Competitors and Others

Employees dealing with customers, suppliers or competitors must fully comply with trade practices laws. If another employee or outside party suggests a breach of these laws this must be immediately reported to the Directors / Shareholders.

Multipack's success depends on the continued support of our customers. We must act in partnership with our customers for our mutual long term benefit. We will compete for business openly and honestly. Employees must not misrepresent our products, services or prices and must not make false claims about those of our competitors.

Multipack will be fair and honest in our dealing with suppliers. The Company's purchasing decisions must be based on such commercially competitive factors as quality, price, and consistent reliability and a supplier's level of service.

Responsibility to the Community

Multipack is committed to being a responsible corporate citizen. We recognise our responsibility to deal effectively and appropriately with the communities in which we operate.

We are committed to protecting the environment in which we operate, minimising the impact of our activities on land, air and water.

Complying with the Law

Multipack will only conduct business by lawful and ethical means. Legal responsibilities change and employees at all levels must keep themselves informed and comply with all legal responsibilities.

All Multipack employees have an obligation to understand and work within these requirements. The Company will provide the training necessary.

Complying with International Standards

Multipack will comply with all International Labour Standards to the extent that these are enshrined in Australian labour law.

In particular the following standards are reinforced in both this Code of Practice and Employee Contracts.

Child Labour - Multipack will not employ any person below the age of 18 years. This will be confirmed if necessary by sighting the birth certificate.

Forced Labour – All persons who work with Multipack will do so of their own volition and will be provided with a contract that states the obligations & benefits associated with such employment. All employees are free to leave employment at any time. Further details are part of the contract of employment.

Discrimination – Multipack is committed to providing a workplace free from discrimination, sexual harassment and bullying. Behaviour that constitutes discrimination, sexual harassment or bullying will not be tolerated and will lead to action being taken, which may include dismissal.

Equal Opportunity - Multipack are an equal opportunity employer and provide opportunity in employment to people without discrimination based on a personal characteristic protected under state and federal equal opportunity legislation. Further details on this can be found in your contract of employment.

All Multipack employees have an obligation to understand and work within these requirements. The Company will provide the training necessary.

Reporting Non-Compliance with this Code

Any Multipack worker who becomes aware of a possible breach of this Code should report this to their manager or on the Confidential Reporting number 0418 294 316

Such reports will be treated confidentially to the extent possible consistent with Multipack's obligation to deal with the matter openly and according to applicable laws.

No employee will be subject to retaliation or disadvantage by reason of a bona fide report of possible non-compliance.

Penalties for Breaches of the Code

Adherence to this Code and Multipack's policies is a condition of employment at Multipack. Breaches of the Code will be subject to disciplinary action including termination of employment, if appropriate.