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Welcome from the Managing DirectorWhether you're working for or with us here at Tourism Australia, this Code of Conduct isrelevant to you. It sets out the values we hold and the standards of behaviour expected of us,and also touches on other Tourism Australia policies that are important to be familiar withregardless of your seniority or role here.While this Code does not and cannot address every issue of conduct or ethics that may arise,in many cases its principles should point to an answer. Where questions do arise, you'reencouraged to discuss them with experienced and respected colleagues.Employees, contractors, agents, interns, and anyone else affiliated with Tourism Australia canbe subject to a high degree of public scrutiny. Accordingly, we must remember that theindividual manner in which we conduct ourselves can have a major bearing on TourismAustralia's reputation and long-term viability.We operate in a complex environment with various political, legal, commercial and geographicimperatives that do not always align. While this can present challenges, it is simply part andparcel of marketing Australia abroad. Tourism Australia has a number of global offices as wellas agents who work independently in smaller markets. The organisation is active in several keymarkets. Given the associated complexities, this Code is essential so that we have a clear anddefinitive set of standards for conduct.We must continue to demonstrate to our stakeholders that we as Tourism Australia employeesmanage ourselves and our business dealings efficiently and exhibit integrity, transparency andprofessionalism at all times. Consider this Code a foundation for the learning you'll do at TourismAustralia; it should help steer you toward the right path and set the context for future decisionmaking.Our desire to strive for excellence means we set a high standard for ourselves and the peoplewe work with. With this in mind, we're glad to welcome you to our great team.John O’SullivanManaging DirectorTourism AustraliaContent owner: General Manager, People & CultureThis document: Code of ConductApproved by the Managing Director on: 5 November 2018Version No. 8Page 1 of 11
ContentsCorporate Values and BehaviourPage 3Ethical ConductPage 4Ethical Decision-MakingPage 4Duties of Employees under Commonwealth LegislationPage 5Respect for the LawPage 5Sexual HarassmentPage 5Harassment, bullying and discriminationPage 6Corrupt conduct and reporting wrongdoingPage 6Conduct at work functionsPage 7Conduct in social mediaPage 7Dress codePage 8Official information, power and privilegesPage 8Intellectual PropertyPage 9Official facilities, equipment and other resourcesPage 10Government relations, political material and activitiesPage 10Conflicts of interestPage 10Secondary employmentPage 11Entertainment expenditure and working mealsPage 12Acceptance of codePage 13Content owner: General Manager, People & CultureThis document: Code of ConductApproved by the Managing Director on: 5 November 2018Version No. 8Page 2 of 11
Corporate Values and BehavioursThe values that an organisation holds will generally determine its workplace culture. Broadly, Tourism Australia’s five corevalues are United, Positive, Genuine, Commercial and Innovative. As teams and as individuals, we embrace these valuesand ensure they are reflected in the actions we take and the decisions we make.To ensure we are UNITED and are one team: We value relationshipsWe communicate openlyWe respect others' opinionsWe trust each otherWe care for and support each otherWe are a global team and believe our differences are our strengthWe are inclusive and treat each other fairlyWe don't compete against each otherWe don't leave people out or show favouritismWe don't operate in silos or focus on our own team at the expense of other teamsWe don't keep information or resources to ourselvesWe don't consult with the same people every timeTo ensure we are POSITIVE and optimistic: We are optimisticWe believe in ourselves, and each otherWe celebrate the small wins & the big winsWe nurture talentWe look for opportunities to developWe are welcomingWe want everyone to enjoy their workWe don't gossipWe don't let our own emotions impact how we treat othersWe don't tolerate bullying or discrimination in any formWe don't overlook the contribution of people or teams who work 'behind the scenes'To ensure we are GENUINE and authentic: We truly believe in what we doWe feel a connection to Australia, the land and its peopleWe act with integrity at all timesWe accept responsibilityWe have hard conversations with kindness and respectWe offer constructive solutionsWe do what we say we will doWe don’t accept insincerityWe don't think or act like we're better (or more important) than other peopleWe don't point the finger or blame others (especially to avoid our own accountability)We don’t leave issues unaddressedWe don’t engage in fraudulent, dishonest or unethical behaviourContent owner: General Manager, People & CultureThis document: Code of ConductApproved by the Managing Director on: 5 November 2018Version No. 8Page 3 of 11
