Code of Business Conduct and Ethics
Gulf Energy’s Ethos
Gulf Energy’s directors, officers and employees (collectively “Team Members”) are required to comply with Gulf Energy’s Code of Business Conduct and Ethics. Each Team Member must sign a declaration to comply with Gulf Energy’s Code of Business Conduct and Ethics. The purpose of Gulf Energy’s Code of Business Conduct and Ethics is to deter wrongdoing and to promote, among other things, honest and ethical conduct and to ensure to the greatest possible extent that Gulf Energy’s business is conducted in a consistently legal and ethical manner.
Gulf Energy’s continued growth and prosperity is linked to its Team Members’ ability to make decisions that are consistent with Gulf Energy’s core values and ethical principles. Gulf Energy is a Company committed to:
• Passion for Excellence—Strive to achieve the best in everything it does.
• Integrity—Hold itself to the highest ethical standards. To interact in an open, honest positive manner and be guided by what is right.
• Teamwork—Work together with trust, openness, honesty, and respect.
• Inspired People—Build a culture where people are motivated, engaged, valued, and growing. Our people make the difference and are the essence of Gulf Energy.
Gulf Energy’s core values support and guide its leadership in establishing the strategic direction of the Company. Sound judgment shall be exercised in the service of its reputation as a business leader, employer of choice, and good corporate citizen. The Company’s Team Members and representatives are expected to conduct their business in accordance with these values and with our Standards of Business Conduct and Ethics (“The Standards”). Gulf Energy’s reputation is based on the personal integrity of each of its Team Members and those with whom we do business. Gulf Energy strives to be compliant with laws, regulations, and policies; and endeavors to conduct itself in a manner beyond reproach. Actions speak louder than words.
Gulf Energy’s responsibilities to stakeholder
To the Company
Integrity is at the heart of Gulf Energy.
To Each Other
Gulf Energy expects all Team Members and stakeholders to act with honesty, respect, and fairness.
To Business Partners
Gulf Energy’s business partners trust the quality and value of its business activities. Gulf Energy depends on strong relationships with its business partners to provide continued opportunities to grow business.
To Shareholders
Gulf Energy’s shareholders trust it to responsibly use all assets to make business grow, whilst applying the Gulf Energy ESG Strategy.
To the Community
When Guld Energy gives back to the community, it instills pride in its employees and gains the respect of the citizens in the community.
The Ethics Committee and compliance
The Gulf Energy Ethics Committee is dedicated to giving employees the support and advice they need to act according to Gulf Energy’s ethical principles.
The Ethics Committee has a charter to:
• Help Team Members use the Company’s ethical principles in their decision-making processes
• Provide guidance for Team Members who have questions about business ethics and compliance issues
• Support Team Members who may be facing ethical challenges in the workplace
• Interpret policies
• Provide easily accessible information on our standards, policies, and procedures
• Foster an atmosphere of trust and open communication where Team Members feel comfortable coming forward and talking about issues
As such, Gulf Energy expects Team Members to act proactively, raising concerns about ethical issues, and reporting any conduct believed to be a violation of The Standards, a Company policy or procedure, or a government law or regulation. Members of Gulf Energy’s management team are expected to maintain an “open-door” policy regarding employee questions, and to support any employee who comes forward to discuss an issue or report a potential violation.
Retaliation is prohibited
Gulf Energy prohibits retaliation or retribution against any Team Members for cooperating in an investigation or for making a complaint. Retaliation or retribution for cooperating in or filing a complaint is illegal and is grounds for immediate termination dismissal. If an Employee feels they have been retaliated against, they are instructed to contact the Managing Director directly.
Taking action
When a Gulf Energy Team Members or agent is confronted with an ethical dilemma, it is their responsibility to act. The Action Decision-Making Model outlined below is provided to all Team Members, agents, representatives, contractors and service providers to help them assess whether a particular action is “the right thing to do.”
Action decision-making model
Act Responsibly
• Has the Team Member taken responsibility for their share of the problem? It’s ok to acknowledge mistakes.
• Does the Team Member have all the information they need?
• Has the information been clarified?
Consider the Company’s Core Values
• Does it demonstrate respect for the Company’s people?
• Does it demonstrate Excellence?
• Does the action reflect Integrity?
• Does it promote Teamwork?
