At OrotonGroup (OG) we conduct all of our business affairs legally, ethically and with strict observance of the highest standards of integrity and professionalism. OG requires that its employees actively work towards the best interests of the Company and meet these high standards also. OG takes seriously its obligations to comply with all federal, state and local government laws and regulations, as well as common law obligations, and again requires all employees to do the same.

This policy outlines what constitutes appropriate behaviour and standards at OG. Breaches of these standards will be dealt with directly, and in the case of serious misconduct may result in instant dismissal. In cases where a breach involves a breach of any law then the relevant government authorities or the police will also be involved.

1. Ethics and behaviors at OG

All employees are expected to observe the highest standards of ethics, integrity and behaviour during their course of employment with OG. We expect all OG employees to at all times:

  • Behave in an honest and fair manner in all dealings with customers, business partners, suppliers, & fellow employees;
  • To not engage in harassing or bullying behaviour towards customers, suppliers, competitors & fellow employees;
  • Act in accordance with OG and legal guidelines, policies and procedures, and standards of operations;
  • Comply with all reasonable and legal instructions of managers;
  • Maintain punctuality – we operate to tight deadlines and require everyone’s cooperation;
  • Observe occupational health and safety rules and regulations and always put safety first;
  • Ensure the highest standards of quality in all products and services;
  • Respect the Company’s ownership of all Company’s funds, equipment, supplies, books, records, assets and property;
  • During and after employment with the Company, maintain the confidentiality of any confidential information, records or other non-public materials with any outside people or organisations (such as, but not limited to, competitors, clients, customers and the media…);
  • Dress in an appropriate professional manner and ensure appearances are neat, presentable, clean and tidy;
  • Acknowledge other people’s work and ideas and the importance of teamwork;
  • Ensure compliance with all environmental laws and standards;
  • Do not make any unauthorised statements to the media about the Company’s business (requests for media statements should be referred to your manager or Leadership Team Member in head office);
  • Not engage in fighting, swearing or other unprofessional behaviour in the workplace;
  • Not discriminate on the basis of irrelevant characteristics, such as sex, race, disability, pregnancy, age, marital status, religion or sexual preference;
  • Not perpetrate, permit or fail to report violations of any federal, state or local government law or regulation;
  • Not use drugs or alcohol on the premises or come to work affected by either.
  • Not smoke in or near the workplace.
  • Not use prescription drugs in the workplace if the use of the drug will impact on work performance or the ability to maintain professional behaviour. If (authorised) prescription drugs are required for medical purposes please provide this information in writing to your immediate manager or HR. This information will be kept in the strictest confidence.

2. Prohibited behaviors

All OG employees and directors are prohibited from the following:

  • Taking advantage of property, information or position for personal gain or to compete with the Company, including complying with the policy on trading in OrotonGroup Limited (subject to Deed of Company Arrangement) shares;
  • Having any interest whatsoever in a Company or business that transacts or deals in products similar to that in which the Company deals. Any such conflict of interests currently held must be disclosed to the Company, if not already done so, on the return of this agreement;
  • Any form of dishonesty or malpractice. This includes any practice, behaviour or activity which is illegal, unethical or improper carried out by an employee which results in a loss (financial or otherwise) to, or is not in the best interests of, the Company;
  • Theft or misappropriation of Company assets including property, product, monies, and non public or confidential information, and additionally property belonging to customers or fellow employees;

Company assets include but are not limited to the following:

    • Property: fixtures, fittings, equipment and any other tangible items belonging to or under the control of the Company
    • Product: merchandise, in any condition
    • Monies: any form of payment received in a Company transaction
    • Information: policy, procedures, trading information, retail operations handbook, sales data, lease data, security information, personnel details, designs and concepts, promotions, and supplier and customer details
  • Removing any Company or customer owned property out of stores or Company premises without the appropriate documentation and approval;
  • Taking, appropriating and/or not declaring Company monies;
  • Failing to bank Company monies in the appropriate process and timeliness as instructed;
  • The giving of unauthorised discount to staff, customers or suppliers;
  • Manipulation or fraud of point of sale system, sales records, invoices or orders, trading return, or banking documentation in order to provide deceptive figures or to conceal losses;
  • Falsifying company records, including but not limited to timesheets, rosters and safe access forms
  • Taking Company merchandise for personal use and failing to pay, or account for it in the correct manner;
  • Taking or wearing Company merchandise whilst working without the appropriate permission;
  • Disposing of Company assets or property in any way without the appropriate permission;
  • Giving or receiving a loan of Company money, property or merchandise;
  • Not declaring any shortage or overage in takings, weekly stock counts, stocktakes or deliveries;
  • Receiving or accepting any form of benefit or personal gain (other than via authorised company incentive programs) as a result of a Company transaction or business partner relationship without first declaring to, and receiving approval from, the Company Secretary/CFO in writing. No gifts over $100 value should be accepted at any time;
  • Assisting any other persons in the conduct of dishonest activities or not reporting dishonest activities, whether or not a direct personal gain is made;
  • Working under the influence of drugs or alcohol;
  • Actively participating in theft, or passively supporting theft, fraud or dishonest activity including by failure to report such theft or activity to the Company, through the correct channels.

These examples are not intended to represent an exhaustive list of prohibited behaviours and actions.

3. Breaches of policy

All employees have an obligation to report any breaches of Company guidelines, policies and procedure or other unauthorised activity, which leads them to believe or suspect that dishonest or unauthorised (harassment, bullying) activities, fraud, theft or irregular transactions are occurring or likely to occur (a confidential hotline is provided).