insurance australia group – code of ethics page i - Realview

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insurance australia group – code of ethics page i - Realview

WelcomeWelcome to Insurance Australia Group (IAG).As a new employee of IAG, you will be joining a strong and vibrant group who is aleader in the insurance industry.To find out more about Insurance Australia Group including our brands, history andthe way we do business, visit our corporate website at www.iag.com.auOn this website you will find a variety of material to support the offer of employmentyou have received.Feel free to browse and review the content and related websites. We suggest youvisit the ‘Where to from here’ page next to understand the steps required to acceptyour offer of employment and what paperwork you need to complete to become anemployee of IAG.If you have any questions, feel free to contact the IAG manager who has hired you inregards to the offer, or for assistance in completing your forms, contact CGU HumanResources on (03) 9601 8330.We look forward to welcoming you to the IAG team.Our Business model and brandsDIRECTINSURANCEINTERMEDIATEDINSURANCEONLINEINSURANCEDIRECTINSURANCEDIRECTINSURANCEINTERMEDIATEDINSURANCEAmAssuranceAUSTRALIANEW ZEALANDINTERMEDIATEDINSURANCEASIAINTERMEDIATEDINSURANCEUNITED KINGDOMOTHERACTIVE PORTFOLIO MANAGEMENT & GOVERNANCEPAGE 1Insurance Australia group – Welcome


The Way WECHOOSE TO DOBUSINESSINSURANCE AUSTRALIA GROUPCODE OF ETHICSThe Way We Choose To Do Business sets out our expectations of every person atIAG. Everyone at IAG is responsible for achieving the highest levels of businessconduct and we are all accountable for delivering our everyday activities in a way thatreflects the ethical principles set out in this Code.PAGE 3Insurance Australia groupcode of ethics


Contents1. INTRODUCTION TO OUR ETHICAL PRINCIPLES 2. IAG PURPOSE & principals3. IAG VALUES4. THE WAY WE OPERATE – OUR GOVERNANCE Financial CrimeDealing with GovernmentsBribery and CorruptionGifts, Entertainment and Other BenefitsRisk ManagementUse of Third Parties and AgentsUse of Information SystemsIntellectual PropertyPublic Disclosure of Company InformationConflicts of InterestInsider TradingHuman Rights5. THE WAY WE WORK – OUR PEOPLE Working at IAGManaging Our PeopleDeveloping Our PeopleEqual OpportunityDiversityCultural SensitivityWork and LifeOccupational Health and SafetyRemunerationSpeaking UpGrievancesOur Rights at WorkPolitical ActivityPAGE 5Insurance Australia groupcode of ethics


6. THE WAY WE HELP – OUR CUSTOMERS Helping Our CustomersCustomer ComplaintsThe Privacy of Our CustomersAccountability for Our MarketingAccess to InsuranceSupporting Industry Standards and CodesTrade and Competition7. THE WAY WE HELP TO REDUCE RISK – THE COMMUNITYAND THE ENVIRONMENT Community EngagementCommunity InvestmentUnderstanding InsuranceDisadvantaged GroupsEnvironmental Risks and OpportunitiesRecognising Our ImpactOur Environmental ManagementClimate ChangeAdvocacy8. RESOLVING ETHICAL DILEMMAS9. ASKING FOR ADVICE AND REPORTING CONCERNSPlease consider the environment before printingthis documentInsurance Australia groupcode of ethics PAGE 6


1. INTRODUCTION TO OUR ETHICALPRINCIPLESWhat is the Code of Ethics?The IAG Code of Ethics (the Code) provides the basic foundations that help guide ourethical conduct.The Code is not meant to replace our detailed policies, rather it is a statement of our basicethical principles in a number of important areas.Codes of conduct, while consistent with the Code, will provide more specific guidance andmay vary across regions, depending on the legal and regulatory rules that apply.Our Foundation – who are we and what we stand forIAGValuesIAGPurposeIAG Ethical PrincipalsIAGGroup-widepolicies andproceduresRegionalcodes ofconductLocalpolicies andproceduresPAGE 7Insurance Australia groupcode of ethics


What are Our Ethical Principles?The Code expresses the fundamental ethical principles that are applicable across all parts ofthe business, regardless of the country of operation.Our ethical principles are provided to help guide each of our people when they make ajudgement on what is right, proper and appropriate in a given situation. These ethicalprinciples will assist us in:• Determining the most appropriate way to deliver on IAG’s purpose to help people managerisk and recover from the hardship of unexpected loss; and• Bringing the IAG values of performance, integrity, respect and a considered sense ofurgency to life in our daily behaviour.These principles are organised into four areas:1. The Way We Operate – Our Governance;2. The Way We Work – Our People;3. The Way We Help – Our Customers; and4. The Way We Help to Reduce Risk – the Community and the Environment.What are Our Expectations?For each of us our ethical behaviour is a series of choices and decisions.At IAG we are all accountable for ensuring that these decisions are in accordance with alllaws and regulations of the countries in which we operate, as well as being consistent withour ethical principles as set out in this Code and the IAG policies and standards that relatedirectly to our duties.We are all expected to be proactive in identifying behaviours that are not in accordance withthe Code and to address them or report them as appropriate. We promote a culture thatencourages us to raise issues of concern as they are identified rather than concealing orignoring them.Who Does the Code Apply to?The Code applies to:• All employees of entities where IAG has majority ownership or which are otherwiseconsidered to be IAG subsidiaries; and• All non-executive directors.Insurance Australia groupcode of ethics PAGE 8