Trust judgement
• Is the action fair?
• Does it feel comfortable?
• Is it the “right” thing to do?
• Could it be shared publicly?
• Can the Team Member look at themself in the mirror and say that they acted with integrity?
Identify impact on Stakeholders
• Does the action have a negative or positive impact on our stakeholders?
• To what extent will the action reflect on the stakeholders?
Obey the Rules - does the action comply with:
• The law?
• Company policy?
• Regulatory requirements?
• Customer requirements?
• Partner or client requirements?
Notify Appropriate Persons
• Have communications been open and honest?
• Have potential problems been disclosed?
The Standards
Gulf Energy operates within the bounds of the laws, rules, and regulations that are relevant to its business. The rule of law is fundamental to civil society, to the democratic process, and to the conduct of business in a dynamic global marketplace. However, today’s market demands that companies meet higher standards—simply obeying the law is not enough. To achieve higher standards of behavior, Gulf Energy needs to make business decisions that are aligned with its values of respect for people, passion for excellence, integrity, teamwork and the Gulf Energy ESG Strategy.
The first and foremost obligation of responsible corporate citizenship is to obey the laws of the countries and communities in which Gulf Energy does business. Any case of noncompliance with applicable law may subject the violating employee to disciplinary action. The fact that in some countries certain standards of conduct are legally prohibited, but these prohibitions are not enforced in practice, or their violation is not subject to public criticism or censure, will not excuse an illegal or unethical action by a Gulf Energy employee.
Gulf Energy is a good corporate citizen not just because it complies with the law, but because its employees are also expected to act according to the Company’s core values. Gulf Energy is committed to going beyond mere compliance—beyond simply “doing things right.” Gulf Energy aspires to “do the right thing” by being faithful to and executing the principles and guidelines cited in The Standards and to act in ways that exceed the minimum standards set by law. Each Team Member of Gulf Energy is personally responsible for meeting this obligation.
Each Gulf Energy Team Member is responsible for displaying integrity. Business Integrity is not hard to define. Everybody knows it when they see it. Among other things, it means honesty, and obeying the law. It means treating those with whom we work with fairness and respect. And it means everyone being accountable and taking responsibility for actions and consequences.
It is also the responsibility of each Gulf Energy Team Member to comply with The Standards, and to act or report to management when aware of criminal acts or acts in violation of The Standards. Team Members who fail to comply with The Standards, including not reporting known unethical or illegal activities, will be subject to employment or contract review.
Individuals who report an ethical or legal concern in good faith will never be subject to retaliation by Gulf Energy for reporting. Any Team Member responsible for retaliation against an individual who in good faith reports a known or suspected violation will be subject to disciplinary action, including termination. Additionally, all Team Members who knowingly submit false reports of ethical or legal concerns, or violations will also be subject to disciplinary action.
Respect others - Value personal dignity and differences
People
Gulf Energy respects the personal dignity of everyone, honor diversity, and are intolerant of violence, discrimination, harassment, or retribution in its workplaces, including virtual and remote. Gulf Energy strives to be an employer of choice committed to creating, managing, leveraging, and valuing diversity. Gulf Energy works hard to create a positive work environment where each individual is appreciated, proud, satisfied, and adds value to the Company. Gulf Energy practices equal opportunity without regard to race, religion, colour, national origin, gender, sexual orientation, age, disability, or veteran or marital status. Gulf Energy’s employment and personnel decisions are based on individual merit and Company requirements. Retaliation is not tolerated.
Human rights and the law
In addition to Gulf Energy’s Anti-Slavery, Child Labour and Human Traffic Policy, Gulf Energy complies with employment laws in every country in which it operates and supports fundamental human rights for all people. In the event the country in which Gulf Energy is operating has below United Nations employment standards and human rights policies, the Company will enforce those to an Australian standard. Gulf Energy will not employ children or forced labor. Gulf Energy will not allow physical or psychological punishment or abuse. Gulf Energy will respect the right of Team Members to exercise their lawful right of free association. Gulf Energy enthusiastically supports laws prohibiting unjustified discrimination based on a person’s race, colour, gender, national origin, age, religion, disability, veteran status, sexual preference, marital status, or other protected characteristics.
