Code of Business Ethics

Our Compass is your guide to IDAPNG's ethical principles and expectations. It’s aligned to our values of professionalism, respect and perseverance, which enable us to lead with integrity. By referring to it often, you can be confident that your actions and decisions are in line with IDAPNG’s requirements for ethical business conduct.

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The requirements and guidelines described in our Compass flow from six core ethical expectations, which we all must know and follow:

1. OUR CODE - We build trust by making informed, ethical decisions and seek support whenever we are unsure. 

2. OUR PEOPLE - We maintain a safe, respectful, inclusive and supportive environment where harassment and discrimination have no place.

3. OUR ORGANISATION - We do business with integrity and transparency, and we are a law-abiding, responsible corporate citizen.

4. OUR ASSETS - We protect our organisation's reputation, assets, programs and intellectual property.

5. OUR ENGAGEMENT - We respect human rights and make a positive social and environmental impact in the community.

6. OUR VOICE - We speak up whenever we have ethical concerns and do not tolerate retaliation against those who raise such concerns.

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Every time you act, remember the 3 Ps:

• PURPOSE - What is the purpose of my action?

• PRINCIPLES - What principles should guide my action?

• PERCEIVED - How will my action be perceived?

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Each of us is responsible for acting with integrity when we conduct business. 

 

You are expected to:

• Be respectful, professional, honest and transparent;

• Not ask or allow another person or third party to do something that is not permitted;

• Always act with integrity, even if it means losing a business opportunity;

• Be mindful of ethical risks which may be elevated in certain markets and business models, and take steps to mitigate them;

• Cooperate and be forthcoming in any investigations, audits or assessments conducted internally or by a legitimate third party;

• Not destroy or alter records;

• Raise a compliance concern if you know of, or suspect, violations of the law, our Compass or steering documents.

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If you’re a manager, member of the Executive Team or member of the Board of Directors, you have an especially important role. You are responsible for driving a culture of integrity and compliance. 

 

Leaders are expected to:

• Encourage team members to ask questions and talk to them about challenging ethical situations;

• Ensure direct reports are properly trained and know how to comply with your Code of Business Ethics and steering documents;

• Avoid putting pressure on your team at the risk of implicitly encouraging unethical conduct;

• Report potential misconduct and support your team members when they raise concerns.

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We recommend that work environments be based on respect.

Treating colleagues with respect, dignity and inclusion brings out the best in everyone, and it’s the right thing to do. At IDAPNG, there is simply no room for harassment, threats, bullying or violence against anyone, regardless of their position or seniority.

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We prohibit all forms of harassment, threats and acts of violence, including:

• Physical, oral or written harassment directed at employees or any third party in the line of work; 

• Bullying, intimidation, hostility, humiliation, discrimination or psychological mistreatment;

• Offensive or disparaging remarks, jokes, images or name-calling;

• Unwanted attention or physical contact or other invasions of privacy or personal space;

• Behaviour intended to disturb or prevent normal work activities.

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We know that diversity makes us stronger.

Having a diverse and inclusive board helps ensure that we attract the best global talent, foster innovation and bring greater value to our members. We want everyone to feel valued and included. We must all contribute to ensuring IDAPNG is a place where each individual can grow and feel empowered – regardless of factors such as their personal background, cognitive perspectives or disability.

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We expect businesses to:

• Recruit, reward and promote people based on merit; 

• Prevent nepotism or discriminatory practices; 

• Avoid any conduct that could make a board member feel excluded or unwelcome.

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We win business by doing business with integrity. 

Reputation and trust are hard-won and easily lost. At the IDAPNG, we advocate our industry and regulatory positions to government bodies based on facts, and never seek to improperly influence actions by public officials. Offering or  giving any benefit to a public official, colleague, customer or other third party as a way to gain an undue advantage is called bribery, and is strictly prohibited. You must also not demand or accept any such benefits from anyone. We have no tolerance for any form of bribery or corruption. In addition, the IDAPNG will not make contributions, directly or indirectly, to political parties or individual politicians except to support voluntary employee contributions permitted under local law and supported by public reporting regulations. 

