Ethics and risk management

Operating our business to the highest ethical standards and managing our risks and opportunities are essential to realising our Group strategy and the long term success of our business.

Our Code of Conduct (the Code) outlines the high level of ethical business behaviour expected from our Directors, Executive Committee, employees and contractors.

A suite of policies (see left) supports the Code to ensure that our business operates to the highest ethical standards. These policies cover all aspects of the Code, including bribery, corruption and fraud, money laundering, conflicts of interest, bullying and harassment, whistleblowing and risk management.

To ensure that our people are aware of these policies, we provide annual Ethics and Conduct online training. As part of Vicinity’s performance review process, our people are assessed against our values and the behavioural standards outlined in the Code. 

Our governance, risk and people and culture teams are responsible for overseeing the Code and related policies.

Vicinity’s enterprise risk management framework helps us to identify, assess and manage material risks and opportunities within the bounds of Vicinity’s risk appetite. For detailed information about our risk management practices see 2017 Corporate Governance Statement.

Our risk management system and compliance plans are subject to an external audit every year to ensure their effectiveness and our adherence to the suite of policies. As required by Australian law, we report any significant breaches to the Australian Securities and Investment Commission.


Percentage of employees trained in our                               Ethics and Conduct policies  

Category Percentage of employees
Executive Committee 100%
Our People 93%


Policies that support our                     Code of Conduct

Anti-bribery and corruption policy

Fraud policy

Gifts and entertainment policy

Whistleblower guidelines

Related party transaction policy

Procurement standard

Conflicts of interest policy

Wholesale funds conflicts policy

Diversity and inclusion policy