Fair treatment and opportunity
Gulf Energy is committed to the fair treatment and compensation of Team Members. All applicants and Team Members are judged by their qualifications, demonstrated skills and achievements. Gulf Energy believes in recognizing and rewarding excellent performance and offering opportunities for advancement through training and promotions.
Diversity
Gulf Energy believes that differences should be valued. Every Team Members deserves the opportunity to work and grow in an environment that is free of discrimination and harassment, and that supports work/life flexibility. At Gulf Energy, diversity will be accepted throughout the organization. In exchange, Gulf Energy will benefit from the creativity, varied perspective, innovation, and energy that result from a diverse workforce.
Harassment
Gulf Energy’s Team Members have the right to work in an environment that is free from intimidation, harassment, and abuse. Gulf Energy is committed to providing a work environment free of harassment of any kind. Verbal, physical, or virtual conduct by any employee that harasses another or disrupts another’s work performance or creates an intimidating, offensive, abusive, or hostile work environment will not be tolerated. Gulf Energy’s anti-harassment policy applies to all persons involved in the Company ‘s operations including all service providers and prohibits harassment of any Team Member. Whistleblowers' complaints will be kept confidential and thoroughly investigated with sensitivity by the Crime and Corruption Commission Queensland, and/or other relevant authorities.
In addition, unwelcome sexual advances, requests for sexual favours, and other unwelcome verbal or physical conduct of a sexual nature are specifically prohibited. Team Members are encouraged to help each other by speaking out when a co-worker’s conduct makes them or others uncomfortable and are responsible for promptly reporting harassment when it occurs.
Gulf Energy has internal complaint procedures to immediately address and undertake an effective, thorough, and objective investigation. If a Team Member believes that he/she has been unlawfully harassed, they should submit a written complaint to the Managing Director as soon as possible after the incident. If it is determined that harassment has occurred, effective remedial action will be taken. Any Team Member determined by Gulf Energy to be responsible for unlawful harassment will be subject to appropriate disciplinary action, up to and including termination.
Promote a Healthy and Safe Workplace - Make a Better World
PEOPLE
When we protect the health and safety of our coworkers, our community, and the environment, we demonstrate respect and contribute to a positive work environment, including remote and virtual offices. Without respect for health, safety, and the environment, we put our coworkers, our employees, our clients, our partners, and the public at risk.
Gulf Energy is committed to protecting the health and safety of our Team Members, the public, clients, suppliers, and visitors. Gulf Energy’s policy is to maintain a drug-free, secure workplace where all Team Members are attentive to hazard prevention and the avoidance of accidents and injuries. Observed accidents, injuries, or hazards should be immediately reported to the Managing Director.
To support this commitment, the Company will provide, upon request and subject to approval, all reasonable purchase requests for more appropriate or improved working furniture and equipment, and general working conditions. Each employee is responsible for observing the safety and health rules and practices that apply to his or her job. Team Members are also responsible for taking precautions necessary to protect themselves and their co-workers, and immediately reporting accidents, injuries, and unsafe practices or conditions. Appropriate and timely action will be taken to correct known unsafe conditions.
Build trust - Keep accurate, complete company books and records
INTEGRITY
Gulf Energy’s reputation depends on the confidence of others, which is partially based on the accuracy of the Company’s written records and verbal statements. By demonstrating honesty in accounting and labor-charging practices, Gulf Energy generates trust with stakeholders and enhances its reputation. When the Company fails to record financial information accurately, reputation damage; risk of losing business, and reduction in customer and shareholder confidence can occur.
Gulf Energy will only use Company funds or assets for purposes that can be disclosed and recorded promptly and accurately in its books and records. Gulf Energy will not make false entries for any reason, nor will it alter documents or sign documents without the proper authority to do so. Gulf Energy will not make or approve payments on behalf of the Company if they will not be used, or might be used, for something other than the stated purpose. Gulf Energy’s financial books, records, and statements shall properly document all assets and liabilities, shall accurately reflect all transactions of the Company, and shall be retained in accordance with Gulf Energy’s record retention policies and all relevant laws and regulations. No employee, agent, representative, client or outsource partner, or customer shall falsify a record. The Company follows The International Financial Reporting Standards Foundation (IFRS) regulations to provide a uniform basis for measuring, managing, and reporting Company operations.
