Insurance Australia group code of ethics

Transcription

1 IAG Job Offer Website PAGE i Insurance Australia group code of ethics

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3 Welcome Welcome to Insurance Australia Group (IAG). As a new employee of IAG, you will be joining a strong and vibrant group who is a leader in the insurance industry. To find out more about Insurance Australia Group including our brands, history and the way we do business, visit our corporate website at On this website you will find a variety of material to support the offer of employment you have received. Feel free to browse and review the content and related websites. We suggest you visit the Where to from here page next to understand the steps required to accept your offer of employment and what paperwork you need to complete to become an employee of IAG. If you have any questions, feel free to contact the IAG manager who has hired you in regards to the offer, or for assistance in completing your forms, contact CGU Human Resources on (03) We look forward to welcoming you to the IAG team. Our Business model and brands DIRECT INSURANCE INTERMEDIATED INSURANCE ONLINE INSURANCE DIRECT INSURANCE DIRECT INSURANCE INTERMEDIATED INSURANCE AmAssurance AUSTRALIA NEW ZEALAND INTERMEDIATED INSURANCE ASIA INTERMEDIATED INSURANCE UNITED KINGDOM OTHER ACTIVE PORTFOLIO MANAGEMENT & GOVERNANCE PAGE 1 Insurance Australia group Welcome

4 Where to From Here If you are accessing this site, you would have already received your Contract of Employment. That document sets out the key conditions relevant to your specific offer. This site provides additional material to support you in deciding whether a career with IAG is right for you. We recommend you take some time to review the material and ask questions where you need to. Remember that either your hiring manager or recruiter are available to help you. When you are ready to accept the offer, download the New Starter Checklist for step by step instructions on how to formally accept the offer and what you need to complete/provide in order to join IAG. The New Starter Checklist and all relevant forms for joining IAG are available on the Download This Site/Download Starter Forms Page. Table of Contents Code of Ethics 3 Code of Conduct 19 Your Superannuation Choices 31 Your Fair Work Statement 37 Download this site/download Starter forms 40 PAGE 2 Insurance Australia group Where to from here

5 The Way WE CHOOSE TO DO BUSINESS INSURANCE AUSTRALIA GROUP CODE OF ETHICS The Way We Choose To Do Business sets out our expectations of every person at IAG. Everyone at IAG is responsible for achieving the highest levels of business conduct and we are all accountable for delivering our everyday activities in a way that reflects the ethical principles set out in this Code. PAGE 3 Insurance Australia group code of ethics

6 ABOUT THIS CODE The global business environment is continuously demanding more from us as a company and as employees. Not only does the world expect us to deliver the best products and services, it expects us also to conduct ourselves ethically and responsibly. We believe that ethical conduct is an integral component of running our business successfully for the long term. When our stakeholders interact with our people at Insurance Australia Group (IAG), we want them to be assured that we are acting with integrity and in a responsible, ethical way. The Way We Choose To Do Business sets out our expectations of every person at IAG. Everyone at IAG is responsible for achieving the highest levels of business conduct and we are all accountable for delivering our everyday activities in a way that reflects the ethical principles set out in this Code. The Way We Choose To Do Business is strongly influenced by IAG s promises and values. The ethical principles in this Code will assist us in determining the most appropriate way to deliver on our promises of paying claims, understanding and pricing risk, managing our costs and reducing risk. Maintaining high standards requires our total commitment to these sound ethical principles and to IAG s values. Throughout this Code we emphasise our values we are strongly committed to our conviction that IAG can best achieve its business goals through integrity, transparency, teamwork, meritocracy and social responsibility. In providing this Code, we undertake to all of our people that no-one will be penalised for any impact, including the loss of business, which may result from adherence to these ethical principles. Insurance Australia group code of ethics PAGE 4

7 Contents 1. INTRODUCTION TO OUR ETHICAL PRINCIPLES 2. IAG PURPOSE & principals 3. IAG VALUES 4. the WAY WE OPERATE OUR GOVERNANCE Financial Crime Dealing with Governments Bribery and Corruption Gifts, Entertainment and Other Benefits Risk Management Use of Third Parties and Agents Use of Information Systems Intellectual Property Public Disclosure of Company Information Conflicts of Interest Insider Trading Human Rights 5. the WAY WE WORK OUR PEOPLE Working at IAG Managing Our People Developing Our People Equal Opportunity Diversity Cultural Sensitivity Work and Life Occupational Health and Safety Remuneration Speaking Up Grievances Our Rights at Work Political Activity PAGE 5 Insurance Australia group code of ethics