To ensure we are COMMERCIAL and deliver results: We deliver results and are driven by the success of the Australian tourism industryWe treat every dollar as our own to ensure we add valueWe engage with risk and have confidence in our judgementWe are committed to excellence in all we doWe think strategically at all levelsWe don't accept mediocrityWe don't waste moneyWe don't focus on things that aren't contributing to our strategyWe don't just put in the minimum effortTo ensure we are INNOVATIVE and are creative thinkers: We try new and daring ideasWe learn from success and failure so that we can put the best approach into actionWe collaborate globally for better solutionsWe always look for opportunities to improve our workWe don't discourage others from trying new ideasWe don't see failure as something negativeWe don't let hierarchy get in the way of moving quickly or getting resultsWe aren't afraid of making mistakesLiving the TA Way Values Poster is attached at Appendix A.Content owner: General Manager, People & CultureThis document: Code of ConductApproved by the Managing Director on: 5 November 2018Version No. 8Page 4 of 11
Ethical ConductIn addition to our own corporate values and behaviours, there are fundamental standards of conduct expected of anyoneworking for the Australian Government, including entities such as Tourism Australia. The following is an adaptation ofthe Code of Conduct for Australian Public Service employees.Here at Tourism Australia, we always: Behave honestly and with integrity;Act with care and diligence;Treat others with respect and courtesy, and without coercion, bullying or harassment;Comply with all applicable laws;Comply with lawful and reasonable directions given;Maintain appropriate confidentiality about dealings with the Minister and Ministerial staff;Disclose and take reasonable steps to avoid any conflict of interest (real or apparent) in connection with ouremployment;Use Tourism Australia resources in a proper manner;Act objectively, impartially and free of conflicts of interest in the conduct of our duties;Behave in a way that upholds Tourism Australia's values and the good reputation and integrity of Tourism Australia; and,While on duty overseas, behave in a way that upholds the good reputation of Australia.We do not: Solicit or accept anything of value from a client or associate that might influence how we conduct our duties andresponsibilities;Provide false or misleading information in response to a request for information that is made for official purposes inconnection to our employment; or,Make improper use of inside information, or our duties, status, power or authority in order to gain, or seek to gain,a benefit or any other form of advantage for ourselves or any other person.Ethical Decision-MakingIf in doubt, we ask ourselves the following questions to determine whether an action or decision is ethical. Why is the action being taken/decision being made?Is the action or decision in the public interest and would it withstand public scrutiny?Is there authority for the action or decision?Is the action or decision based on facts or on generalisations?Is the action or decision consistent with government policy, Tourism Australia’s objectives and this Code?What will be the outcome for all parties involved?Is there a conflict of interest?Has natural justice been observed?Has the action or decision been made expeditiously or in a timely fashion?What are the risks associated with the action or decision?What are the other alternatives considered and why are they rejected?Will the supporting papers identify the individual merits of the action or decision?Content owner: General Manager, People & CultureThis document: Code of ConductApproved by the Managing Director on: 5 November 2018Version No. 8Page 5 of 11
Duties of Employees under Commonwealth LegislationTourism Australia employees must abide by the duties set out under the Public Governance, Performance andAccountability Act 2013: Duty of care and diligence – an employee must exercise their powers, perform their functions and discharge theirduties with the degree of care and diligence that a reasonable person would exercise; Duty to act honestly, in good faith and for a proper purpose – an employee must perform their functions honestly, ingood faith, and for a proper purpose; Duty in relation to use of position – an employee must not improperly use their position to gain or seek to gain abenefit or an advantage for themselves or any other person, or seek to cause detriment to Tourism Australia, anyother person, or the Commonwealth of Australia; Duty in relation to use of information – an employee must not improperly use information obtained throughemployment at Tourism Australia to gain, or seek to gain, a benefit for themselves or any other person, or