Accuracy of business records
Honest and accurate recording and reporting of information is extremely important. Investors count on Gulf Energy to provide accurate information about its businesses and to make responsible business decisions based on reliable records. Team Members throughout Gulf Energy are responsible for properly recording many kinds of information.
All financial books, records and accounts must accurately reflect transactions and events, and conform both to IFRS Principles and to Gulf Energy’s system of internal controls. Undisclosed or unrecorded funds, assets or liabilities are not allowed. Team Members uncertain about the validity of an entry or process are expected to consult with the Managing Director or a Company Director.
Recording and retaining business records
Almost all business records—including email and computer records—may become subject to public disclosure in the course of litigation or governmental investigations. Records are also often obtained by outside parties or the media. Team Members should therefore attempt to be as clear, concise, truthful, and accurate as possible when recording any information. Avoid exaggeration, colorful language, guesswork, legal conclusions, and derogatory characterizations of people and their motives.
Documents should only be destroyed in accordance with the applicable document retention policy, and never in response to or in anticipation of an investigation or audit. Team Members should contact the Ethics Committee if there is any doubt about the appropriateness of document destruction.
Keep your commitments - Negotiate, perform, and market in good faith
INTEGRITY, EXCELLENCE, TEAMWORK
Gulf Energy’s success in the marketplace is based on the quality of its services, the value to clients, and the competence and honesty of sales presentations. Gulf Energy prospers only to the degree that it serves clients well—and treats them, our Team Members, our business partners, our investors, and our competitors fairly and honestly. When the Company fails to negotiate, perform, or market in good faith, serious damage to reputation and loss of loyalty of our clients can occur.
Fair competition is the hallmark of relationships—the Company’s business dealings will always be frank and respectful. Gulf Energy strives to generate mutually beneficial relationships and outcomes.
Gulf Energy believes in doing business with those suppliers, contractors, partners, agents, sales representatives, distributors, and consultants who embrace and demonstrate high standards of ethical business behavior. Gulf Energy will not knowingly use suppliers who operate in violation of applicable laws or regulations, including local, environmental, employment or safety laws
Marketing, negotiations, and contract execution
Gulf Energy is committed to the truthful and accurate communication of information about our services. Promotional materials will be honest and factual, not misleading, or deceptive. Gulf Energy Team Members are expected to execute Company agreements in an ethical and conscientious manner—and always in accordance with our contractual obligations. Team Members will always obtain proper approvals before deviating from a contract or other agreement.
Purchasing practices
All purchasing decisions must be made based on the best value received by Gulf Energy. Team Members should take care that personal, or family relationships not influence or appear to influence all business decisions. Obtaining competitive bids, verifying quality and service claims on a regular basis, and confirming the financial and legal condition of the supplier are all important steps in good purchasing decisions. Agreements should be written, clearly setting forth the services or products to be provided, the basis for earning payment, and the applicable rate or fee. The amount must not be excessive considering good industry practice and must be commensurate with the services provided. Gulf Energy will respect the confidential information of our suppliers.
Act responsibly - Disclose and resolve potential conflicts of interest
INTEGRITY, EXCELLENCE, TEAMWORK
Integrity in a business relationship means that all participants are working together for the common good and are not making decisions based on self-interest alone. When the Company acts with integrity, trust is earned, and long-term client and customer relationships can be built. When the Company acts, or appears to be acting, solely in its own self-interest, reputation can be damaged and lost.
Conflicts of interest
Shareholders of Gulf Energy expect that business decisions are made in the best interests of the Company. Actions must be based on sound business judgment, and not motivated by personal interest or gain. Any situation that creates or appears to create a conflict of interest between personal interests and the interests of Gulf Energy must be avoided. Potential conflict of interest situations must be reported to an employee’s manager and to the Ethics Committee, before the conflict of interest occurs.
Gulf Energy expects its business will be conducted free from any actual or potential conflict that might arise when one’s loyalty is split between personal interests and those of the Company. Judgment can be affected in any transaction or relationship where an individual might find that Gulf Energy’s interest competes with their own. Gulf Energy will work with its Team Members to resolve disclosed conflicts in a mutually satisfactory manner. Gulf Energy’s clients, partners and suppliers can expect to be dealt with fairly and impartially, free from any conflicting interests.
Gulf Energy Team Members have a duty to avoid financial, business, or other relationships that might interfere with this commitment. Each Team Member will scrupulously avoid even the appearance of a conflict between personal interests and those of the Company in matters of importance to Gulf Energy business, and it is expected those with whom the Company interacts supports this endeavor.