8 6. the WAY WE HELP OUR CUSTOMERS Helping Our Customers Customer Complaints The Privacy of Our Customers Accountability for Our Marketing Access to Insurance Supporting Industry Standards and Codes Trade and Competition 7. the WAY WE HELP TO REDUCE RISK THE COMMUNITY AND THE ENVIRONMENT Community Engagement Community Investment Understanding Insurance Disadvantaged Groups Environmental Risks and Opportunities Recognising Our Impact Our Environmental Management Climate Change Advocacy 8. resolving ETHICAL DIlemmas 9. asking FOR ADVICE AND REPORTING concerns Please consider the environment before printing this document Insurance Australia group code of ethics PAGE 6

9 1. INTRODUCTION TO OUR ETHICAL PRINCIPLES What is the Code of Ethics? The IAG Code of Ethics (the Code) provides the basic foundations that help guide our ethical conduct. The Code is not meant to replace our detailed policies, rather it is a statement of our basic ethical principles in a number of important areas. Codes of conduct, while consistent with the Code, will provide more specific guidance and may vary across regions, depending on the legal and regulatory rules that apply. Our Foundation who are we and what we stand for IAG Values IAG Purpose IAG Ethical Principals IAG Group-wide policies and procedures Regional codes of conduct Local policies and procedures PAGE 7 Insurance Australia group code of ethics

10 What are Our Ethical Principles? The Code expresses the fundamental ethical principles that are applicable across all parts of the business, regardless of the country of operation. Our ethical principles are provided to help guide each of our people when they make a judgement on what is right, proper and appropriate in a given situation. These ethical principles will assist us in: Determining the most appropriate way to deliver on IAG s purpose to help people manage risk and recover from the hardship of unexpected loss; and Bringing the IAG values of performance, integrity, respect and a considered sense of urgency to life in our daily behaviour. These principles are organised into four areas: 1. The Way We Operate Our Governance; 2. The Way We Work Our People; 3. The Way We Help Our Customers; and 4. The Way We Help to Reduce Risk the Community and the Environment. What are Our Expectations? For each of us our ethical behaviour is a series of choices and decisions. At IAG we are all accountable for ensuring that these decisions are in accordance with all laws and regulations of the countries in which we operate, as well as being consistent with our ethical principles as set out in this Code and the IAG policies and standards that relate directly to our duties. We are all expected to be proactive in identifying behaviours that are not in accordance with the Code and to address them or report them as appropriate. We promote a culture that encourages us to raise issues of concern as they are identified rather than concealing or ignoring them. Who Does the Code Apply to? The Code applies to: All employees of entities where IAG has majority ownership or which are otherwise considered to be IAG subsidiaries; and All non-executive directors. Insurance Australia group code of ethics PAGE 8

11 2. IAG PURPOSE IAG s purpose is to help people manage risk and recover from the hardship of unexpected loss. To be true to this purpose, each of IAG s operating businesses must live by a set of agreed principles. IAG Principles Experts in the fundamentals of insurance. This means excelling at understanding and pricing risk, managing claims and distributing our products. And that s because we understand the importance of what we do. Disciplined business leaders. We re not just good at insurance, we re good at business. We are high performing and professional. Passionate about our customers. At every interaction, we demonstrate our passion for our customers. This gains our customer trust and loyalty, and means our customers are our advocates. Innovative and one step ahead. We re determined to keep moving and be one step ahead of our competitors. By listening to our customers, we stay relevant and generate new ideas, cementing our competitive advantage. Sustainable, so we re around for the long term. At IAG, our definition of sustainable business is one which delivers for our shareholders, customers, people and the community by taking a balanced approach. PAGE 9 Insurance Australia group code of ethics

12 3. IAG values The foundation of all we do is what we value as an organization. At IAG, what we value determines the behaviours that drive the performance that is required by our shareholders, employees and customers. We value PERFORMANCE In the way that we collaborate to deliver the highest level of sustainable business outcomes for our shareholders, customers and communities. We value INTEGRITY Through the application of the highest standards of honesty and openness in our interactions with colleagues, customers, shareholders and other stakeholders. We value RESPECT In the way that we treat our customers and colleagues, and for the diversity that they represent. We value A CONSIDERED SENSE OF URGENCY In the way that we approach our business with a Can-do attitude. Insurance Australia group code of ethics PAGE 10

13 4. THE WAY WE OPERATE OUR GOVERNANCE Financial Crime We are committed to preventing, detecting and investigating financial crime and working with other organisations to reduce opportunities for fraud or criminal misconduct. Dealing with Governments We respect the authority of governments in the countries in which we operate and are committed to maintaining honest, open and cooperative relationships with governments and regulatory officials. We believe in remaining impartial in relation to party politics. Bribery and Corruption We value open and honest relationships with all parties and believe that bribery and corruption should not play any part in our business dealings, including influencing a business relationship or decision. Gifts, Entertainment and Other Benefits We believe that gifts, entertainment and other benefits can compromise our ability to make objective and fair business decisions and should only be accepted where they cannot be perceived to unfairly or illegally influence a business relationship or decision and are within reasonable limits. Risk Management We believe that managing risk is vital for the sustainability of IAG and supports the achievement of our business goals. We want to maintain a proactive risk culture that delivers consistent risk management behaviour. Use of Third Parties and Agents We believe in using agents or third parties to represent IAG s interests where it is the most efficient way of doing business and for them to do so according to our ethical principles. Use of Information Systems We believe that our Information Technology must be used responsibly and that we have a responsibility to protect company information communicated or stored using these systems. PAGE 11 Insurance Australia group code of ethics