seek tocause detriment to Tourism Australia, another person, or the Commonwealth of Australia; and Duty to disclose interests – an employee that has a personal interest that relates to the affairs of Tourism Australiamust disclose details of the interest.Failure to comply with these duties may result in disciplinary action, including immediate dismissal, and where applicable,criminal prosecution.Respect for the LawWe demonstrate respect for the law by complying with all applicable state, territory, Commonwealth and foreign/locallaws as directed. From time to time, grey areas may arise whereby this Code conflicts with a foreign/local law. In suchcases, the foreign/local law will take precedence. Breaches of law must be reported to the Executive General Manager,Corporate Services who can provide the appropriate advice and direction.Sexual HarassmentTourism Australia recognizes the right of all staff to be able to attend work and to perform their duties without beingsubjected to any form of harassment, including sexual harassment. We have a zero tolerance for sexual harassmentunder any circumstances. It is the obligation of every employee and contractor, at any level, to ensure that TA remainsfree from all harassment, including sexual harassment.Swift disciplinary action will be taken against any employee or contractor who is in breach of TA’s Sexual HarassmentPolicy.All staff must familiarise themselves with this Policy. Attendance at mandatory training as delivered from time to time isrequired. This Policy, as well as other policies and plans referred to throughout this Code, are available on TourismAustralia’s intranet.Content owner: General Manager, People & CultureThis document: Code of ConductApproved by the Managing Director on: 5 November 2018Version No.: 8Page 11 of 11
Harassment, Bullying and DiscriminationTourism Australia is committed to ensuring a safe business environment for our staff, which extends to protecting stafffrom psychological hazards in addition to physical ones. We treat each other and our stakeholders with courtesy andrespect, we are sensitive to the cultural backgrounds of others, and we refrain from behaviour that is, or could beconstrued to be harassment, be it sexual or otherwise. Unsafe and unacceptable behaviour including harassment,discrimination and bullying will not be tolerated.Discrimination against others on the grounds of race, colour, sex, sexual orientation, age, physical or mental disability,marital status, family responsibilities, pregnancy, religion, political opinion, national extraction or social origin or any otherground is illegal; any such incidents must be reported to the General Manager, People & Culture for appropriate action.For more information, refer to the Harassment, Discrimination and Bullying Policy or the Work Health and Safety Policy.Corrupt conduct and reporting wrongdoingAs custodians of public money we are held to a high standard of ethical and transparent conduct, and acknowledge thatincidents of corrupt conduct, including theft, fraud and bribery, expose Tourism Australia to significant reputational andfinancial damage. Accordingly, Tourism Australia has a zero-tolerance attitude toward such activity and considers itgrounds for immediate dismissal and, possibly, legal action.FraudFraud is defined as dishonestly obtaining a benefit, or causing a loss, by deception or other means. There is a mental orfault element to fraud; it requires more than carelessness, accident or error, and can be committed by an internal orexternal party (or both by way of collusion).Tourism Australia’s Fraud and Corruption Policy requires us all to: Manage fraud control within our areas of responsibility;Implement fraud risk management strategies where directed and participate fully in activities relating to fraudcontrol; and,Advise our Managers, the Executive General Manager, Corporate Services or the Managing Director of any concern,suspicion, or information related to fraudulent, corrupt or improper conduct and encourage others to do the same.For more information refer to the Fraud and Corruption Policy and Fraud Control Plan.Bribery, Kickbacks and Facilitation PaymentsBribery, often seen in the form of gifts, hospitality and travel, also carries material fines and criminal penalties. Bribery canalso take the form of kickbacks, whereby a pre-negotiated commission is paid to a bribe-taker as a quid pro quo forservices rendered, for example, through inflated or fraudulent invoices.Being on either end of a bribe is a serious offence. The following three elements when combined form a strong case forbribery; when identifying whether a circumstance constitutes bribery we consider:1.2.3.The provision of a benefit - Providing, offering or promising a benefit, or causing a benefit to be provided, offered orpromised to another person; the benefit does not actually need to be given, it is just the promise of the benefit thatcan be perceived as bribery.Whether that benefit is legitimately due - If the payment is under a contract there is no problem; it is when extrapayments are made that issues arise. It is of no relevance that the benefit may be considered ‘customary’ or ‘officiallytolerated’.Whether that benefit represents an intention to influence - Where there is an intention to influence someone in theexercise of their duties to obtain or retain business or an illegitimate business advantage.Content owner: General Manager, People & CultureThis document: Code of ConductApproved by the Managing Director on: 5 November 2018Version No.: 8Page 11 of 11
