Code of Conduct

Achieving together
We work together, build trusting relationships and consider the impact of our actions. We look for ways to contribute to a better future for our people, our communities and the environment.

Owning it
No matter where we work, our role or where we are from, we have standards to which we hold ourselves and each other accountable. We strive to make the right choices every time. We do what we say we are going to do and take responsibility for our actions.

Valuing everyone always
We value each other and create an environment where everyone’s voice is heard and respected.

Delivering our best
We strive for excellence in everything we do, to optimise performance and productivity. In doing so, we deliver for our teams, our customers, our organisation and ourselves. We learn from the past while embracing innovation and change.

Our success depends on the application of our values. We need to live these to protect our reputation, resources and business relationships. This applies to our dress and behaviour in the workplace and in all situations where we are representing Fremantle Ports, or associated with or affecting the workplace. This includes work-related events such as conferences, work functions and business trips.

We treat everyone we deal with, including our colleagues, customers, the community and other stakeholders with respect, courtesy and fairness always, having proper regard for their interests, rights, safety and welfare. We promote equal opportunity and diversity and do not tolerate harassment, discrimination or bullying, vilification, occupational violence or victimisation on any grounds.

We take safety and the protection of the environment within which we operate seriously. We are guided by our values, environmental and work health and safety laws, regulations, standards and our own policies and procedures. We take care to ensure our and everyone else’s safety, health and wellbeing at work, and we ensure we’re fit for work every working day. Unsafe work is stopped immediately. Safety and environmental incidents are reported and acted on.

We are ethical and make decisions based firmly upon principles of honesty
and integrity. We are accountable for our decisions and actions, putting the
organisation’s interests before our own or other interests. This is integral to
maintaining the trust and confidence of our people, customers, stakeholders
and the community.

We make decisions fairly, impartially, and promptly, and consider what is in the best interests of the organisation based on all available information, legislation, policies and procedures. We provide timely, well-considered information and advice, and act with the best intent and diligence.

We comply with and follow all lawful and reasonable directions, and do not hinder or obstruct anyone acting in an official capacity in relation to legislation, policy, standard or procedure.

We observe the applicable laws and regulations, and all Fremantle Ports’ policies and procedures wherever we operate. Where the Code or a policy sets higher standards of behaviour than local laws, rules, customs or norms, the higher standard will apply. We are accountable for making ourselves aware of these requirements so that we understand and comply with our obligations.

We do not tolerate fraudulent, corrupt or other improper conduct by our directors, personnel, contractors or consultants. Fraud is a dishonest activity that causes actual or potential financial loss to any person or our organisation. Corrupt conduct occurs when an employee uses or attempts to use their position for the benefit of themselves or others, or to cause a detriment to others. Our commitment to operating with integrity and preventing fraudulent or corrupt activities is part of who we are and what we do every day.

This means we do not:
• engage in behaviour or conduct that is fraudulent, corrupt, misleading or
deceptive
• tolerate or accept behaviour or conduct that is fraudulent, corrupt,
misleading or deceptive by others, including from those supplying services
• make use of Fremantle Ports’ systems, property or its position to gain or
seek improper benefit for ourselves, the organisation or a third party
• support or deal with any person or business knowingly involved in bribery
or corrupt practices.

Community confidence in ethical decision making can be lost when fraudulent
or corrupt behaviour occurs. Left unchecked, fraudulent and corrupt behaviour
can undermine the culture of our organisation. It can damage the reputation
of Fremantle Ports and our people. It may also result in disciplinary action,
including termination of employment. Fraud or corrupt behaviour by Fremantle
Ports personnel (who are public officers) is also considered criminal conduct.

A conflict of interest is a situation arising from conflict between the performance of your role at Fremantle Ports and your own private or personal interests. Conflicts may involve private, financial or political interest and may be actual, perceived or potential. It is not wrong for an employee to have a conflict of interest; what matters is how it is reported and managed. Conflicts of interest become a problem when an employee’s private interests influence their decision making at work.

Examples of potential conflicts of interest include, but are not limited to:
• holding a position or being engaged in outside work (which may be paid or unpaid) or
• having an interest in a business that is a competitor, supplier, contractor, client or other entity that has any association directly or indirectly with Fremantle Ports or the work of Fremantle Ports.

Receiving gifts, benefits or hospitality from external parties also has the potential to place us in a position where we feel conflicted and are compromised. We may be offered hospitality as part of our work but it is not always appropriate to accept it. We must avoid situations that present an actual, perceived or potential financial or moral obligation to another organisation or individual.

