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Corporate Code of Conduct
This code of conduct applies to directors and to all employees of
- Reef Corporate Services Limited (“responsible entity”);
- Reef Casino Trust (“trust”); and
- The Reef Hotel Casino (Casinos Austria International (Cairns) Pty Ltd) (“operator”).
The Board of the responsible entity supports the ongoing need for directors and employees to demonstrate the highest level of behaviour and ethics. The purpose of this code is to
- Inform directors and employees of the Board’s expectations of them
- Ensure compliance with legislation relevant to an employee’s responsibilities
- Fulfil the expectations of our unit or shareholders
- Maintain confidence in the integrity of the responsible entity, the trust and the operator and to preserve and enhance our corporate reputation
1. Conflicts of interest
Directors and employees should avoid any activities that involve or could appear to involve a conflict of interest between their own personal interests and the interests of their employer.
Directors and employees should not seek to obtain an advantage for themselves or others from information gained through their employment or seek to use their position as directors or employees to obtain an advantage for themselves or others.
Examples of potential conflicts of interest include
- An employee initiating a purchase of goods or services from a company associated with that employee or that employee’s relatives
- Being involved in the employment of a relative or directly supervising a relative in the workplace
To avoid conflicts of interests directors and employees must
- declare any conflict of interest to senior management or the Board as soon as they become aware of any conflict or potential conflict in relation to a customer, supplier or service provider
- declare any direct line management relationship between family (spouse, partner, children, parents, siblings)
- Not seek or accept offers of money, gifts, favours or entertainment which might influence or appear to influence the making of a business decision. An employee receiving a small gift (eg at Christmas time) or an invitation to a sporting or social event should seek approval from their manager before accepting.
- Not be involved in any other business or position outside their employment that may result in the employee being unable to effectively carry out their duties and responsibilities to their employerSeek approval of senior management or the board before accepting a directorship on the board of another company
- Always use company property for the use it was intended and not for personal use unless properly authorised.
Directors and employees should discuss any concerns regarding actual or potential conflicts of interest with their manager (the Chairman for directors).
2. Trading in Reef Casino Trust Units (Insider Trading)
Directors and employees must not trade in Reef Casino Trust units, influence others to trade or communicate information to others if they are in possession of price sensitive information which is not available to the share market.
The Reef Casino Trust’s unit trading policy sets out guidelines for directors, officers and senior managers.
Employees should decline to comment on the state of the company or the value of RCT units.
3. Confidentiality
Directors and employees are required to protect information that is confidential to their employer. These obligations of confidentiality continue after an individual's employment has ceased.
Information that is not generally available concerning the operation or strategies of their employer must be used for authorised purposes only, and must not be disclosed to outside parties without proper authority.
Directors and employees must not make public statements unless expressly authorised to do so.
4. Compliance with law
The Reef Casino Trust Compliance Committee and Compliance Plan have been established to ensure compliance with legislation including the Corporations Act, the Trust Constitution and the Casino Control Act.
In addition, directors and employees must comply with the letter and the spirit of all laws and regulations.
All directors and employees are expected to understand the laws that affect both their roles and their general business conduct. If an employee is unclear of the impact that the law may have on their role, they should seek advice from the Company Secretary of the responsible entity.
Any instances of non compliance with the law are to be reported to the Compliance Officer.
5. Privacy
Employees must respect the privacy of customers, other employees and unitholders and only use information for the purpose it was collected.
6. Treatment of others
Employees must treat customers, unitholders, suppliers and fellow employees fairly, honestly and in an open manner.
Discrimination and harassment in any form is unacceptable.
7. Political contributions
Directors and employees must not make any political donations on behalf of the responsible entity, trust, or operator, unless authorised by the Board.
8. Gambling at the Reef Hotel Casino
Directors and employees must not (directly or indirectly) gamble at the Reef Hotel Casino. They should not approach any of the gambling outlets/facilities, including the gaming tables, gaming machines, TAB, Keno and Reef Club at the complex at any time.
9. Compliance with code of conduct
All Directors and employees are responsible for ensuring their own individual compliance with this code. Employees are encouraged to report any actual or potential breaches of the code to management or the Board without fear of retribution in accordance with the whistleblowers policy.
10. Annual review of code of conduct
The Company Secretary of the responsible entity is to conduct an annual review of the code to ensure it continues to reflect the law and the Board’s commitment.
Employees are encouraged to report any difficulties or challenges in complying with or in understanding the code to the Company Secretary of the responsible entity and this will assist in the annual review of the code.
Amended and approved by the board on 16 July 2008
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