2. IAG PURPOSEIAG’s purpose is to help people manage risk and recover from the hardship of unexpectedloss. To be true to this purpose, each of IAG’s operating businesses must live by a set ofagreed principles.IAG PrinciplesExperts in the fundamentals of insurance. This means excelling at understanding andpricing risk, managing claims and distributing our products. And that’s because weunderstand the importance of what we do.Disciplined business leaders. We’re not just good at insurance, we’re good at business.We are high performing and professional.Passionate about our customers. At every interaction, we demonstrate our passion forour customers. This gains our customer trust and loyalty, and means our customers areour advocates.Innovative and one step ahead. We’re determined to keep moving and be one step aheadof our competitors. By listening to our customers, we stay relevant and generate new ideas,cementing our competitive advantage.Sustainable, so we’re around for the long term. At IAG, our definition of sustainablebusiness is one which delivers for our shareholders, customers, people and the communityby taking a balanced approach.PAGE 9Insurance Australia groupcode of ethics


3. IAG valuesThe foundation of all we do is what we value as an organization. At IAG, what we valuedetermines the behaviours that drive the performance that is required by our shareholders,employees and customers.We value PERFORMANCEIn the way that we collaborate to deliver the highest level of sustainable business outcomesfor our shareholders, customers and communities.We value INTEGRITYThrough the application of the highest standards of honesty and openness in our interactionswith colleagues, customers, shareholders and other stakeholders.We value RESPECTIn the way that we treat our customers and colleagues, and for the diversity thatthey represent.We value A CONSIDERED SENSE OF URGENCYIn the way that we approach our business with a “Can-do” attitude.Insurance Australia groupcode of ethics PAGE 10


4. THE WAY WE OPERATEOUR GOVERNANCEFinancial CrimeWe are committed to preventing, detecting and investigating financial crime and working withother organisations to reduce opportunities for fraud or criminal misconduct.Dealing with GovernmentsWe respect the authority of governments in the countries in which we operate and arecommitted to maintaining honest, open and cooperative relationships with governments andregulatory officials. We believe in remaining impartial in relation to party politics.Bribery and CorruptionWe value open and honest relationships with all parties and believe that bribery andcorruption should not play any part in our business dealings, including influencing abusiness relationship or decision.Gifts, Entertainment and Other BenefitsWe believe that gifts, entertainment and other benefits can compromise our ability to makeobjective and fair business decisions and should only be accepted where they cannot beperceived to unfairly or illegally influence a business relationship or decision and are withinreasonable limits.Risk ManagementWe believe that managing risk is vital for the sustainability of IAG and supports theachievement of our business goals. We want to maintain a proactive risk culture thatdelivers consistent risk management behaviour.Use of Third Parties and AgentsWe believe in using agents or third parties to represent IAG’s interests where it is the mostefficient way of doing business and for them to do so according to our ethical principles.Use of Information SystemsWe believe that our Information Technology must be used responsibly and that we have aresponsibility to protect company information communicated or stored using these systems.PAGE 11Insurance Australia groupcode of ethics


Intellectual PropertyWe are committed to respecting the Intellectual Property rights of third parties and toprotecting our own Intellectual Property rights attached to the work of all our people, includingensuring that our people take appropriate measures to safeguard our Intellectual Property.Public Disclosure of Company InformationWe believe in communicating with all of our stakeholders in a way that is transparent,honest, accurate and timely and respects privacy and other legal requirements.Conflicts of InterestWe believe that our people should avoid situations where personal or professional interestsconflict or appear to conflict with carrying out their responsibilities as representatives of IAG.Insider TradingWe believe that our people must ensure that they do not use inside information in anytrading by them in securities issued by entities within IAG and that they do not communicateinside information to another person who may trade in IAG securities.Human RightsWe respect and support the UN Universal Declaration of Human Rights and acknowledgethat in our growth as a multinational organisation, we will need to continue to consider andintegrate human rights policies and thinking into all of our operations.Insurance Australia groupcode of ethics PAGE 12