While some organisations may regard facilitation payments an acceptable and efficient means of doing business, TourismAustralia strictly prohibits the making or taking of such payments irrespective of whether cultural customs or geographiclocation would otherwise permit. Cases of facilitation payments are also considered grounds for immediate dismissal and,possibly, legal action.Grey AreasIn some instances it may be difficult to identify corruption. For example, there are legitimate circumstances where wemay give or receive a gift or benefit. The general rule for gifts and benefits is that we must not accept gifts, benefits orhospitality that will compromise, or appear to compromise, our integrity and objectivity in performing our duties, orcause, or appear to cause a conflict of interest. We may accept gifts, benefits or hospitality if they are in keeping with thegenerally accepted local customs and practice in the tourism and travel industry, and provided that such conduct is legaland can be publicly defended, or if their refusal would cause offence to the giver (provided that such conduct is legal andcan be publicly defended). For more information, refer to the Gifts and Benefits Policy.Reporting WrongdoingThe Public Interest Disclosure Act 2013 (PID Act) promotes integrity and accountability in the Australian public sector byencouraging the disclosure of information about suspected wrongdoing. Allegations of wrongdoing made under the PIDAct are known as 'public interest disclosures'. The PID Act also places certain legal obligations on public sector entities,including Tourism Australia.Tourism Australia's Public Interest Disclosure Policy sets out how we will meet our obligations under the PID Act, internalprocedures for handling public interest disclosures and guidance to staff who are considering making a disclosure. Formore information, refer to the Public Interest Disclosures Policy.Conduct at Work FunctionsTourism Australia is a social workplace where interaction between teams is encouraged. In this spirit, from time to timewe will be invited to workplace gatherings where alcohol may be consumed. It is important to remember that even in acasual atmosphere, we have a duty to behave professionally and exercise good judgement at work functions held eitheronsite or off. Those who fail to do so, or who bring Tourism Australia into disrepute as a result of inappropriate behaviour,will be held accountable under this Code.Supervising or coordinating managers of Tourism Australia functions have additional responsibilities to be alert to andcontinually monitor escalating situations, as well as take steps to manage situations. It is the responsibility of managersto manage their staff at work functions. For this reason, it is strongly recommended that these individuals establish andcommunicate protocols for dealing with possible situations prior to the actual function.Tourism Australia strictly prohibits the use of illicit drugs at its functions, on its premises or during other work-relatedactivities.If you suspect that you have a dependency problem with alcohol or drugs you are expected to seek counselling. TourismAustralia provides employees and their families with access to a free, confidential and professional counselling serviceunder its Employee Assistance Program (for staff in Australia) or other similar programs in-region. For more information,refer to the Employee Assistance Program Policy.Conduct in Social MediaWe acknowledge that our conduct in social media, either on behalf of Tourism Australia or as individuals in our own time,carries risks that may potentially negatively impact upon Tourism Australia if not managed properly. For this reason, apartfrom a limited group of employees who have explicit permission to represent Tourism Australia in social media forums,we do not lead others to believe we are commenting on behalf of, or in the name of, Tourism Australia. Where wecomment or share information on a subject that could be construed to be related to Tourism Australia, we discloseContent owner: General Manager, People & CultureThis document: Code of ConductApproved by the Managing Director on: 5 November 2018Version No.: 8Page 11 of 11