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You are expected to:

• Ensure that any gifts, entertainment, hospitality, sponsorships, donations and employment opportunities are compliant with our steering documents and the law; 

• Never provide any personal benefits to individuals, such as cash, cash equivalents, loans, vacations or similar benefits; 

• Be diligent when providing anything to public officials (or their family members) and remember that pre-approvals and more restrictive rules apply;

• Obtain the necessary approvals and document them;

• Never make a payment to expedite or secure a routine governmental action, such as the issuance of a visa, permit or license; 

• Not use personal funds or someone else’s funds to do something that you couldn’t do with corporate funds, for example purchasing illegal gifts such as ivory, narcotics or sexual services; 

• Consult Government & Industry Relations or Legal Affairs & Compliance prior to meeting with government officials.

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We act swiftly and transparently to disclose anything that may be a conflict of interest.
In our work, situations can arise where our professional judgment could be seen to be impaired by other competing interests related to relationships and roles we maintain outside of the organisation. This is called a conflict of interest, and it is not inherently wrong. However, we each have a responsibility to put legitimate business interests first. Whenever we become aware of a potential conflict of interest, we don’t ignore it; we ensure that it is properly disclosed and handled.
 

You are expected to:

• Avoid conflicts of interest when manageable; 

• Disclose all situations, transactions and relationships that could lead to or be perceived as a conflict of interest;

• Speak with your board and legal department who will help you manage the situation.

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Examples of potential conflicts of interest:

• Doing business with third parties that employ or are owned by your family members, friends or former colleagues;

• Hiring or supervising anyone with whom you have a personal relationship;

• Working in your free time for customers or suppliers; 

• Working outside the scope of your employment or taking on engagements or directorships that interfere with your job performance, require you to use information or assets or would create intellectual property;

• Engaging on behalf of your organisation with customers, suppliers or other external stakeholders of a company in which you have ownership or other significant financial interest.

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We compete on the merits of our programs and offerings.
Competition laws – also known as antitrust or anti-monopoly laws – exist to protect consumers and ensure that businesses have a fair opportunity to compete in the marketplace. They prohibit, for example, practices that fix prices, allocate customers or markets between competitors or restrict market competition. These laws also prohibit the abuse of a dominant market position.

 

We recommend that you:

• Not discuss or exchange competitively sensitive information with competitors either directly or indirectly through third parties;

• Not fix or control distributors’ resale prices;

• Check with Legal Affairs & Compliance before negotiating exclusivity or non-compete agreements or hiring restrictions with third parties;

• Contact Legal Affairs & Compliance if you have concerns in relation to any competition matters.

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We only work with third parties who abide by the same standards of integrity that we demand of ourselves.
Working with third parties can present significant risks that we must carefully navigate – so that the values we stand for aren’t compromised. At the IDAPNG, we only partner with those who share our high standards in relation to integrity, human rights, health and safety and the environment.

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We recommend that you:

• Work only with qualified, approved third parties that go through the responsible sourcing processes;

• Ensure that third parties sign and commit to your Code of Conduct for Business Partners or equivalent;

• Actively monitor the performance of third parties for compliance with the Code of Conduct for Business Partners and any other conditions upon which an approval decision was made;

• Never use a third party to do something that your employees are not allowed to do themselves.

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Note: A Politically Exposed Person (PEP) is someone who holds (or formerly held) a prominent public position or a family member or close associate of such a person. PEPs present a higher risk of being involved in corruption because of their position and influence. Be especially diligent when working with PEPs.

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We adhere to applicable laws and regulations governing international trade and anti-money laundering.
The European Union (EU), Papua New Guinea (P.N.G.), Australia and other countries enforce trade and sanctions laws; these include export and customs controls, embargoes and sanctions. Such laws impact the persons, countries and entities with whom we can do business. Organisations should be aware of any sanctions, import or export controls that might apply to business dealings before doing such business and ensure that a license is obtained when required.