14 Intellectual Property We are committed to respecting the Intellectual Property rights of third parties and to protecting our own Intellectual Property rights attached to the work of all our people, including ensuring that our people take appropriate measures to safeguard our Intellectual Property. Public Disclosure of Company Information We believe in communicating with all of our stakeholders in a way that is transparent, honest, accurate and timely and respects privacy and other legal requirements. Conflicts of Interest We believe that our people should avoid situations where personal or professional interests conflict or appear to conflict with carrying out their responsibilities as representatives of IAG. Insider Trading We believe that our people must ensure that they do not use inside information in any trading by them in securities issued by entities within IAG and that they do not communicate inside information to another person who may trade in IAG securities. Human Rights We respect and support the UN Universal Declaration of Human Rights and acknowledge that in our growth as a multinational organisation, we will need to continue to consider and integrate human rights policies and thinking into all of our operations. Insurance Australia group code of ethics PAGE 12

15 5. THE WAY WE WORK OUR PEOPLE Working at IAG We are committed to meeting the needs of our people by providing a working environment where everyone is provided with opportunities to achieve personal fulfilment and development. Managing Our People We believe that a sustainable workforce is crucial to achieving long term success and will strive to provide a working environment that is based on the principles of high performance, productivity and flexibility. Developing Our People We believe in providing our people with the development opportunities to assist them in carrying out their roles and to help them realise their fullest career potential. Equal Opportunity We believe in treating our people fairly and on an equal basis regardless of age, gender, disability, race or religion. Diversity We believe that our culture should value rather than tolerate differences and allow a flexible and inclusive work environment that supports all of our people in achieving their potential. Cultural Sensitivity We believe in respecting and being sensitive to the cultures and customs of the countries in which we operate. Work and Life We believe that a healthy workplace involves a flexible work environment that allows our people to balance work with their personal commitments. Occupational Health and Safety We believe in providing a healthy, safe and clean environment for our people, customers and visitors and aim to foster and sustain a positive safety culture in all of our workplaces. PAGE 13 Insurance Australia group code of ethics

16 Remuneration We believe in attracting and retaining high quality people, paying our people fairly, and supporting, recognising and rewarding high performance. Speaking Up We want our people to speak up about issues of concern or when they suspect any behaviour that may breach any laws or IAG policies. Grievances We believe in providing a workplace environment that is sensitive to grievances and are committed to providing an environment where grievances can be discussed and resolved. Our Rights at Work We respect and support the International Labour Organisation Declaration on Fundamental Principles and Rights at Work and are committed to ensuring that our people enjoy the fundamental rights ascribed to them in this declaration and in the labour standards and laws of the countries in which we operate. Political Activity We acknowledge that our people have the right to take part in political activities as individuals but not as representatives of IAG. Insurance Australia group code of ethics PAGE 14

17 6. THE WAY WE HELP OUR CUSTOMERS Helping Our Customers We believe that the insurance products and services we provide must have the central focus of helping our customers and recognise that there is potential for us to interact more with customers to help them minimise their risks. Customer Complaints We welcome feedback from our customers and believe that it helps us to remain open and responsive to their needs and expectations, and ensures we continually improve the experience our customers have when they deal with us. The Privacy of Our Customers We respect confidentiality and our customers right to privacy and will strive to maintain the confidence our customers have in us to properly handle their confidential information. We will only release customer data to a third party when approved by the customer or required by law. Accountability for Our Marketing We believe in marketing and selling our products responsibly and being accountable for the promises we make in our advertising and marketing. Access to Insurance We believe in understanding the needs of the communities in the countries in which we operate regarding access to insurance, particularly low income earners and rural and regional customers and working to develop products and services that meet those needs. Supporting Industry Standards and Codes We support standards and codes that improve the performance of the industry and we will be held responsible for our performance in relation to those standards and codes that we endorse. Trade and Competition We support the principles of fair and open trading and believe in competing for business in a fair and ethical manner. PAGE 15 Insurance Australia group code of ethics

