Code of Ethics

As an industry leader, UGL is committed to setting the very highest standards of ethical business practices. Every individual working directly or indirectly for UGL shares a responsibility to uphold these standards and to conduct our business in a professional, open, safe, ethical and responsible manner. Ethical behaviour helps to create trust in the UGL brand and minimise risk to market confidence. Acting ethically underpins both the financial and non-financial goals of UGL such as our commitment to environmental protection, sustainability, fair dealing with stakeholders and service quality and safety.

UGL’s Code of Ethics summarises the essence of our corporate governance practices, corporate responsibility and our Code of Conduct.

This Code sets out the standards of behaviour required of our people in dealing with colleagues and contractors as well as those outside the company including clients, business partners, suppliers, shareholders or other stakeholders.

Our Code of Ethics underpins our social, ethical and environmental commitments and sends a powerful message to all our stakeholders of UGL’s commitment to responsible business practices.

There are five sections of the Code which outline the standards of ethical behaviour that we adhere to:

Relations with our employees

Our people are the key to the success of the Company.  We respect and value the individuality and diversity that every employee brings to UGL and seek to create a positive and open working environment.

  • We are committed to employee relations that respect the dignity and diversity of individuals and fair treatment for all.
  • We aim to recruit and promote employees on the basis of their suitability for the job, without discrimination.
  • We aim to foster effective communication enabling all our employees to perform their work to the best of their ability.  Employees will be assisted and encouraged to develop the skills to progress their careers.
  • We place the highest priority on the health and safety and ethical conduct of our employees in the workplace.
  • We do not tolerate any form of discrimination, victimisation or sexual, physical, mental or other harassment of any kind toward our employees.
  • We operate in accordance with fair and just remuneration policies.
  • We require any employee with a potential conflict of interest to disclose it to their line manager.
  • We operate in an environment of trust and as such we do not tolerate any fraudulent, unethical or dishonest behaviour by our employees either within the Company or in dealing with other stakeholders.
Relations with our clients

Our continued success and the loyalty of our clients relies upon our delivery of superior quality, service and choice.

  • The quality and safety of our processes, products and services must never be compromised.
  • We aim to provide a high level of client service at all times.
  • All client information is treated as confidential.
  • We never deliberately give inadequate or misleading descriptions of our products or services.
  • UGL and its employees must comply with the Anti-Bribery and Corruption Policy and Guideline in our dealings with our clients.  No employee may offer or receive (or influence others to offer or receive) any money or material gift that could be construed to be a bribe.  This includes the offer or receipt of facilitation payments.
  • In accordance with UGL’s Code of Conduct, an employee will follow the protocol and guidelines for accepting or providing a gift or hospitality which includes approval by a business unit manager to a value of no more than AUD 150.00 and no more than once a year.
Relations with our investors

The Company’s success is built upon the trust and confidence of our investors, and we remain dedicated in protecting their interests.

  • We aim to generate an attractive, long-term rate of return through the responsible use of assets.
  • We are committed to the highest standards of corporate governance and accountability.
  • Our accounting statements will be true, timely, complete and material, and available in an easily understandable form.
  • We are committed to the principles of market integrity and take our regulatory obligations seriously which include continuous disclosure to the market of company announcements.
Relations with our suppliers and subcontractors
  • We seek to establish mutually beneficial relationships with all our suppliers and contractors so as to encourage them to match our high standards in respect of quality, safety, ethical conduct, working conditions, trading practices, and environmental sustainability.
  • We treat our suppliers and contractors honestly and fairly.
  • We will comply with our obligations under the Anti-Bribery and Corruption Policy and Guideline in our dealings with suppliers, contractors and other third parties.
  • No employee or contractor on behalf of UGL may offer or receive, or influence others to offer or receive, any money or material gift that could be construed as an attempt to bribe or influence a decision.
  • We will not make facilitation payments in any circumstances.
  • All information concerning the Company and its suppliers and contractors is to be treated as confidential.
  • We do not work with companies who breach the law and/or endanger UGL’s reputation.
Relations with governments and the wider community

Success in business is dependent on compliance with legal obligations, together with sensitivity to local customs and conventions governing business relationships.  The communities where we operate and draw our employees are important to our future.

  • We are committed to making a positive contribution to the sustainable development of the communities where we operate.
  • We take into account the interests of the wider community, including national and local interests, in all our dealings. We use our expertise to contribute to the wellbeing of the community.
  • We take steps to ensure we are not exploited for the purpose of money laundering, drug trafficking or tax evasion.
  • We are committed to and take steps to prevent and detect bribery and corruption.
  • We do not make donations to political party funds or candidates.
  • We respect the law, traditions and cultures of the countries and communities affected by our dealings.  When there is an apparent conflict between local custom and the principles and values set out in this Code, all employees, contractors and others acting on our behalf must be guided by this Code.
  • We are committed to upholding human rights with particular reference to the people who are affected by our presence in emerging market countries.
  • We are committed to doing our business in a way that minimises environmental impact. 
  • UGL’s Environmental Policy outlines our commitment on waste reduction and recycling, and the conservation of water and energy.
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