our professional relationship with Tourism Australia and provide a clear disclaimer that our views are our own, and in noway represent those of Tourism Australia.We are at all times mindful that the information we post or distribute on social media sites could be subject to publicscrutiny and refrain from listing or promoting our personal accounts on Tourism Australia account pages (e.g. Facebookpages or Twitter accounts).For those engaging in social media on behalf of Tourism Australia as part of their official duties, media enquiries andcontact with staff originating from such platforms, as well as all communication relating to issues management, requireprior approval from the Corporate Affairs Team. To request approval, email (and follow up by phone) the GeneralManager, Media & Communications or the Executive General Manager, Corporate Affairs.Personal communication on social media sites, redistribution of content originating from Corporate Affairs (e.g. retweeting a press release) and comments on/redistribution of purely destination content distributed by the marketingand PR teams (i.e. Facebook posts) does not require the prior approval of Corporate Affairs. For more information, referto the Communications Approvals Policy.Dress codeEmployees are expected to exercise good judgment and common sense in how they present themselves when representingTourism Australia. Whilst Tourism Australia is not necessarily a conservative workplace, it is important that staffdemonstrate respect towards their workplace, and courtesy towards others by exhibiting good hygiene practices andavoiding wearing clothing that is likely to be considered unprofessional, inappropriate or offensive.Management may exercise a degree of discretion when determining the standard of dress that will be adopted within eachoffice. In doing so, consideration will be given to stakeholder expectations, Tourism Australia’s reputation, the comfort andpreferences of employees, the standards of competitors and other tenants in Tourism Australia office buildings, climate,local custom and the type of work to be performed. Larger offices of Tourism Australia are typically situated in businessdistricts where the standard of dress is business attire. All employees are required to observe the guidelines establishedfor their office.The following is considered inappropriate workplace attire at all times: Soiled or torn clothing or shoes (whether deliberate or not); Sports attire such as gym gear and shorts Tank tops or halter tops Clothing that is too tight, too short or too revealing Apparel displaying offensive logosOn Fridays, staff may wear casual clothing to work however they should consider any meetings they have that day andwhat the appropriate attire might be.Managers have the right to ask employees to change into appropriate attire should this code not be adhered to. Repeatincidents may be regarded as failure to comply with Tourism Australia behavioural standards and result in performancecoaching or disciplinary action.Official information, Power and PrivilegesWe use the official information, and power and privileges bestowed on us responsibly and for a proper purpose. We alsoexercise care when providing information and advice both verbally and in writing, conscious not to abuse the trust placedin us.With this in mind, we do not: Use our official positions to obtain benefits for ourselves or anyone else;Solicit or receive benefits that will influence or give the appearance of influence on any decisions we may make; or,Content owner: General Manager, People & CultureThis document: Code of ConductApproved by the Managing Director on: 5 November 2018Version No.: 8Page 11 of 11
Influence or coerce others by intimidating them to compromise themselves in regard to this Code.For more information on how and by whom official information may be released, refer to the Privacy Policy and theCommunications Approvals Policy.Intellectual PropertyThe output of Tourism Australia's creative effort is paid for mainly with public funds. Accordingly, we acknowledge thatTourism Australia will own all rights (including any intellectual property rights) in any works, ideas, concepts, designs,inventions, developments, improvements, systems or other material or information (Materials) created by us: In the course of our employment;That relates directly or indirectly to our employment;That assists in the performance of our roles actually performed by us in the position of employment;That was created as the result of using Tourism Australia resources;That otherwise relates in any way to Tourism Australia business and activities.To the extent necessary to give effect to this provision, employees assign all of their intellectual property rights (includingany copyright) in any such Materials to Tourism Australia. To the extent permitted by law, employees also unconditionallyand irrevocably consent to any act or omission that would otherwise infringe his/her moral rights and waive all moral rightsthat they may have worldwide.If you would like to use Tourism Australia’s intellectual property for personal purposes, the Managing Director's writtenapproval