18 7. THE WAY WE HELP TO REDUCE RISK THE COMMUNITY AND THE ENVIRONMENT Community Engagement We are committed to understanding and supporting the communities in the countries in which we operate, with a focus on reducing risk for our shareholders, our customers, our people and all of our collective stakeholders. Community Investment We will partner with organisations and projects that reflect our desire to help the community to reduce risk in the areas of safety and the environment. Understanding Insurance We recognise that the community would like to know more about insurance and how it works and are committed to helping the communities in which we operate to better understand the consequences of underinsurance and non-insurance. Disadvantaged Groups We recognise that in some countries there are groups of people who have traditionally suffered disadvantage in the workplace and in the broader community and we are mindful of their business and social needs. We are committed to ensuring that our policies and actions do not reduce the rights of these people or deny them access to services to which they are entitled. Environment Risks and Opportunities We believe that it makes commercial sense to understand environmental risks and opportunities and are committed to sharing our experience in assessing complex risks as a contribution to addressing environmental issues. Recognising Our Impact We recognise that our business has impacts on the community, the environment and the wider economy. We believe that it is good business to operate in a way that recognises adverse impacts and manages them effectively. Our Environmental Management We recognise that our business activities have direct and indirect environmental impacts and are committed to actively reducing our key environmental impacts across all of our operations. Insurance Australia group code of ethics PAGE 16

19 Climate Change We believe that human induced climate change represents an unprecedented and highly complex threat to long term economic and social interests and are committed to understanding the risks to our business and the community. We seek to maximise the potential shared benefits for the community and IAG by working together to address the adverse impacts of climate change. Advocacy We believe that we have a significant role to play in increasing awareness in the community of the benefits of managing and reducing risk, through advocacy and communication activities. 8. RESOLVING ETHICAL DILEMMAS Ethical behaviour and decision making extends beyond legal requirements and as such requires you to exercise judgement and accept personal responsibility. At IAG we encourage you to seek help or engage others in dialogue and debate to identify the best course of action. When faced with an ethical dilemma, begin by asking yourself the following questions: Do my intended actions comply with relevant laws and regulations? Do my intended actions reflect the IAG values? Do my intended actions follow the ethical principles in the IAG Code of Ethics? If reported in the newspaper, would my intended actions be viewed positively? Would I be happy if my intended actions were done to me or a loved one? Would I and those I respect be proud of my intended actions both now and in the future? If you answer not sure or no to any of these questions refer to the Asking for Advice and Reporting Concerns section and discuss the situation and your intended actions or decisions with one of these resources, refer to the following page. PAGE 17 Insurance Australia group code of ethics

20 9. asking FOR ADVICE AND REPORTING CONCERNS There is always someone at IAG who can help you when you need assistance with ethical concerns. You can use the following resources for help, information or guidance about an ethics matter or to report a suspected incident. Your concerns will be taken seriously and addressed in a thorough and professional manner, regardless of the method you choose. When potential misconduct is reported, we will investigate and take appropriate action. Your Manager In most cases your manager is the best person to speak to. If you are unsure about the most appropriate course of action to take in any situation, you can ask for advice by consulting your manager. Your Next Level Manager In special cases where you feel that it is inappropriate to consult your direct manager, you can consult your manager s manager for advice or to report ethical concerns. Your Local Human Resources Team Your local human resources team is available to discuss any ethical matters or dilemmas you might have, as well as concerns involving grievances, performance and equality of opportunity or harassment complaints. Anonymous Reporting Services If you suspect serious inappropriate behaviour and feel uncomfortable using the above channels, consult your local human resources team to find out about processes for anonymous reporting. IAG WILL NOT TOLERATE ANY RETALIATION IN ANY FORM AGAINST PEOPLE WHO, IN GOOD FAITH, REPORT SUSPECTED ETHICAL OR LEGAL MISCONDUCT OR POLICY VIOLATIONS. Insurance Australia group code of ethics PAGE 18

21 CODE OF CONDUCT AUSTRALIA Our Code of Conduct The Code of Conduct is designed to make our employees aware of their responsibility to perform their duties in an ethical and appropriate manner and to ensure that IAG maintains its reputation as a good corporate citizen. The Australian Code of Conduct supports IAG s Code of Ethics, by providing specific guidance for operating in the Australian legal and regulatory environment. PAGE 19 Insurance Australia group Code of Conduct

22 Contents ENSURING INTEGRIty Dishonest and Fraudulent Behaviour Conflicts of Interest Employment outside the Group Staff Business Purchase of Goods and Services Gifts and Benefits COMPLIANCE WITH LEGAL AND REGULATORY REQUIrements Dealing in Insurance Australia Group Limited (IAG) Shares CONFIDENTIALIty Protecting Confidential Information Confidentiality after Ceasing Employment Privacy Act Obligations Communication with the Media EEO AND ANTI-harassment OCCUPATIONAL HEALTH AND safety Drugs and Alcohol YOUR RESPONSIBILITIes The Code of Conduct applies to all employees of the companies within the Insurance Australia Group ( the Group ) in Australia. The Code of Conduct is designed to make employees aware of their responsibility to perform their duties in an ethical and appropriate manner and to ensure that IAG maintains its reputation as a good corporate citizen. Insurance Australia group code of Conduct PAGE 20

