Our Code of Conduct is not only a document the underpins how we do business but is a key guide for improving our conduct to ensure we are always treating our customers, partners and staff with respect. Following our Code is critical to ensuring we deliver on every aspect of our service.

1. Purpose

This Code of Conduct sets out the guidelines which all employees, contractors, consultants and directors (employees) of Vehicle Solutions Australia Pty Limited (ABN 12 548 824 435) and its subsidiaries (collectively, VSA) are required to follow when performing all duties related to their role.

VSA’s board of directors (Board) is committed to achieving the highest possible standards of ethical behaviour and best practice in corporate governance. This Code of Conduct outlines the standards expected of employees and is intended to guide them in relation to their business conduct and behaviour in the workplace.

The standards set out in this Code of Conduct cannot, and do not try to, anticipate every situation which may pose a legal, ethical or moral issue. Therefore, this Code of Conduct is not a prescriptive set of rules for business behaviour, but rather a practical set of principles giving direction and reflecting VSA’s approach to business conduct.

2.Who the code applies to

All employees of VSA must comply with the Code of Conduct. A reference to ‘employees’ in this Code of Conduct includes permanent and temporary employees, contractors, consultants and directors.

The Code of Conduct applies to all VSA business activities with suppliers, contractors, customers, shareholders and employees in Australia and overseas.

Responsibility lies with every person covered by this Code of Conduct to conduct themselves in accordance with this Code of Conduct. If there is any doubt, advice should be sought from VSA management before taking any action.

All employees of VSA must:

  • actively promote the highest standards of integrity and ethics in carrying out their duties;
  • deal with clients, shareholders, competitors, suppliers, the general public and each other with the highest level of honesty, efficiency, fairness and integrity and observe the rule and spirit of the legal and regulatory environment in which VSA operates including obligations related to the licences VSA holds;
  • disclose any actual or perceived conflicts of interest of a direct or indirect nature of which they become aware and which they believe could compromise in any way the reputation or performance of VSA;
  • respect confidential information acquired in the course of VSA’s business which is not in the public domain and not divulge such confidential information to any person unless specific authorisation is given for disclosure by VSA’s managing director or disclosure of the information is required by law;
  • not use VSA’s name or their position for personal gain or in competition with VSA;
  • act with due care and diligence in fulfilling their functions; and
  • not engage in conduct which may bring discredit upon VSA.

3. Code Governance

The Code annually to ensure compliance with applicable laws and that it continues to meet legislation and industry standards.

The Code will be subject to more frequent review if there are grounds to believe the Code fails to meet the objectives of VSA or to respond to changes in legislative or regulatory requirements.

4. What to do if you suspect the Code has been breached

You are encouraged to report to the managing director any behaviour or situation which you believe breaches or potentially breaches VSA’s Code of Conduct, policies or the law.

5.Equal Employment

VSA expects that all officers, employees and all people who work at VSA, including contractors and consultants, treat one another with respect and dignity.

VSA’s policies and practices promote equal opportunity and demonstrate a commitment to providing an environment that values diversity with a conscious desire to achieve understanding, respect, inclusion and continuous learning.

In addition to complying with the Fair Work Act 2009 (Cth) and other relevant Australian employment and equal employment opportunities (EEO) legislation, VSA is committed to complying with all other applicable civil and human rights laws.

6.Harassment Free Workplace

VSA is committed to a working environment that is free from discrimination, harassment, bullying, vilification, victimisation or other intimidating personal behaviors. VSA is committed to maintaining a professional and harassment-free working environment – a place where employees act with respect for one another and for those with whom we do business.

7.Health, Safety, Environment and Community

VSA is committed to ensuring a safe working environment for all employees.

VSA conducts its operation in compliance with applicable Work Health and Safety laws and regulations in the states we have employees located.

8.Compliance with Laws

Depending on their individual responsibilities, employees should be familiar with corporate, competition and consumer, taxation, employment, work health and safety, equal opportunity and discrimination, privacy and environmental laws and regulations as well as any of VSA’s internal policies in relation to such matters.

It is the responsibility of each and every employee to ensure that they do not personally engage in, allow or ignore any behavior by others that may contravene their legal responsibilities (including, in particular, the provisions of Competition and Consumer Laws). A breach of Competition and Consumer Laws may have serious consequences for VSA and the employee involved in the breach. Any breach of Competition and Consumer Laws will be viewed by VSA as a serious contravention of the terms of the employment of the employee involved in the breach and may result in disciplinary action, up to and including dismissal.

9. Conflict of Interest

VSA has adequate arrangements to manage any conflict of interest that may arise wholly or partially in relation to activities undertaken by VSA and its employees in the provision of financial and credit services. Conflicts of interest may impact on the quality of financial and credit services provided by VSA.