Act with integrity - Stay clear of improper business courtesies
INTEGRITY
To maintain trust in business relationships, Gulf Energy must always act with integrity. Gulf Energy must steer clear of giving or receiving gifts that are intended to influence, or appear to influence, business decisions. When gifts are accepted it can undermine customer relationships, cause reputation damage, and put the Company in legal jeopardy.
In many industries and countries, gifts and entertainment are used to strengthen business relationships. Gulf Energy recognizes that gifts, gratuities, and other business courtesies may occasionally be appropriate in building and maintaining business relationships with clients, partners, suppliers, and other stakeholders. Gifts and entertainment should further the business interests of Gulf Energy and not be lavish or more than the generally accepted best business practices of one’s industry. However, our Team Members, representatives, and agents must avoid even the perception of favorable treatment or the appearance of impropriety when offering or accepting any item of value in conducting the Company’s business. Throughout the world, one principle is common and clear: No gift, favor, or entertainment should be accepted or provided if it will obligate or appear to obligate the recipient.
Requesting or soliciting personal gifts, favors, entertainment, or services is unacceptable. Accepting gifts of cash or cash equivalents is also always unacceptable. Additionally, Team Members may not exploit their position to solicit vendors, including financial institutions, to provide individual preferential treatment in pricing, terms, or loans.
Focus on global responsibility - Our reputation extends across borders
INTEGRITY, PEOPLE
Gulf Energy could be expanding globally in the future. Success in any global business transaction depends on the Company’s compliance with country-specific constraints and conditions, and sensitivity to local customs. Laws, regulations, and conventions governing business relationships vary from country to country. Gulf Energy’s obligation to comply with Australian and international laws and regulations does not end beyond the border of Australia, nor does the commitment to treat stakeholders with care and respect.
Gulf Energy respects all responsibilities in countries where it may do business. Being a responsible corporate citizen means being sensitive to the people who live in varied global communities. It requires that the Company knows and comply with the laws, regulations, and customs of each host country and community in which we conduct business. Finally, being a good corporate citizen means that the Company conducts business not as a “foreigner” but rather as part of the fabric of that host nation and the communities . Gulf Energy recognizes that it will be welcome only if it makes a positive contribution in each host nations’ communities.
Protect sensitive information
INTEGRITY, PEOPLE
One of Gulf Energy’s most valuable assets is information. Like all other assets, information that is not generally disclosed can be helpful to competitors and must be protected. Some examples of the areas that Gulf Energy has a competitive advantage includes technical know how, trade secrets, detailed financial figures, marketing plans, service offering ideas and information about potential acquisitions, divestitures, and investments.
Safeguard confidential information by keeping it secure, limiting access to those who have a need to know to do their job, disposing of proprietary documents in a secure manner and avoiding discussion of confidential information in public areas, for example on planes, elevators, and mobile phones. The obligation to preserve Gulf Energy’s confidential information is ongoing, even after employment ends.
Gulf Energy Team Members will protect the Company’s intellectual property, and act responsibly with the sensitive information of clients, partners, and other stakeholders. Each Team Member and those that are granted access to sensitive, confidential information (including private, competition sensitive, and proprietary information held by the Company) are obligated to protect and maintain its confidentiality and are prohibited from disclosing it unless authorized beforehand by designated Company officials. This sensitive information also includes bid prices, competitor pricing, or technical data, or proposal evaluations. Sensitive information from other companies (or proprietary information)—whether marked with a restrictive legend or unmarked—may only be used for the purpose(s) authorized by the owner company.
Gulf Energy Team Members will not use improper means to seek proprietary information about a competitor—especially theft, illegal entry, electronic eavesdropping, or surveillance. Gulf Energy make misrepresentations to persuade another party to release information (by posing as a customer, for example), nor will it commission a third party to do so. Similarly, Gulf Energy will be careful not to transfer outside the Company confidential electronic mail messages or any message intended for internal use only. The Company will Team Members personal privacy and protect private personnel information from those inside or outside Gulf Energy who have no need to know. Gulf Energy trades on trust and its reputation for integrity. Devious tactics that undermine the confidence others have in Gulf Energy do not comply with its ethical principles.