5. THE WAY WE WORKOUR PEOPLEWorking at IAGWe are committed to meeting the needs of our people by providing a working environmentwhere everyone is provided with opportunities to achieve personal fulfilment anddevelopment.Managing Our PeopleWe believe that a sustainable workforce is crucial to achieving long term success and willstrive to provide a working environment that is based on the principles of high performance,productivity and flexibility.Developing Our PeopleWe believe in providing our people with the development opportunities to assist them incarrying out their roles and to help them realise their fullest career potential.Equal OpportunityWe believe in treating our people fairly and on an equal basis regardless of age, gender,disability, race or religion.DiversityWe believe that our culture should value rather than tolerate differences and allow a flexibleand inclusive work environment that supports all of our people in achieving their potential.Cultural SensitivityWe believe in respecting and being sensitive to the cultures and customs of the countries inwhich we operate.Work and LifeWe believe that a healthy workplace involves a flexible work environment that allows ourpeople to balance work with their personal commitments.Occupational Health and SafetyWe believe in providing a healthy, safe and clean environment for our people, customers andvisitors and aim to foster and sustain a positive safety culture in all of our workplaces.PAGE 13Insurance Australia groupcode of ethics


RemunerationWe believe in attracting and retaining high quality people, paying our people fairly, andsupporting, recognising and rewarding high performance.Speaking UpWe want our people to speak up about issues of concern or when they suspect anybehaviour that may breach any laws or IAG policies.GrievancesWe believe in providing a workplace environment that is sensitive to grievances and arecommitted to providing an environment where grievances can be discussed and resolved.Our Rights at WorkWe respect and support the International Labour Organisation Declaration on FundamentalPrinciples and Rights at Work and are committed to ensuring that our people enjoy thefundamental rights ascribed to them in this declaration and in the labour standards andlaws of the countries in which we operate.Political ActivityWe acknowledge that our people have the right to take part in political activities asindividuals but not as representatives of IAG.Insurance Australia groupcode of ethics PAGE 14


6. THE WAY WE HELPOUR CUSTOMERSHelping Our CustomersWe believe that the insurance products and services we provide must have the central focusof helping our customers and recognise that there is potential for us to interact more withcustomers to help them minimise their risks.Customer ComplaintsWe welcome feedback from our customers and believe that it helps us to remain openand responsive to their needs and expectations, and ensures we continually improve theexperience our customers have when they deal with us.The Privacy of Our CustomersWe respect confidentiality and our customers’ right to privacy and will strive to maintain theconfidence our customers have in us to properly handle their confidential information. Wewill only release customer data to a third party when approved by the customer or requiredby law.Accountability for Our MarketingWe believe in marketing and selling our products responsibly and being accountable for thepromises we make in our advertising and marketing.Access to InsuranceWe believe in understanding the needs of the communities in the countries in which weoperate regarding access to insurance, particularly low income earners and rural andregional customers and working to develop products and services that meet those needs.Supporting Industry Standards and CodesWe support standards and codes that improve the performance of the industry and we willbe held responsible for our performance in relation to those standards and codes that weendorse.Trade and CompetitionWe support the principles of fair and open trading and believe in competing for business ina fair and ethical manner.PAGE 15Insurance Australia groupcode of ethics


Climate ChangeWe believe that human induced climate change represents an unprecedented andhighly complex threat to long term economic and social interests and are committed tounderstanding the risks to our business and the community. We seek to maximise thepotential shared benefits for the community and IAG by working together to address theadverse impacts of climate change.AdvocacyWe believe that we have a significant role to play in increasing awareness in thecommunity of the benefits of managing and reducing risk, through advocacy andcommunication activities.8. RESOLVING ETHICAL DILEMMASEthical behaviour and decision making extends beyond legal requirements and as suchrequires you to exercise judgement and accept personal responsibility.At IAG we encourage you to seek help or engage others in dialogue and debate to identifythe best course of action.When faced with an ethical dilemma, begin by asking yourself the following questions:• Do my intended actions comply with relevant laws and regulations?• Do my intended actions reflect the IAG values?• Do my intended actions follow the ethical principles in the IAG Code of Ethics?• If reported in the newspaper, would my intended actions be viewed positively?• Would I be happy if my intended actions were done to me or a loved one?• Would I and those I respect be proud of my intended actions both now and in the future?If you answer ‘not sure’ or ‘no’ to any of these questions refer to the Asking for Adviceand Reporting Concerns section and discuss the situation and your intended actions ordecisions with one of these resources, refer to the following page.PAGE 17Insurance Australia groupcode of ethics


9. ASKING FOR ADVICE AND REPORTINGCONCERNSThere is always someone at IAG who can help you when you need assistance withethical concerns.You can use the following resources for help, information or guidance about an ethicsmatter or to report a suspected incident.Your concerns will be taken seriously and addressed in a thorough and professional manner,regardless of the method you choose. When potential misconduct is reported, we willinvestigate and take appropriate action.Your ManagerIn most cases your manager is the best person to speak to. If you are unsure aboutthe most appropriate course of action to take in any situation, you can ask for advice byconsulting your manager.Your Next Level ManagerIn special cases where you feel that it is inappropriate to consult your direct manager, youcan consult your manager’s manager for advice or to report ethical concerns.Your Local Human Resources TeamYour local human resources team is available to discuss any ethical matters or dilemmasyou might have, as well as concerns involving grievances, performance and equality ofopportunity or harassment complaints.Anonymous Reporting ServicesIf you suspect serious inappropriate behaviour and feel uncomfortable using the abovechannels, consult your local human resources team to find out about processes foranonymous reporting.IAG WILL NOT TOLERATE ANY RETALIATION IN ANY FORM AGAINST PEOPLEWHO, IN GOOD FAITH, REPORT SUSPECTED ETHICAL OR LEGAL MISCONDUCT ORPOLICY VIOLATIONS.Insurance Australia groupcode of ethics PAGE 18