23 ENSURING INTEGRITY It is important to maintain the Group s reputation for honesty and integrity. You should therefore be open and honest in all your dealings with the Group as an employee and customer. Dishonest and Fraudulent Behaviour You must immediately report any possible fraudulent activity including theft of company property, breach of any legal, regulatory or organisational requirement, or inappropriate practices or behaviour which affects the Group to your manager, HR Business Partner or directly to the Fraud Hotline ( ). Managers must ensure that any allegations of dishonest or fraudulent behaviour are reported to the Fraud Hotline ( ) and a HR Business Partner within their division as soon as possible after becoming aware of the allegations. For further details, please refer to the Dishonest and Fraudulent Behaviour policy or the Incident Reporting Page on the intranet. Audits are regularly conducted to ensure the integrity and security of our people, systems and processes. You must fully cooperate with any audit or investigation where required. Serious disciplinary action, including termination of employment, will be taken against any employee who is involved in theft, fraud or other dishonest behaviour. Conflicts of Interest A conflict of interest is a situation where your personal or professional interests may conflict with your position and your obligations and responsibilities as an employee to the Group. It may also include situations where you act in a way or use your influence as an IAG employee that would compromise IAG s reputation or affect the conduct of IAG s business. You must make every effort to avoid conflicts of interest. For example, if your position brings you into business contact with your personal interests, or those of family or friends, and there is likely to be a conflict of interest, you must inform your manager or your Risk and Compliance Manager via the Compliance Mailbox on the intranet. Examples of where a conflict of interest may arise include situations such as: a manager signing off on their own business related expenses if an employee attempts to obtain a benefit by approving or recommending a transaction; an employee who favours a supplier during a tender process due to a personal relationship with them; an employee using their position to influence an outcome on a personal claim or in conducting business with the Group. PAGE 21 Insurance Australia group code of ethics

24 There are a number of situations which may constitute a conflict of interest. If you are not sure whether a situation constitutes a conflict of interest, speak to your Risk and Compliance Manager or HR Business Partner. Employment outside the Group Employment undertaken outside work hours is permitted, unless that employment causes a conflict of interest. For example, any work performed for a competitor is likely to produce a conflict of interest. If you are unclear about whether a conflict of interest may exist you should speak with your manager. Use of the Group s equipment, information or property is prohibited for work done outside of the Group. Staff Business Under no circumstances should you view, handle or process any form of the Group s business, such as insurance policies or claims for yourself, family, friends, colleagues or associates. This includes amending or creating policies, authorising payments or changing personal details. An example of how this might happen in the workplace Reema is a claims consultant in the Call Centre. Reema s parents realise their insurance policy has lapsed so call Reema at work to ask her to renew it. Reema knows she is not meant to handle business for herself, family, friends or colleagues so she calls a claims consultant in the call centre and asks them to set the policy up for her parents. Ben, the claims consultant requires personal information regarding the policy holders to setup the Policy. Reema fills in the required documentation on behalf of her parents believing she is doing nothing wrong as she is not actually setting the policy up herself. Once the policy is activated Reema accesses it to ensure her parents have enough contents cover. She thinks they have underestimated their household contents, so calls them and suggests they increase the cover. Reema s mum phones Ben and asks him to increase their contents insurance, telling him, that their daughter, Reema had a look at the policy on the system and thinks they are underinsured. Ben is uncomfortable as he knows employees of IAG are not allowed to view, handle, or process any business for themselves, family and friends. Ben mentions his feelings to his manager who discusses the situation with their HR Business Partner to discuss what appropriate action needs to be taken. Insurance Australia group code of ethics PAGE 22

25 It is important to remain at arm s length to any business that you have with the Group. Many parts of the business have procedures in place in relation to employee s doing business with the Group to ensure that employees do not handle any business for themselves, family, friends, colleagues or associates. If you are unsure about these procedures, discuss this with your manager. Purchase of Goods and Services The purchase of goods and services from a trade contact or supplier, or the purchase of salvage or property associated with a claim, is permitted only with the prior written approval of your manager. A fair market price must be paid for any goods or services purchased to ensure that you are not placed in a position where you may create a sense of obligation to the trade contact or supplier. For more specific information regarding specific procedures in place in a division, please refer to the intranet or speak with your manager. An example of where purchase of goods and services is a breach of the Code of Conduct John, a Motor Assessor at a Care and Repair Centre is assessing a 4WD. John thinks a 4WD would be a good family car as his current car is getting too small for his growing family. He knows the car can be repaired but decides to alter the figures so that it will be a totalloss and as a result, sold at auction through the salvage centre. John then determines when the vehicle will be auctioned. He attends the auction and purchases it for a significantly cheaper price than if he had bought it as a second hand car. John s manager was unaware that John purchased the car until after the auction when he overheard John telling another Motor Assessor what a great price he got it for. This situation would constitute a breach of the Code of Conduct because John did not speak to his manager about purchasing salvage before completing the transaction and gain written approval to ensure that a reasonable price was paid for the vehicle. The situation also created a conflict of interest for John because he used his position as a Motor Assessor to influence a decision about the condition of the car for personal gain. This resulted in John getting a benefit to which he was not entitled. PAGE 23 Insurance Australia group Code of Conduct