To protect ourselves and Fremantle Ports, we will take all reasonable steps to avoid actual, perceived or potential conflicts of interest in connection with our work and disclose any hospitability offered or received.

This means we will:
• act honestly and in the best interests of Fremantle Ports
• openly declare private interests and affiliations that may conflict with or be perceived to conflict with Fremantle Ports’ interests
• ensure decisions are accurately recorded so that they are transparent and able to be reviewed
• follow legislated and/or policy requirements for managing actual, perceived, or potential conflicts of interest
• refuse any gift, benefit or hospitality that is likely to place yourself or Fremantle Ports under an actual, perceived or potential commercial, moral or ethical obligation to other organisations or individuals
• ensure that the acceptance (or refusal) of gifts, benefits or hospitality is in accordance with Fremantle Ports’ policy and is recorded in the Gifts and Benefits Register
• respond with ‘No thanks, it’s all in a day’s work’, when unsure of how to react when offered a gift or benefit

Fremantle Ports is accountable to the Minister, the Western Australian Government and the people of Western Australia, so our use of resources must be in the public interest and transparent.

Our resources are also an important part of our business. They include our facilities and equipment, vehicles, materials and supplies, computer and telephone networks, money and time. They also include intellectual property: our ideas and know-how, customer and supplier information and market data. We are committed to ensuring they are treated appropriately with care, responsibility and respect always.

This means we will:
• only use Fremantle Ports’ resources for business purposes
• take care to prevent waste, loss, damage, misuse or theft of resources
• comply with applicable policies, processes, guidelines and laws regarding the acquirement, use and/or disposal use of resources
• report any damage or loss of property or equipment immediately.

We are required to maintain confidentiality and protect private information, and we must not make improper use of information obtained in our duties. We respect the privacy of individuals and are committed to the security of confidential and personal information. Confidential, sensitive and personal information may only be used for authorised purposes and may not be disclosed without appropriate authorisation.

We are all responsible for creating and managing records appropriately, and we need to take particular care in the way information is recorded and handled, including confidential and sensitive information.

Making and maintaining proper records also assists with accountability and transparency by demonstrating the basis for decisions and the process we use to make the decision.

Therefore we:
• record actions, decisions and transactions properly to ensure transparency
and accuracy
• make use of the correct information system for the various types of
information and task
• ensure information, including confidential information, is recorded, handled
and securely stored in accordance with recordkeeping and archiving
procedures
• obtain authorisation before altering or destroying records.

We recognise that social media is an important tool for business, and it is increasingly used for work and personal communications. At the same time, all personnel understand and work within the boundaries that exist between the use of social media for business purposes and personal use, ensuring we:
• comply with relevant policies, processes and guidelines related to
social media
• do not make comments in a personal capacity that are seen to represent
the views of Fremantle Ports where you are identified as a Fremantle Ports
employee
• do not create any interference to our daily duties
• make it clear that our online posts are our own views and not those
of Fremantle Ports.

We have high expectations of performance and conduct of all our people, but we have the highest expectations of our leaders. We expect our leaders to always:
• role-model behaviours consistent with our Code, values and safety
practices
• create a respectful, courteous and professional work environment
that embodies our values and Code
• make ethical and transparent decisions consistent with our Code
• encourage our people to communicate openly and address concerns
• hold all personnel to account, regardless of position or seniority
• act in a timely manner to address any concern or breaches of the Code.

We take breaches of the Code, our policies and procedures, employment agreements and any other laws or regulation that apply seriously. Fremantle Ports aims to ensure that concerns about an employee’s conduct are addressed, with the aim of improving conduct so that it meets our expectations. Personnel will be treated in a fair and equitable manner in the process.

Depending on the circumstances, action to improve an employee’s conduct may include education, training, coaching or performance management. Breaches may also result in disciplinary action, including termination of employment.

If you breach the Code or break the law, we may be required to report the incident to the Public Sector Commission, the Corruption and Crime Commission, the WA Police or other appropriate authority.

We support anyone raising or helping to address concerns regarding a breach. The reporting of concerns or alleged breaches must be reasonable. There is no requirement to have all the facts to prove the wrongdoing but the report must be based on reasonable likelihood of a breach having occurred. Reports that are found to be vexatious or frivolous may constitute a breach of the Code. Reports may be made anonymously; however, you will not be able to receive updates in relation to your report.

Fremantle Ports will ensure that concerns and disclosures are managed confidentially and impartially and will provide reporting personnel with support and protection from reprisal. Personnel must manage information confidentially and, once a report is made, take no further action until advised by the relevant officer managing the alleged breach.