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Values, ethics and legal compliance

Code of Conduct

Although the business is governed by existing policies in relation to business ethics and codes of behaviour, a new Code of Conduct, that better reflects core company values, is being developed for roll-out in 10/11. While we regret that the original timetable for launch of the new code has slipped from the date envisaged in last year's report we felt that the delay was justified by the need to embrace both the new vision and values platforms.

Our Code of Conduct underpins all aspects of our business operations and is the foundation stone in our commitment to corporate citizenship. It incorporates our values, which provide the principles to guide us in our day-to-day attitudes and behaviour and provide a framework to assist in decision making. Individual contracts articulate the terms and conditions of individual employment and company HR policies provide clear direction on topics as diverse as leave, confidentiality and discrimination.

The Code of Conduct provides a supplement to these processes and establishes a minimum set of standards that all employees are required to comply with. It guides our staff through how to avoid conflicts of interest and how to respect laws relating to privacy, consumer protection and competition.

The new code will be promulgated to staff through a range of mechanisms including the example set by our executive team and senior management. Employee contracts will incorporate an obligation to comply with the code. We will confirm compliance with the code annually with all our staff, and will ask managers to make us aware of any breaches.

Access to an ethics counselling service and a whistle-blower mechanism are intended to uncover unethical or illegal incidents in breach of our code. A review of our whistleblower process for capturing customer concerns regarding business ethics, has highlighted the need for some improvement to overall web-based customer feedback. Customer feedback mechanisms, including the ability to highlight issues of an ethical nature, will be reviewed as part of an overall web project in 10/11.

The existing mechanism for employees wanting to highlight issues of ethical concern has been to raise it with their first or second line management. In conjunction with the cascading of the new Code of Conduct, an improved mechanism for confidential employee feedback will be established in 10/11.

Reflecting and reconnecting with our values

Work to ensure our values are brought to life in our business continued throughout 09/10. 'Reflect and reconnect' sessions are ongoing in every division. Communications and reflections on our values are emphasised in many corporate vehicles and embedded in management development and networking events. An assessment of values is now part of every employee's annual performance review, which has led to more open discussion of what role model behaviour should include and what is inappropriate. Increasingly, values alignment also plays an important role in our decisions to select, continue and terminate employment.

Legal compliance

Legal compliance is fundamental to good corporate governance. Internal legal counsel alert management to likely business impacts from developments in the law. We ensure general legal requirements as well as trade practices, privacy and product safety requirements are met in the following ways:

  • Our general legal and trade practices policies establish how compliance is to be maintained.
  • We conduct self-assessment and report against checklists on legal compliance, general business process integrity and the Financial Instruments and Exchange law (JSOX). Internal auditors also review these self-assessment checklists.
  • Corporate Affairs review all promotional materials and significant external communications for compliance with company policy, the Trade Practices Act 1974 and other relevant legislation.
  • Data security and privacy requirements are documented in employee contracts and/or in company policies.
  • Our product safety requirements are outlined in the Fuji Xerox C11 safety standard, which goes beyond regulatory obligations.
  • Managers in the business are also expected to maintain a working knowledge of the law relevant to their area of responsibility, such as in safety and environmental areas.

Training in legal compliance
As mentioned in our last report, our approach to using third-party training and testing tools has been under review. We have commenced drafting a new in-house legal awareness training program, which includes tailored content to provide more relevance. The core training material is targeted for completion in the first half of 10/11 and a new online training and testing program will be cascaded at that point. Where necessary, face-to-face sessions for specific aspects of legal training will continue to be provided for identified groups.

Incidents and complaints

No material claims have been brought by our customers or suppliers against us in 09/10. Corporate Affairs review has brought to light a recurring issue with marketing promotions that provide business and personal incentives to our customers. Since the close of the year under review this has been discussed within the leadership team and in 10/11 we will remind our business of the legal and ethical framework for marketing promotions.

We engage a number of independent dealers and authorised agents to sell our products in Australia. As can be seen from disclosures in previous reports from time to time a dispute arises in relation to those arrangements. The status of such disputes is set out below:

  • The dispute with a sales agent about an incident reported in the 07/08 year in which false equipment orders were placed was finally settled. No customers were affected by this matter. The dispute was not financially material and resulted in a general tightening of order validation processes.
  • The service of one employee was terminated during the year for misconduct – attempting to obtain a personal benefit from the performance of a role for the company. The company was notified of the matter, which was subject to a police investigation, but no charges were laid against the individual.
  • The dealer dispute referred to in the 08/09 report has also been resolved. The then incumbent dealer sold his business to another longstanding dealer and Fuji Xerox Australia entered into a new dealership agreement with that party.
  • A new dispute has arisen within the 09/10 reporting period with another one of our dealers. We are obliged to maintain confidence with regard to this contractual dispute. We hope to resolve this matter in the near future and obtain consent to include further details in the 2011 report.

There were no significant ethical concerns brought to our attention through our external whistleblower web link during the year. As in prior years, the one or two incidents per month usually related to customer dissatisfaction with aspects of operational performance and were responded to within 24 hours and usually closed within a week. Given the nature of issues raised by the whistleblowing service, our customer feedback web mechanisms will be reviewed in 10/11 to ensure operational issues are quickly dealt with by appropriate functions. We will work to identify another appropriate communication channel, for specific issues that relate to unethical behaviour.

During 09/10, no material ethical incidents emerged affecting employees. However, the increased visibility and discussion of values has highlighted several instances where interpretation of some basic company policy (eg customer entertainment) needs to be better supported by examples of what is appropriate and inappropriate behaviour. This will be achieved through the new Code of Conduct.

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