26 Gifts and Benefits Great care must be taken when accepting gifts or benefits as they may create a sense of obligation to the donor. Any gift, favour or other benefit must be declared to your manager. You and your manager must decide whether to return the gift or benefit, donate it to charity, or share it between employees. You must always act in an ethical manner and under no circumstances should you offer or accept any improper payments or bribes. You and your manager should agree what trade nights or social events you can attend which are related to your position. Insurance Australia group code of Conduct PAGE 24

27 COMPLIANCE WITH LEGAL AND REGULATORY REQUIREMENTS The Group is required to comply with a number of laws, regulations, industry codes and organisational policies and practices that regulate the conduct of the Group s businesses. To ensure that the Group meets its obligations, you will be required to undertake training in these areas. For more information on compliance training required, you should refer to your Learning and Development Consultant. Dealing in Insurance Australia Group Limited (IAG) Shares Insider trading in IAG shares is illegal and can result in substantial penalties, including jail terms. Such illegal conduct will lead to disciplinary action and may lead to termination of employment. Senior Managers and nominated employees may only buy or sell IAG shares during three dealing window periods during the year. For further details, please refer to the Security Trading Policy on the intranet. PAGE 25 Insurance Australia group Code of Conduct

28 CONFIDENTIALITY During your employment, you will become aware of, and have access to, personal information about customers, employees and other individuals and the Group s commercially sensitive information. This may include the types of policies a customer holds, customer contact details, supplier details and arrangements, etc. You must keep this information confidential and only use it for IAG business purposes. Protecting Confidential Information Information about the Group and its customers is confidential and remains the property of the Group at all times. Confidential information is all information disclosed, provided or otherwise made available during your employment, work you have contributed to or made in the course of your employment, which may include but is not limited to the business and affairs of the Group. Confidential information does not include information that was public knowledge when your employment commenced or became so at a later date (other than as a result of a breach of confidentiality by, or involving you). Confidential information must only be used in the course of your employment and may not be released or taken offsite without authorisation from your manager. Commercially sensitive documents, records and files must be stored securely and not left where visible. Confidential information must not be left on computer screens and you must not share your computer access passwords with others. Computer systems must be secured and used for business purposes only. This ensures long term integrity of systems and confidentiality of business, customer and employee data. You must not misuse or internet systems and should refer to the and Internet Access/Usage Policy which outlines appropriate use. Misuse of IAG s or internet systems may result in disciplinary action which may include termination of employment. If you re not sure whether any information is confidential information, you must speak with your manager before you disclose this information. For more information and detail about the physical security requirements of the Group, including building access and IAG s clean desk requirements, you should refer to the Physical Security Policy on intranet. An example of a breach of confidentiality Tony and Max used to work together at IAG in the Retail Sales and Service business before Max received an offer from a competitor that he could not refuse. Tony and Max still make the effort to catch up for lunch occasionally and talk about the old days at IAG and what everyone Insurance Australia group code of Conduct PAGE 26

29 is up to now. They often compare what their companies are currently doing in the marketplace and any new company initiatives. At a recent lunch, Max asked Tony if he could forward him a copy of a marketing strategy that they had worked on together whilst they worked together at IAG. Tony forwarded the strategy paper to Max because they had spent months developing the strategy paper and thought that it was only fair that Max have a copy. The document contained sensitive confidential information about IAG s customer base and strategies to increase premium over the next 12 months. The document was marked private and confidential. This example is a serious breach of the Code of Conduct because the strategy paper was the property of IAG s and contained sensitive confidential information which could impact on the Company s competitive position in the market. Tony did not have the authority to send this document to an ex-employee. The situation was made worse because Max was now working for a competitor. Confidentiality after Ceasing Employment Your obligation to protect the Group s confidential information continues after your employment ceases. This means you must not use the Group s confidential information for your own benefit or the benefit of anybody else, disclose it to a third party, copy it or take it with you when you leave. The Group takes these obligations seriously and will take whatever legal action is necessary to protect its confidential information. For more information, you should refer to your contract of employment or the confidentiality agreement signed at the beginning of your employment. Privacy Act Obligations Compliance with the Privacy Act is mandatory. You have an obligation and personal responsibility to respect our customer s, other employees and individuals, right to privacy. This means doing everything reasonably within your power to protect the security of any personal information you handle in the course of doing your job. Personal information about customers, employees and other individuals should only be used in the course of your employment. For more information, speak to your manager or refer to the Privacy section the intranet. Communication with the Media Media or public comment on the Group can only be made by the Group employees authorised to do so. You must inform Corporate Affairs and Investor Relations as soon as any media enquiries are received. If you have any doubt about who is authorised to speak to the media, contact Corporate Affairs and Investor Relations. Refer all investor relations enquiries, for example questions about the performance of IAG shares, Corporate Affairs and Investor Relations. For further information please refer to the Continuous Disclosure Policy on the intranet. PAGE 27 Insurance Australia group Code of Conduct