CODE OF CONDUCTAUSTRALIAOur Code of ConductThe Code of Conduct is designed to make our employees aware of theirresponsibility to perform their duties in an ethical and appropriate manner and toensure that IAG maintains its reputation as a good corporate citizen.The Australian Code of Conduct supports IAG’s Code of Ethics, by providing specificguidance for operating in the Australian legal and regulatory environment.PAGE 19Insurance Australia group – Code of Conduct


ContentsENSURING INTEGRITYDishonest and Fraudulent BehaviourConflicts of Interest Employment outside the GroupStaff BusinessPurchase of Goods and ServicesGifts and BenefitsCOMPLIANCE WITH LEGAL AND REGULATORY REQUIREMENTSDealing in Insurance Australia Group Limited (IAG) SharesCONFIDENTIALITYProtecting Confidential InformationConfidentiality after Ceasing EmploymentPrivacy Act ObligationsCommunication with the MediaEEO AND ANTI-HARASSMENTOCCUPATIONAL HEALTH AND SAFETYDrugs and AlcoholYOUR RESPONSIBILITIESThe Code of Conduct applies to all employees of the companies within the InsuranceAustralia Group (‘the Group’) in Australia.The Code of Conduct is designed to make employees aware of their responsibility to performtheir duties in an ethical and appropriate manner and to ensure that IAG maintains itsreputation as a good corporate citizen.Insurance Australia groupcode of ConductPAGE 20


ENSURING INTEGRITYIt is important to maintain the Group’s reputation for honesty and integrity. You shouldtherefore be open and honest in all your dealings with the Group as an employeeand customer.Dishonest and Fraudulent BehaviourYou must immediately report any possible fraudulent activity including theft of companyproperty, breach of any legal, regulatory or organisational requirement, or inappropriatepractices or behaviour which affects the Group to your manager, HR Business Partner ordirectly to the Fraud Hotline (1800 237 283). Managers must ensure that any allegations ofdishonest or fraudulent behaviour are reported to the Fraud Hotline (1800 237 283) and aHR Business Partner within their division as soon as possible after becoming aware of theallegations. For further details, please refer to the Dishonest and Fraudulent Behaviour policyor the Incident Reporting Page on the intranet.Audits are regularly conducted to ensure the integrity and security of our people, systemsand processes. You must fully cooperate with any audit or investigation where required.Serious disciplinary action, including termination of employment, will be taken against anyemployee who is involved in theft, fraud or other dishonest behaviour.Conflicts of InterestA conflict of interest is a situation where your personal or professional interests may conflictwith your position and your obligations and responsibilities as an employee to the Group. Itmay also include situations where you act in a way or use your influence as an IAG employeethat would compromise IAG’s reputation or affect the conduct of IAG’s business.You must make every effort to avoid conflicts of interest. For example, if your position bringsyou into business contact with your personal interests, or those of family or friends, andthere is likely to be a conflict of interest, you must inform your manager or your Risk andCompliance Manager via the Compliance Mailbox on the intranet.Examples of where a conflict of interest may arise include situations such as:• a manager signing off on their own business related expenses• if an employee attempts to obtain a benefit by approving or recommending a transaction;• an employee who favours a supplier during a tender process due to a personalrelationship with them;• an employee using their position to influence an outcome on a personal claim or inconducting business with the Group.PAGE 21Insurance Australia groupcode of ethics


It is important to remain “at arm’s length” to any business that you have with theGroup. Many parts of the business have procedures in place in relation to employee’sdoing business with the Group to ensure that employees do not handle any businessfor themselves, family, friends, colleagues or associates. If you are unsure about theseprocedures, discuss this with your manager.Purchase of Goods and ServicesThe purchase of goods and services from a trade contact or supplier, or the purchase ofsalvage or property associated with a claim, is permitted only with the prior written approvalof your manager. A fair market price must be paid for any goods or services purchased toensure that you are not placed in a position where you may create a sense of obligation tothe trade contact or supplier.For more specific information regarding specific procedures in place in a division, pleaserefer to the intranet or speak with your manager.An example of where purchase of goods and services is a breach of the Code of ConductJohn, a Motor Assessor at a Care and Repair Centre is assessing a 4WD. John thinks a4WD would be a good family car as his current car is getting too small for his growing family.He knows the car can be repaired but decides to alter the figures so that it will be a totallossand as a result, sold at auction through the salvage centre. John then determines whenthe vehicle will be auctioned. He attends the auction and purchases it for a significantlycheaper price than if he had bought it as a second hand car. John’s manager was unawarethat John purchased the car until after the auction when he overheard John telling anotherMotor Assessor what a great price he got it for.This situation would constitute a breach of the Code of Conduct because John did not speakto his manager about purchasing salvage before completing the transaction and gain writtenapproval to ensure that a reasonable price was paid for the vehicle. The situation alsocreated a conflict of interest for John because he used his position as a Motor Assessor toinfluence a decision about the condition of the car for personal gain.This resulted in John getting a benefit to which he was not entitled.PAGE 23Insurance Australia group – Code of Conduct


