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

A suite of policies (see left) 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 online training known internally as, ‘Your obligations in 10’.  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 compliance, 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. As a part of our annual risk review process Vicinity assesses all risks related to the nature and markets of our business operations. This includes corporate governance and compliance risks considered under the Code, covering all of our operations.  For detailed information about our risk management practices see 2018 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 that support our Code.If any significant breaches were to occur they would firstly be reported to the Board and, as required by Australian law, then reported to the Australian Securities and Investment Commission.

Percentage of employees trained in our Code

Executive Committee:  


Our People:



Policies that support our Code of Conduct

  • Securities Trading Policy
  • Conflicts of Interest Policy
  • Anti-Bribery & Corruption Policy
  • Privacy Policy
  • Disclosure and External Communications Policy
  • Gifts and Entertainment Policy
  • Health and Safety Policy
  • Employee Conduct and Performance Management
  • Policy and Procedures
  • Vicinity Regulatory Training Policy
  • Vicinity Compliance Management Policy
  • Procurement Standard