will need to be obtained before doing so. For more information, refer to the Intellectual Property Policy.Official Facilities, Equipment and Other ResourcesTourism Australia has a number of policies on the use of its facilities, equipment and other physical resources. If in doubtabout which apply to you, you should speak to your manager about your role, responsibilities and the relevant policies.The following is a summary of the responsibilities that apply to all of us.We always: Use Tourism Australia resources and assets (facilities, equipment, physical resources, and communication media,including email and the Internet) in a proper manner, and only in the performance of our official functions unlessauthorised by our managers (e.g. email and Internet may be used for personal purposes provided this use is limited,and does not compromise or appear to compromise our work performance);Discourage others from misusing resources and assets;Avoid waste or extravagance in the use of resources and assets; Ensure that resources or assets under our care are carefully maintained and not exposed to theft. We do not: Use resources for political campaigns, fundraising and canvassing, or for personal gain; or,Use assets if intoxicated (any employee who damages Tourism Australia property as a result of intoxication,negligence or recklessness will be required to pay the full cost of replacement of the property, and will facedisciplinary action).Government Relations, Political Material and ActivitiesWe are expected to remain impartial when discharging our official duties and to refrain from the following if and whereit could be construed as being associated with Tourism Australia: Wearing or displaying political material;Making political contributions; or,Expressing political views that are not official Tourism Australia policy or Australian Government policy.Content owner: General Manager, People & CultureThis document: Code of ConductApproved by the Managing Director on: 5 November 2018Version No.: 8Page 11 of 11
We may, however, participate in political activities in our private time and provided such conduct cannot be construed asbeing representative of Tourism Australia’s political disposition, and that it does not affect our integrity and objectivity inperforming our duties.If you decide to stand for election to local, state or federal governments, it is your responsibility to seek legal advice as towhether you will be required by Australian law to resign from Tourism Australia.Working with childrenTA is committed to ensuring that appropriate protections are in place when working with children. Whilst TA’s corebusiness does not involve working with children, there may be rare circumstances where this is not the case. Wherethere is a reasonable expectation that staff or contractors will work with children, the General Manager People & Culturemust be consulted to determine whether a working with children check is required.Conflicts of InterestA conflict of interest can be defined as a conflict between the public duties and private interests of a public official, inwhich the public official has private-capacity interests which could improperly influence the performance of their officialduties and responsibilities. Conflicts of interest are of concern to the broader public service as even the appearance of aconflict can undermine the Australian Government's credibility and result in a loss of public confidence.There are two types of conflicts to be aware of so that we can avoid or manage them:1.2.Actual conflicts (e.g. personal financial interests); and,Perceived conflicts (e.g. familial relationships, associations, gifts, fraternisation).In the Tourism Australia context, conflicts of interest could include: Giving Tourism Australia business to a supplier/company that you hold shares in;Being treated to lunch by a tenderer who is competing for Tourism Australia business in an active tender selectionprocess; or,Accepting a hotel’s offer of free accommodation in return for choosing to partner with that hotel for a TourismAustralia campaign.We must not allow the pursuit of private interests to interfere with the proper discharge of our official duties, and musttake reasonable steps to avoid any relationship, situation or activity that could: Affect our independent judgment or influence decisions made during the course of our employment;Conflict with Tourism Australia interests or policies; or,Lead to the appearance of affected judgment or decisions, or conflict with Tourism Australia interests or policies.Accordingly, we do not: Solicit or accept from any person any financial reward or non-financial benefit for the discharge of our duties overand above our official remuneration; or,Solicit or accept any benefit, advantage or promise of future advantage whether for ourselves or for our immediatefamily or any business concern which we are associated with, from pe
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