Gifts and BenefitsGreat care must be taken when accepting gifts or benefits as they may create a sense ofobligation to the donor. Any gift, favour or other benefit must be declared to your manager.You and your manager must decide whether to return the gift or benefit, donate it to charity,or share it between employees.You must always act in an ethical manner and under no circumstances should you offer oraccept any improper payments or bribes.You and your manager should agree what trade nights or social events you can attend whichare related to your position.Insurance Australia groupcode of ConductPAGE 24


COMPLIANCE WITH LEGAL ANDREGULATORY REQUIREMENTSThe Group is required to comply with a number of laws, regulations, industry codes andorganisational policies and practices that regulate the conduct of the Group’s businesses.To ensure that the Group meets its obligations, you will be required to undertake training inthese areas. For more information on compliance training required, you should refer to yourLearning and Development Consultant.Dealing in Insurance Australia Group Limited(IAG) SharesInsider trading in IAG shares is illegal and can result in substantial penalties, including jailterms. Such illegal conduct will lead to disciplinary action and may lead to termination ofemployment. Senior Managers and nominated employees may only buy or sell IAG sharesduring three dealing window periods during the year. For further details, please refer to theSecurity Trading Policy on the intranet.PAGE 25Insurance Australia group – Code of Conduct


CONFIDENTIALITYDuring your employment, you will become aware of, and have access to, personalinformation about customers, employees and other individuals and the Group’s commerciallysensitive information. This may include the types of policies a customer holds, customercontact details, supplier details and arrangements, etc. You must keep this informationconfidential and only use it for IAG business purposes.Protecting Confidential InformationInformation about the Group and its customers is confidential and remains the property ofthe Group at all times.Confidential information is all information disclosed, provided or otherwise made availableduring your employment, work you have contributed to or made in the course of youremployment, which may include but is not limited to the business and affairs of the Group.Confidential information does not include information that was public knowledge when youremployment commenced or became so at a later date (other than as a result of a breach ofconfidentiality by, or involving you).Confidential information must only be used in the course of your employment and may notbe released or taken offsite without authorisation from your manager.• Commercially sensitive documents, records and files must be stored securely and not leftwhere visible.• Confidential information must not be left on computer screens and you must not shareyour computer access passwords with others.• Computer systems must be secured and used for business purposes only. This ensureslong term integrity of systems and confidentiality of business, customer and employee data.• You must not misuse email or internet systems and should refer to the Email and InternetAccess/Usage Policy which outlines appropriate use. Misuse of IAG’s email or internetsystems may result in disciplinary action which may include termination of employment.If you’re not sure whether any information is confidential information, you must speak withyour manager before you disclose this information.For more information and detail about the physical security requirements of the Group,including building access and IAG’s clean desk requirements, you should refer to thePhysical Security Policy on intranet.An example of a breach of confidentialityTony and Max used to work together at IAG in the Retail Sales and Service business beforeMax received an offer from a competitor that he could not refuse. Tony and Max still make theeffort to catch up for lunch occasionally and talk about the old days at IAG and what everyoneInsurance Australia groupcode of ConductPAGE 26


is up to now. They often compare what their companies are currently doing in the marketplaceand any new company initiatives. At a recent lunch, Max asked Tony if he could forward him acopy of a marketing strategy that they had worked on together whilst they worked together atIAG. Tony forwarded the strategy paper to Max because they had spent months developing thestrategy paper and thought that it was only fair that Max have a copy. The document containedsensitive confidential information about IAG’s customer base and strategies to increasepremium over the next 12 months. The document was marked ‘private and confidential’.This example is a serious breach of the Code of Conduct because the strategy paper wasthe property of IAG’s and contained sensitive confidential information which could impact onthe Company’s competitive position in the market. Tony did not have the authority to sendthis document to an ex-employee. The situation was made worse because Max was nowworking for a competitor.Confidentiality after Ceasing EmploymentYour obligation to protect the Group’s confidential information continues after youremployment ceases. This means you must not use the Group’s confidential information foryour own benefit or the benefit of anybody else, disclose it to a third party, copy it or take itwith you when you leave. The Group takes these obligations seriously and will take whateverlegal action is necessary to protect its confidential information.For more information, you should refer to your contract of employment or the confidentialityagreement signed at the beginning of your employment.Privacy Act ObligationsCompliance with the Privacy Act is mandatory. You have an obligation and personalresponsibility to respect our customer’s, other employees’ and individuals’, right to privacy. Thismeans doing everything reasonably within your power to protect the security of any personalinformation you handle in the course of doing your job. Personal information about customers,employees and other individuals should only be used in the course of your employment. Formore information, speak to your manager or refer to the Privacy section the intranet.Communication with the MediaMedia or public comment on the Group can only be made by the Group employeesauthorised to do so. You must inform Corporate Affairs and Investor Relations as soon asany media enquiries are received. If you have any doubt about who is authorised to speakto the media, contact Corporate Affairs and Investor Relations.Refer all investor relations enquiries, for example questions about the performance of IAGshares, Corporate Affairs and Investor Relations. For further information please refer to theContinuous Disclosure Policy on the intranet.PAGE 27Insurance Australia group – Code of Conduct