Employees make business decisions every day. All business decisions and any related action must be based on the needs of VSA and not on personal interests or relationships. It is essential that employees avoid even the appearance of conflicts of personal interest and those of the business. The perception of a conflict of interest can do as much damage to VSA’s reputation as an actual conflict of interest. Employees must be mindful of when a conflict may be perceived by others and take action to avoid or address this risk.

10. Acting Responsibly with Customers, Suppliers, Competitors and Others

Employees dealing with customers, suppliers, partners, competitors and other third parties must engage with such persons fairly, ethically, honestly and respectfully and in compliance with applicable laws and VSA’s policies. In particular:

  • employees must be fair, honest and open in all business dealings;
  • employees must not misrepresent VSA’s products, services or prices and must not make false claims about those of VSA’s competitors;
  • purchasing decisions must be based on such commercially competitive factors as quality, price, reputation and reliability and a supplier’s level of service; and
  • employees must respect confidential information that is obtained through any business

11. Gifts, Gratuities and Entertainment

VSA is committed to ensuring all business relationships with suppliers are legal and based on professional integrity. Employees must not give, seek or accept in connect with the business any gifts, meals, refreshments or entertainment which goes beyond common courtesies associated with ordinary and proper course of business.

12. Bribery, Corruption and Fraud

VSA places a strong emphasis on the values of honesty and integrity. Bribery, fraud and corruption are incompatible with VSA’s Values.

Acts of bribery, corruption and fraud are subject to strict disciplinary action, including dismissal and possible civil and/or criminal action. All employees are prohibited from committing fraud or engaging in fraudulent behavior.

13. Proprietary, Data Protection and Confidential Information

VSA employees may need to collect, use and disclose personal and confidential information relating to VSA’s business partners, colleagues, customers and others during the course of their employment. This information is very valuable and needs to be protected. All employees are obligated to respect and protect VSA’s proprietary and confidential information by ensuring they:

  • collect, use, store, handle, update and destroy information, particularly personal information, in line with applicable policies and processes at all times;
  • maintain strict confidentiality of information safeguarded to them;
  • do not share that information with anyone – even a co-worker – who does not need to know about it;
  • ensure that confidential information is safely stored through technical safeguards;
  • do not disclose any information about VSA that is not already in the public domain without the proper authority to do so;
  • report confidentiality or privacy breaches through appropriate channels as quickly as possible; and
  • never release information about customers or colleagues to third parties outside of VSA unless the person the information relates to, has agreed to such release in writing or if VSA is required to release the information under the law.

Information provided to VSA in good faith by our clients must be treated with the same degree of confidentiality as VSA’s information.

The obligations of confidentiality extend beyond an employee’s employment with VSA. After the termination of employment, employees may not disclose or in any way provide confidential information to others.

Any business innovations, proposals, technical or strategy documents that an employee creates while employed or engaged by VSA are the sole property of VSA.

14. Anti-money Laundering and Counter Terrorism Financing

Money laundering is the concealment of money which was made by carrying out illegal activities. Terrorism financing involves the use of money raised from legitimate sources, such as donations and business profits as well as money from illegal sources to fund terrorism. VSA has strict controls in place to mitigate the risk of money laundering and terrorism financing.

Employees are expected to ensure that they follow all procedures in place to mitigate the risk of money laundering and terrorism financing.

15. Whistleblowing

VSA does not tolerate incidents of fraud, corrupt conduct, legal or regulatory non- compliance, including misconduct in respect of, or an improper state of affairs or circumstances in relation to VSA’s accounting and auditing matters, by its officers, employees, directors, contractors and consultants. VSA expects that employees will report known, suspected or potential cases of disclosable matters.

Failure to raise issues could result in disciplinary action.

A disclosure by a whistleblower of a disclosable matter and the identity of a whistleblower will be kept confidential, subject to any legal requirements and provisions permitting disclosure.

16. Communications and Communications Technology

Under no circumstances should an employee make comments to the media or submit a story for publication in the media (including internet-based forums and social media).

All communications data and information sent or received using VSA’s property, is VSA’s property and not private communications. VSA owns and/or controls access to all communication equipment, including laptops, software, email and voicemail. VSA reserves the right to monitor all communications, including internet usage.

VSA’s property is in place to enable employees to perform the business-related duties that each position requires. The use of VSA’s property is for the sole purpose of conducting business- related tasks, noting that employees may also use VSA property such as mobile phones and laptops for reasonable personal use (as determined by VSA).

17. Legal Actions

Any actual, proposed or potential legal action against VSA or employees must be notified to the managing director as soon as becoming aware of such an action. Any actual, proposed or potential legal action by VSA or employees on behalf of VSA against another party must be approved in advance by the managing director.

18. Code Expectations

All employees must comply and actively promote compliance with applicable laws and regulations and must not engage in conduct likely to bring VSA into disrepute.

Employees must recognise and respect the rights of individuals regarding privacy, private and confidential information.

Updates to this policy

We will update this policy from time to time where necessary to reflect changes in applicable laws or in our privacy compliance practices. The latest version of this policy will always be available on our website.