30 EEO AND ANTI-HARASSMENT The Group is committed to equal employment opportunities for all employees. All employees will be treated fairly and with respect and no person will be discriminated against on the basis of race, colour, sex, sexual preference, age, physical or mental disability, marital status, family responsibilities, pregnancy, religion, political opinion, national extraction or social origin. The Group will not tolerate any form of sexual harassment. Sexual harassment is any form of unwelcome and uninvited words, or conduct, of a sexual nature that a reasonable person would find offensive, humiliating, intimidating or embarrassing. Every employee is responsible for ensuring that harassment or discrimination does not occur in their workplace. As part of this, all employees must complete the online Diversity and EEO course. For further information, refer to the human resources section on the intranet. An example of sexual harassment This year the annual Christmas party was held in the local restaurant. Dinner and drinks were paid for by IAG. Everyone was dancing and generally having a really good time. Two employees, Ms Smith and Mr Jones were dancing together when Mr Jones tried to kiss Ms Smith. Ms Smith pushed Mr Jones away and told him to stop but he persisted, thinking that Ms Smith was interested in him. Ms Smith finally pulled herself free and left the venue to go home. After Ms Smith left Mr Jones began sending her suggestive text messages to her work mobile phone. Ms Smith replied to the text messages telling Mr Jones to stop sending the messages but Mr Jones thought it was all harmless fun. On Monday when Ms Smith returned to work she put in a complaint about Mr Jones s behaviour at the dinner and the harassing text messages that followed. Ms Smith didn t think that she could work in the same team as Mr Jones anymore as she felt uncomfortable around him after what had happened. Even though the event was after normal work hours, it was still considered a work related function. Therefore, all employees are still required to act appropriately and as representatives of IAG. Insurance Australia group code of Conduct PAGE 28

31 OCCUPATIONAL HEALTH AND SAFETY The Group is committed to ensuring a healthy, safe and clean environment for our people, our customers and visitors as detailed in the Charter for Health Safety & Security. The Group adopts a cooperative approach between managers and employees in the development and implementation of occupational health and safety (OH&S) practices. Drugs and Alcohol The use of drugs and alcohol may impair an employee s capacity to perform their job safely, efficiently and with respect for work colleagues and customers. No employee is to commence work, or return to work whilst under the influence of alcohol or drugs if that influence impairs the employee s work performance. Any concerns should be raised with a manager immediately. Employees found to be under the influence of illegal or illicit drugs or alcohol whilst at work may be subject to disciplinary action which includes termination of their employment. The unauthorised use, sale, possession or distribution of any type of drug is prohibited at all times on IAG premises. If an employee is found to request, purchase, possess, distribute or use an illegal or illicit drug on IAG s premises then the employee will be subject to disciplinary action which includes termination of their employment. The Group provides the services of a confidential Employee Assistance Program to assist employees in the treatment of alcohol or drug use problems. PAGE 29 Insurance Australia group Code of Conduct

32 YOUR RESPONSIBILITIES It is the responsibility of all employees to ensure that they work in a manner consistent with this Code and to report any possible breaches of the Code to your Manager, HR Business Partner/representatives, Risk and Compliance Manager or via the incident reporting page on the intranet. To ensure that all employees understand their responsibilities under the Code of Conduct, every employee is required to complete the online Code of Conduct course. If you are unsure about any aspects of this Code please speak to your manager. Employees who breach this Code of Conduct may face disciplinary action including termination of employment. Further information on matters covered in this Code can be obtained through your manager, HR Business Partner/representative and from policies on the intranet. Insurance Australia group code of Conduct PAGE 30

33 Your Superannuation Choices Superannuation is an important benefit for all employees. Given the great degree of variety in personal circumstances, we suggest you seek independent financial advice on the best options for you. Attached, you will find a variety of supporting documents relating to the IAG & NRMA Superannuation Plan. You have the choice to either: 1. Join the IAG & NRMA Superannuation Plan or 2. Join another complying fund of your choosing PAGE 31 Insurance Australia group Your Superannuation Choices