EEO AND ANTI-HARASSMENTThe Group is committed to equal employment opportunities for all employees. All employeeswill be treated fairly and with respect and no person will be discriminated against on thebasis of race, colour, sex, sexual preference, age, physical or mental disability, maritalstatus, family responsibilities, pregnancy, religion, political opinion, national extraction orsocial origin.The Group will not tolerate any form of sexual harassment. Sexual harassment is any formof unwelcome and uninvited words, or conduct, of a sexual nature that a reasonable personwould find offensive, humiliating, intimidating or embarrassing.Every employee is responsible for ensuring that harassment or discrimination does not occurin their workplace. As part of this, all employees must complete the online Diversity and EEOcourse. For further information, refer to the human resources section on the intranet.An example of sexual harassmentThis year the annual Christmas party was held in the local restaurant. Dinner and drinkswere paid for by IAG. Everyone was dancing and generally having a really good time. Twoemployees, Ms Smith and Mr Jones were dancing together when Mr Jones tried to kiss MsSmith. Ms Smith pushed Mr Jones away and told him to stop but he persisted, thinking thatMs Smith was interested in him. Ms Smith finally pulled herself free and left the venue togo home. After Ms Smith left Mr Jones began sending her suggestive text messages to herwork mobile phone. Ms Smith replied to the text messages telling Mr Jones to stop sendingthe messages but Mr Jones thought it was all harmless fun.On Monday when Ms Smith returned to work she put in a complaint about Mr Jones’sbehaviour at the dinner and the harassing text messages that followed. Ms Smith didn’tthink that she could work in the same team as Mr Jones anymore as she felt uncomfortablearound him after what had happened.Even though the event was after normal work hours, it was still considered a workrelated function. Therefore, all employees are still required to act appropriately and asrepresentatives of IAG.Insurance Australia groupcode of ConductPAGE 28


OCCUPATIONAL HEALTH AND SAFETYThe Group is committed to ensuring a healthy, safe and clean environment for our people,our customers and visitors as detailed in the Charter for Health Safety & Security.The Group adopts a cooperative approach between managers and employees in thedevelopment and implementation of occupational health and safety (OH&S) practices.Drugs and AlcoholThe use of drugs and alcohol may impair an employee’s capacity to perform their job safely,efficiently and with respect for work colleagues and customers.No employee is to commence work, or return to work whilst under the influence of alcoholor drugs if that influence impairs the employee’s work performance. Any concerns should beraised with a manager immediately.Employees found to be under the influence of illegal or illicit drugs or alcohol whilst at workmay be subject to disciplinary action which includes termination of their employment.The unauthorised use, sale, possession or distribution of any type of drug is prohibited at alltimes on IAG premises. If an employee is found to request, purchase, possess, distribute oruse an illegal or illicit drug on IAG’s premises then the employee will be subject to disciplinaryaction which includes termination of their employment.The Group provides the services of a confidential Employee Assistance Program to assistemployees in the treatment of alcohol or drug use problems.PAGE 29Insurance Australia group – Code of Conduct


Types of SuperannuationContributions You Can MakeIAG can make both employer and employee contributions to your preferred super fund.Employer (IAG) ContributionsIAG values the contribution that super can make to people’s future financial security andlifestyle. That’s why our default contribution rate is 13%, four percent higher than the currentGovernment minimum.In recognition that people have different financial needs and objectives at different times intheir lives, IAG also provides pay flexibility. Employees can choose to vary their cash/supermix by:• Keeping IAG’s contributions at the default rate of 13%; or• Decreasing IAG’s contribution below 13% to a minimum of 9%, and electing to receive thedifference in cash along with their regular pay• Making additional voluntary contributions from before-tax or after-tax salaryNote: If you wish to ‘cash down’ your Super from 13% to the statutory 9%, you need tocomplete that request once you start with IAG via our ‘Employee Self Service’ tool.IAG encourages people to seek independent financial advice when deciding how to structuretheir remuneration, and to think of both the short and long term financial objectives andimplications.Employer (IAG) contributions for your STI andbonusesPart of short-term incentive (STI) and bonus payments are paid to employees assuperannuation.The cash/super mix for incentives and bonuses is at the employee’s chosen contributionrate (eg. 13% super is the default rate). Employees can control the cash/super mix for theiroverall level of pay by varying this rate for their fixed pay and incentives.Insurance Australia group – Your Superannuation ChoicesPAGE 34


