Ethics and risk management

Operating our business to the highest ethical standards and managing our risks and opportunities is essential for Vicinity to execute our Group strategy and ensure the long-term success of our business.

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

A suite of policies supports the Code to ensure our business operates to the highest ethical standards. These policies cover all aspects of the Code, including anti-bribery and corruption; fraud; money laundering; conflicts of interest; privacy; bullying and harassment; whistleblowing; and risk management.

To ensure that our people are aware of these policies and their obligations, we provide regular training.  All employees are required to complete training within six weeks of commencement of employment, and annually thereafter.

As part of Vicinity’s performance review process, our people are assessed against our values and the behavioural standards outlined in the Code. Short-term performance incentives are additionally linked to completion of related training.

Our people and culture, risk and compliance, and company secretariat 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. Vicinity adopts a structured and comprehensive approach to managing financial and non-financial risk and this approach extends to corporate governance and compliance risks.

For more information about our risk management practices see 2020 Corporate Governance Statement.  

Percentage of employees trained in our Code

Executive Committee:  


Our People: