Ethical Business Conduct

At Santos, we promote high standards of corporate governance and ethical conduct.

This applies to our employees and representatives, the Board and executive management team.

To this end the Company has provided its employees with a clear set of rules, values and guidelines to follow when carrying out their work as a Santos employee and representative.

We also have Board Guidelines and the Company has adopted a Code of Conduct which prescribes that, in addition to compliance with all applicable legal requirements, the Board expects all Directors, executives and employees of the Company to adopt appropriate standards of professional and business conduct in their dealings on behalf of the Company.

In addition, the Board, in conjunction with executive management, has implemented procedures designed to ensure compliance by all employees with those standards.

In particular,  the Code of Conduct requires that Directors and employees:

  • Avoid conflicts of interest, and ensure that all business transactions are conducted solely in the best interests of the Company.
  • Are aware of, and comply with laws and regulations relevant to the Company’s operations including environmental and trade laws both in Australia and abroad.
  • Protect any Company assets under their control and not use Company assets for personal purposes, without prior Company approval.
  • Do not disclose or use in any improper manner confidential information about the Company, its customers or affairs.
  • Respect the privacy of others and comply with the Company’s privacy policy.
  • Report misconduct.

 

The standards of conduct expected of Santos staff, including those directed at the broader stakeholder constituency of shareholders, employees, customers and the community, are also recorded in separate guidelines and policies relating to dealing in securities, the environment, occupational health and safety and human resources. Further, a Code of Conduct, based on that developed by the Group of 100, applies to the CFO and all other officers and employees within the finance function of the Company who have the opportunity to influence the integrity, direction and operation of the Company and its financial performance.

Where applicable, the guidelines and policies are incorporated by reference in individual contracts of employment or expressly set out in those contracts, including provisions relating to: conflicts of interest; confidentiality and restrictions against use and dissemination of information; use of Company assets; perquisites, tender processes, benefits and contact with suppliers; employment opportunity practices; privacy; training and further education support; and smoking, alcohol and drugs.