Employee (voluntary) ContributionsEmployees can boost their retirement savings by making their own super contributions.Employee contributions are voluntary. They can be varied at any time and can be made from:• Before-tax salary, or• After-tax salary, or• A combination of your before-tax and after-tax salaryYou can choose to make your own contributions as a whole percentage of your salarystarting at a minimum rate of 1%. Contributions cannot exceed 90% of salary and must beapproved by IAG. What’s best for you will depend on your own individual financial situation.Note that if you are making before or after-tax contributions, you should be aware of yourconcessional and non-concessional contribution limits and the implications ofexceeding these.To make an employee contribution, please complete the “Your Change of EmployeeContribution Form”.Employees also have the opportunity to contribute all or part of their potential short-termincentive (STI) into superannuation. Annual STIs are paid in September. The election tosuperannuation period is from November to January, however as a new employee you willalso have one month from your employment date to elect to have all or part of your STI paidas superannuation.PAGE 35Insurance Australia group – Your Superannuation Choices


Additional DownloadsThe below documents provide you with further details on the IAG & NRMA SuperannuationPlan. These documents and all Superannuation forms are available for you to access atwww.IAGNRMA.superfacts.comIAG & NRMA Superannuation Plan Annual ReportIAG & NRMA Superannuation Plan Short Form Product Disclosure StatementThis document summarises some of the key features of the plan.Insurance Australia group – Your Superannuation ChoicesPAGE 36


Your Fair WorkStatementThis Fair Work Statement is provided to all employees covered by the nationalworkplace relations system and outlines details of the safety net minimum terms andconditions under the National Employment Standards.PAGE 37Insurance Australia group – Your Fair Work Statement


Fair WorkInformation StatementFrom 1 January 2010, this Fair Work Information Statement is to be provided to all new employees by their employer as soon as possibleafter the commencement of employment. The Statement provides basic information on matters that will affect your employment. If yourequire further information, you can contact the Fair Work Infoline on 13 13 94 or visit www.fairwork.gov.au. The National Employment StandardsThe Fair Work Act 2009 provides you with a safety net of minimum terms and conditions of employment through the NationalEmployment Standards (NES).There are 10 minimum workplace entitlements in the NES:1. A maximum standard working week of 38 hours for full-time employees, plus ‘reasonable’ additional hours.2. A right to request flexible working arrangements to care for a child under school age, or a child (under 18)with a disability.3. Parental and adoption leave of 12 months (unpaid), with a right to request an additional 12 months.4. Four weeks paid annual leave each year (pro rata).5. Ten days paid personal/carer’s leave each year (pro rata), two days paid compassionate leave for each permissible occasion,and two days unpaid carer’s leave for each permissible occasion.6. Community service leave for jury service or activities dealing with certain emergencies or natural disasters. This leave isunpaid except for jury service.7. Long service leave.8. Public holidays and the entitlement to be paid for ordinary hours on those days.9. Notice of termination and redundancy pay.10. The right for new employees to receive the Fair Work Information Statement.A complete copy of the NES can be accessed at www.fairwork.gov.au. Please note that some conditions or limitations may apply toyour entitlement to the NES. For instance, there are some exclusions for casual employees.If you work for an employer who sells or transfers their business to a new owner, some of your NES entitlements may carry over to thenew employer. Some NES entitlements which may carry over include personal/carer’s leave, parental leave, and your right to requestflexible working arrangements. Modern awardsIn addition to the NES, you may be covered by a modern award. These awards cover an industry or occupation and provide additionalenforceable minimum employment standards. There is also a Miscellaneous Award that may cover employees not covered byany other modern award.Modern awards may contain terms about minimum wages, penalty rates, types of employment, flexible working arrangements,hours of work, rest breaks, classifications, allowances, leave and leave loading, superannuation, and procedures for consultation,representation, and dispute settlement. They may also contain terms about industry specific redundancy entitlements.If you are a manager or a high income employee, the modern award that covers your industry or occupation may not apply to you.For example, where your employer guarantees in writing that you will earn more than the high income threshold, currently set at$113,800 per annum and indexed annually, a modern award will not apply, but the NES will.Transitional arrangements to introduce the modern award system may affect your coverage or entitlements under a modern award. Agreement makingYou may be involved in an enterprise bargaining process where your employer, you or your representative (such as a union or otherbargaining representative) negotiate for an enterprise agreement. Once approved by Fair Work Australia, an enterprise agreement isenforceable and provides for changes in the terms and conditions of employment that apply at your workplace.There are specific rules relating to the enterprise bargaining process. These rules are about negotiation, voting, matters that can andcannot be included in an enterprise agreement, and how the agreement can be approved by Fair Work Australia.You and your employer have the right to be represented by a bargaining representative and must bargain in good faith whennegotiating an enterprise agreement. There are also strict rules for taking industrial action. If you have enquiries about making,varying, or terminating enterprise agreements, you should contact Fair Work Australia on 1300 799 675.PAGE Page 38 1Fair Work Ombudsman ABN 43 884 188 232 www.fairwork.gov.au Fair Work Information Statement


