Code of conduct and business ethics

Extranet Systems Pty Ltd (ABN 29 632 743 189) ("Extranet Systems", "we", "us") earns its clients' trust through the way we behave, not only through the work we deliver. This Code sets the standards we hold ourselves to. It applies to every director, officer, employee, contractor, labour hire worker and intern of Extranet Systems and its related bodies corporate, wherever they work (together, "our people"), and we expect our suppliers, partners and other representatives acting on our behalf to meet the same standards. A breach of this Code may result in disciplinary action up to and including termination of employment or engagement, and may be reported to the relevant authorities.

1. We obey the law

We comply with the laws of every country in which we operate. Where this Code sets a higher standard than local law or custom, this Code applies. Where local law is stricter than this Code, local law applies. No business objective, instruction from a manager or client request justifies breaking the law.

2. We do not bribe, and we are not bribed

We prohibit bribery and corruption in every form, whether involving government officials or private persons, and whether the benefit is money, gifts, hospitality, employment, favours or anything else of value. Specifically, our people must not:

• offer, promise, give or authorise anything of value to any person to improperly influence a decision, obtain or retain business, or secure an advantage;
• request, agree to receive or accept anything of value that is, or could reasonably be seen as, intended to improperly influence their decisions;
• make facilitation payments, meaning small payments to speed up routine government action, even where local practice tolerates them;
• use a third party, including an agent, partner, reseller or family member, to do anything that this section prohibits.

This applies in every country we operate in and is consistent with the Criminal Code Act 1995 (Cth), which makes bribery of foreign public officials by Australians an offence wherever it occurs, and with the laws of the Kingdom of Bahrain and the Arab Republic of Egypt. Gifts and hospitality may be given or accepted only where they are modest, infrequent, openly given, appropriate to the business relationship, not offered during a tender or contract negotiation, and recorded in our gifts register. When in doubt, decline and ask.

3. We avoid conflicts of interest

Our people must avoid situations where their personal, financial or family interests could conflict with, or appear to conflict with, their duties to Extranet Systems or to a client. Examples include holding an interest in a supplier, competitor or client; outside employment that competes with our business; and personal relationships with people whose work they supervise or whose contracts they influence. Any actual or potential conflict must be disclosed in writing to management as soon as it arises, and the person must not take part in the affected decision until the conflict is resolved.

4. We protect information

We keep client, personal and company information confidential, use it only for the purpose for which it was provided, and protect it in accordance with our Information Security Policy and Privacy Policy. The duty of confidentiality continues after a person leaves Extranet Systems. We never use confidential information for personal advantage, including by trading in securities on the basis of information that is not public.

5. We deal fairly and honestly

• We describe our services, products, qualifications and certifications accurately, and we do not make claims we cannot substantiate. This includes compliance with the Australian Consumer Law in the Competition and Consumer Act 2010 (Cth).
• We compete on merit. We do not fix prices, rig bids, allocate markets or exchange competitively sensitive information with competitors, and we do not obtain competitor information by improper means.
• We keep accurate books and records. Every transaction is recorded completely and truthfully, and no undisclosed or unrecorded fund or asset is maintained for any purpose.
• We respect intellectual property, ours and others', and we use software, data and content only under valid licences.

6. We respect people

We provide a workplace free from discrimination, harassment, bullying and victimisation, and we make employment decisions on merit. We respect human rights throughout our business and supply chain, and we do not tolerate modern slavery in any form; see our Modern Slavery Policy. We take care of the health and safety of our people and of those affected by our work.

7. We use technology responsibly

We use security testing tools only against systems we are authorised to test, in line with our Acceptable Use Policy. We use artificial intelligence in line with our AI Use Policy, with human accountability for every outcome. We do not use company systems for unlawful or inappropriate purposes.

8. We engage responsibly with governments and politics

Dealings with government officials are conducted transparently and in accordance with the rules that apply to those officials. We do not make political donations on the company's behalf without board approval, and our people's personal political activity is their own and must not be presented as the company's.

9. Raising a concern

Anyone, inside or outside Extranet Systems, who becomes aware of conduct that may breach this Code or the law is encouraged to report it. Reports can be made to a manager, to a director, or by email to info@extranetsystems.com.au with the subject "Conduct concern". Reports may be made anonymously. We will treat reports confidentially to the extent the law and a proper investigation allow, investigate them promptly and fairly, and we prohibit retaliation, detriment or victimisation against anyone who raises a concern in good faith or who assists an investigation. Where the Corporations Act 2001 (Cth) whistleblower protections apply to a disclosure, those protections apply in addition to this Code.

10. Responsibility for this Code

Our board of directors approves this Code and reviews it at least every two years. Managers are responsible for promoting it, for leading by example and for acting on concerns raised with them. Every one of our people confirms on joining, and periodically afterwards, that they have read and will comply with it. The current version is always the one published at extranetsystems.com.au/policies/code-of-conduct/.

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