Real Pet Food Co.

Code of Conduct

Company Code of Conduct

1. Purpose

Real Pet Food Company Pty Ltd ACN 618 564 257 and its related bodies corporate (RPF) are committed to ensuring that the Company can meet its commitment to the policy statement, it requires all workplace participants to treat each other with respect and courtesy in the workplace and refrain from unlawful behaviour.

The purpose of this policy is to provide a framework of principles for conducting business and dealing with customers, colleagues and other stakeholders which are to:

    • Meet the standards of behaviour in accordance with our RPF values that demonstrate personal integrity, professionalism and individual accountability to interact with others in a way that embodies Real Pet Food;
    • to be scrupulous in proper use of Company information, funds, equipment and facilities;
    • exercise fairness, equity, proper courtesy, consideration and sensitivity in dealing with customers, employees and other stakeholders; and
    • avoid real or apparent conflict of interests.

    2. Application

    This code of conduct applies to all employees of Real Pet Food Company (RPFC) and its subsidiaries (“the Company”). If an employee has doubts about any aspect of this code, they must seek clarification from their manager or the Human Resources Team.

    3. Responsibilities

    Employees are required to:

    • Act with personal and professional integrity;
    • Ensure health and safety of all those affected by your activities and the activities of the Company;
    • Develop competence and perform their duties with skill, honesty, care and diligence, using authority in a fair and equitable manner;
    • abide by policies and procedures, instructions and lawful directions that relate to their employment and duties;
    • Employees must promote the interests of the company and safeguard the company’s reputation (other than when using approved whistleblower channels); 
    • Prevent discrimination and harassment; and
    • Respect different opinions.

    4. Real Pet Food Values

    The Real Pet Food Values underpin who we are as an organization. Each member of our pack across every Region has an obligation throughout their employment to ensure every decision and interaction is in accordance with our values.

    • Work as a Pack – How we band together: We’re a unique, talented and hardworking team. Our success is enabled by our ability to communicate and collaborate across boundaries as one Real Pet family.
    • Change the Game – How we innovate: We think differently, and we challenge ourselves to create a healthier and happier life for our pets. To us, innovation is about changing and improving what we do, and doing it better than anyone else.
    • Lead With Passion - How we lead: We are committed and passionate about leading the way in a new era of pet food. This requires us to be agile and resilient, to know when to keep chasing, but not chase our tails!
    • Make Your Mark – How we get ahead: We relish in creating an environment where our people can be their best every day.   We all play an important role in shaping who we are and the success we achieve.

    5. Code of Conduct

    5.1 Conflict of Interest

    Employees must avoid any personal, financial, or other interest which may be in conflict with their duties and responsibilities to the Company. Any interest which may constitute a conflict of interest must be promptly disclosed to an appropriate senior manager. Accepting any external appointment, such as a board appointment (other than to the board of a non-Trading family company), working for another organisation or conducting a business, is not permitted without the written permission of the Chief Executive Officer (CEO), or in the case of the CEO, of the Chairman. Related Policy: Conflict of Interest Policy

    5.2 Confidentiality

    Employees must preserve the confidentiality of colleagues, and the company and must not use or disclose information obtained through their employment other than in the proper course of their duties or when using approved whistleblower channels. Information obtained in the course of employment must not be used to obtain financial reward or other benefit, or to take advantage of another person.

    5.3 Company Property

    Company property, funds, facilities and services must be used only for authorised purposes. Unless governed by law or otherwise agreed in writing, any intellectual property developed by an Employee during or as a result of his or her employment by the Company is the sole property of the Company.

    5.4 Public Statements

    The Company’s relationships with the media and the investment community are conducted exclusively by the CEO or as delegated by the Board.

    5.5 Gifts and Entertainment

    From time to time, employees may entertain or be entertained and give or receive gifts in the course of their duties.

    However,

    • gifts should never be offered or accepted in circumstances where the outcome of a transaction may be influenced by the gift or give rise to the perception that the transaction may be influenced by the gift;
    • employees involved in a tendering process must refrain from actions which may give rise to an expectation of some favoured treatment from or by any tendering party; and
    • under no circumstances must employees offer or accept money. Gifts and entertainment reasonably estimated to be more than a value of $150 must be disclosed to the manager who would usually authorise similar expenditure by the employee accepting the gift or entertainment. Invitations where travel and accommodation are involved must be authorised by a senior manager, or in the case of senior managers, by the CEO, or in the case of the CEO, by the Board.

    5.6 Compliance

    Employees must be aware of, understand and fully comply with both the letter and the spirit of relevant legislation and regulations, as well as the Company’s policies and procedures, values, instructions, and lawful directions that relate to their employment and duties;

    6. Breaches of the Code

    Employees have a duty to observe the code and ensure that no breaches occur. Breaches require immediate attention and employees have a duty to report known or suspected breaches of the code.

    Any employee, who in good faith, makes a complaint or disclosure about an alleged breach of the code and follows the reporting procedure outlined below, will not be disadvantaged or prejudiced in the making of such a complaint or disclosure. All reports will be treated as confidential.

    6.1 Reporting a breach

    A complaint or disclosure about an alleged breach of the code should be in writing and contain details about the date, time and nature of the alleged breach and include any available supporting material.

    The allegation should be made to the employee’s direct line of Management, or if the employee believes the immediate manager may be implicated, to a senior manager or to the CEO.

    A report of an alleged breach can also be made following the process outlined in the Company’s Whistleblower Policy.

    The person to whom the allegation is made to should undertake a prompt and thorough investigation and determine whether any action is required.

    The reporting employee will be informed of the outcome of the investigation. If unsatisfied with the outcome of the investigation, the employee may refer the matter to a senior manager or the CEO.

    Employees may at any time discuss a matter or seek advice on how to proceed with a matter, from the Human Resources lead, or any other senior manager.

    END OF POLICY