Individual flexibility arrangementsYour modern award or enterprise agreement must include a flexibility term. This term allows you and your employer to agree toan Individual Flexibility Arrangement (IFA), which varies the effect of certain terms of your modern award or enterprise agreement. IFAsare designed to meet the needs of both you and your employer. You cannot be forced to make an IFA, however, if you choose to makean IFA, you must be better off overall. IFAs are to be in writing, and if you are under 18 years of age, your IFA must also be signed byyour parent or guardian. Freedom of association and workplace rights (general protections)The law not only provides you with rights, it ensures you can enforce them. It is unlawful for your employer to take adverse actionagainst you because you have a workplace right. Adverse action could include dismissing you, refusing to employ you, negativelyaltering your position, or treating you differently for discriminatory reasons. Some of your workplace rights include the right tofreedom of association (including the right to become or not to become a member of a union), and the right to be free fromunlawful discrimination, undue influence and pressure.If you have experienced adverse action by your employer, you can seek assistance from the Fair Work Ombudsman or Fair WorkAustralia (applications relating to general protections where you have been dismissed must be lodged with Fair Work Australia within60 days). Termination of employmentTermination of employment can occur for a number of reasons, including redundancy, resignation and dismissal. When youremployment relationship ends, you are entitled to receive any outstanding employment entitlements. This may include outstandingwages, payment in lieu of notice, payment for accrued annual leave and long service leave, and any applicable redundancy payments.Your employer should not dismiss you in a manner that is ‘harsh, unjust or unreasonable’. If this occurs, this may constitute unfairdismissal and you may be eligible to make an application to Fair Work Australia for assistance. It is important to note that applicationsmust be lodged within 14 days of dismissal. Special provisions apply to small businesses, including the Small Business Fair DismissalCode. For further information on this code, please visit www.fairwork.gov.au. Right of entryRight of entry refers to the rights and obligations of permit holders (generally a union official) to enter work premises. A permitholder must have a valid and current entry permit from Fair Work Australia and, generally, must provide 24 hours notice of theirintention to enter the premises. Entry may be for discussion purposes, or to investigate suspected contraventions of workplace lawsthat affect a member of the permit holder’s organisation or occupational health and safety matters. A permit holder can inspect orcopy certain documents, however, strict privacy restrictions apply to the permit holder, their organisation, and your employer. The Fair Work Ombudsman and Fair Work AustraliaThe Fair Work Ombudsman is an independent statutory agency created under the Fair Work Act 2009, and is responsible forpromoting harmonious, productive and cooperative Australian workplaces. The Fair Work Ombudsman educates employers andemployees about workplace rights and obligations to ensure compliance with workplace laws. Where appropriate, the Fair WorkOmbudsman will commence proceedings against employers, employees, and/or their representatives who breach workplace laws.If you require further information from the Fair Work Ombudsman, you can contact the Fair Work Infoline on 13 13 94 or visitwww.fairwork.gov.au.Fair Work Australia is the national workplace relations tribunal established under the Fair Work Act 2009. Fair Work Australiais an independent body with the authority to carry out a range of functions relating to the safety net of minimum wages andemployment conditions, enterprise bargaining, industrial action, dispute resolution, termination of employment, and otherworkplace matters.If you require further information, you can contact Fair Work Australia on 1300 799 675 or visit www.fwa.gov.au.The Fair Work Information Statement is prepared and published by the Fair Work Ombudsman in accordance with section 124 of the Fair Work Act 2009.© Copyright Fair Work Ombudsman. Last updated: July 2010.www.fairwork.gov.auFair Work Infoline 13 13 94Mon-Fri 8.00am-6.00pm local timePAGE Page 39 2 Fair Work Ombudsman ABN 43 884 188 232 www.fairwork.gov.au Fair Work Information Statement


DownloadThis SiteYour access to this site content is only valid for the next month. To preserve thecontent for your future reference we recommend you download the site and store itsomewhere safe.Clicking the ‘Download Site’ button will provide you with a PDF version of all thesite pages.Clicking the ‘Download Starter Forms’ button will provide you with a PDF version ofthe New Starter Checklist for step by step instructions on joining IAG and the formsyou need to complete.Download SiteDownload Starter FormsIf you would like to provide general feedback regarding the Job Offer Website, pleasecontact cguhumanresources@cgu.com.auPAGE 40Insurance Australia group – Download This SiteG014306 08/11

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