34 1. Joining the IAG & NRMA Superannuation Plan The IAG & NRMA Superannuation Plan is one of Australia s largest corporate super funds with over 12,000 members. The plan provides a range of investment choices and benefits including insurance coverage for members. For information about the IAG & NRMA Superannuation Plan you can: 1. read the Product Disclosure Statement and the IAG & NRMA Superannuation Plan Annual Report available on this site, 2. visit the Plan website at or 3. contact the Plan Helpline on (1300 IAG NRM). To join this plan, complete the following forms: 1. IAG & NRMA Superannuation Plan Application Form 2. Change of Employee Contribution Form (if you wish to make additional contributions to superannuation from your pay) 3. election of STI to Superannuation Form (if you wish all or part or your future STI payments to be paid as superannuation contributions). Insurance Australia group Your Superannuation Choices PAGE 32

35 2. Choosing to join another super fund IAG can make contributions for employees to funds that are complying and which can accept contributions from IAG as your employer. Some funds can only accept contributions if the employer signs an agreement with the trustee to become a participating employer of the fund. Due to the large number of complying funds in Australia and the administration overhead involved, it is not viable for IAG to participate in these agreements To join another super fund, complete the following: 1. Complete the Choice of Superannuation Fund form 2. Contact your new superannuation fund and request a written copy of the following (these are standard forms for most superannuation funds) A letter from the trustee stating that the fund is a complying fund, or for a self managed superannuation fund, a copy of documentation from the Tax Office confirming the fund is regulated Written evidence stating that they will accept contributions from your employer Details about how IAG can make contributions to your chosen fund. The information required depends on the payment method 3. Return the completed forms with your other new employee forms for processing Note: Where paperwork is not processed in time for your first superannuation contribution, it will be made to the IAG & NRMA Superannuation Plan. It may take up to two months for your forms to be processed depending on the type of super plan arrangement. There will be processing delays where the form has been incorrectly completed or the required supporting information has not been provided. PAGE 33 Insurance Australia group Your Superannuation Choices

36 Types of Superannuation Contributions You Can Make IAG can make both employer and employee contributions to your preferred super fund. Employer (IAG) Contributions IAG values the contribution that super can make to people s future financial security and lifestyle. That s why our default contribution rate is 13%, four percent higher than the current Government minimum. In recognition that people have different financial needs and objectives at different times in their lives, IAG also provides pay flexibility. Employees can choose to vary their cash/super mix by: Keeping IAG s contributions at the default rate of 13%; or Decreasing IAG s contribution below 13% to a minimum of 9%, and electing to receive the difference in cash along with their regular pay Making additional voluntary contributions from before-tax or after-tax salary Note: If you wish to cash down your Super from 13% to the statutory 9%, you need to complete that request once you start with IAG via our Employee Self Service tool. IAG encourages people to seek independent financial advice when deciding how to structure their remuneration, and to think of both the short and long term financial objectives and implications. Employer (IAG) contributions for your STI and bonuses Part of short-term incentive (STI) and bonus payments are paid to employees as superannuation. The cash/super mix for incentives and bonuses is at the employee s chosen contribution rate (eg. 13% super is the default rate). Employees can control the cash/super mix for their overall level of pay by varying this rate for their fixed pay and incentives. Insurance Australia group Your Superannuation Choices PAGE 34

37 Employee (voluntary) Contributions Employees can boost their retirement savings by making their own super contributions. Employee contributions are voluntary. They can be varied at any time and can be made from: Before-tax salary, or After-tax salary, or A combination of your before-tax and after-tax salary You can choose to make your own contributions as a whole percentage of your salary starting at a minimum rate of 1%. Contributions cannot exceed 90% of salary and must be approved by IAG. What s best for you will depend on your own individual financial situation. Note that if you are making before or after-tax contributions, you should be aware of your concessional and non-concessional contribution limits and the implications of exceeding these. To make an employee contribution, please complete the Your Change of Employee Contribution Form. Employees also have the opportunity to contribute all or part of their potential short-term incentive (STI) into superannuation. Annual STIs are paid in September. The election to superannuation period is from November to January, however as a new employee you will also have one month from your employment date to elect to have all or part of your STI paid as superannuation. PAGE 35 Insurance Australia group Your Superannuation Choices

38 Additional Downloads The below documents provide you with further details on the IAG & NRMA Superannuation Plan. These documents and all Superannuation forms are available for you to access at IAG & NRMA Superannuation Plan Annual Report IAG & NRMA Superannuation Plan Short Form Product Disclosure Statement This document summarises some of the key features of the plan. Insurance Australia group Your Superannuation Choices PAGE 36

39 Your Fair Work Statement This Fair Work Statement is provided to all employees covered by the national workplace relations system and outlines details of the safety net minimum terms and conditions under the National Employment Standards. PAGE 37 Insurance Australia group Your Fair Work Statement