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Money laundering is an illegal activity where someone attempts to hide the true origins of money that was obtained through crime. Terrorist financing is when funds are used to support terrorist activities. The IDAPNG does not allow any activities resulting in money laundering or terrorist financing.

We recommend that you:

• Never engage in a business transaction if you suspect that it involves funds connected with criminal activity;

• Adhere to all responsible sourcing and due diligence requirements.

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We handle confidential information and intellectual property with great care.
At the IDAPNG, our technical and financial information as well as our intellectual property are critical to our success. This includes research and development information, patents, business and product plans and strategies as well as member and sponsor information. We must ensure that such information is used for proper and authorised purposes only.

We recommend that you:

• Not discuss confidential information in public places or on the internet; 

• Only access or share confidential information if there is a legitimate business reason to do so;

• Only store confidential information on authorised devices and cloud services;

• Accompany your visitors at offices and facilities;

• Not take or use confidential information when you leave the company;

• Not attempt to improperly obtain confidential information belonging to other companies or third parties.

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Each of us has a responsibility to watch out for cybersecurity threats – such as malware or phishing – and follow best practices to protect information and systems. 

 

We recommend that you:

• Keep your computer and mobile devices updated to the latest software versions and change your passwords;

• Not share user IDs (signums) or passwords;

• Use the software provided for securely connecting your laptop to your organisation's network when away from the office;

• Never download or use unapproved software or devices;

• Encrypt emails containing any confidential or personal information.

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We do not engage in any form of insider trading and we use assets for legitimate purposes only.
Inside information is non-public and material information about companies that would have a significant effect on the price of financial instruments and securities, such as shares, bonds or derivatives, if disclosed. Using this information or providing it to others to trade in financial instruments and securities is illegal. It is called insider trading, and it must be avoided without exception.

 

We recommend that you:

• Not buy or sell financial instruments and securities when having inside information or tell others to do so;

• Not share inside information with anyone including colleagues except on a strict need-to-know basis, as approved by the project leader;

• Check with Legal Affairs & Compliance before trading if you are unsure if you are in possession of inside information.

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We process personal data responsibly and in accordance with data privacy laws.
We protect personal data and support global efforts to safeguard it. We adhere to global privacy principles and applicable laws, including the EU General Data Protection Regulation (GDPR). We also have contractual agreements which regulate how we process and share data.

We recommend that you:

• Collect and process personal data in accordance with the law and steering documents;

• Ensure that people from whom you obtain personal data understand why it is being collected and processed;

• Use personal data only for legitimate business purposes and approved uses necessary for your job;

• Share personal data only with people who are authorised to receive it;

• Report any suspected data breaches.

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Note: What is “personal data”?
Personal data is information that can be related to an identifiable person. Examples include name, address, phone number, email and bank or credit card information.

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We record all financial information diligently, accurately and honestly.
We must all take steps to prevent fraud and financial irregularities. We should always ensure that the true nature and extent of our business transactions are recorded transparently and accurately. Making false or misleading entries, or sidestepping internal controls, are strictly prohibited and may be illegal.

We recommend that you:

• Enter into written (never oral) contracts with customers and third parties;

• Ensure contracts reflect the substance of the commercial transaction;

• Avoid giving unusual incentives or agreeing to terms that are not in your orgaisation's best interest;

• Follow signature and spending authority and relevant approval processes;

• Record all financial transactions in accordance with applicable rules;

• Never authorise the payment of vague or questionable expenses or third-party invoices that are poorly documented or incomplete;

• Ensure expense reports are complete, truthful and accurate;

• Use corporate cards for legitimate business expenses;

• Provide all supporting documentation needed to ensure accurate financial statements;

• Check with your finance department if you are not sure what to do or have finance-related questions or concerns.

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Raise a concern if you become aware of for example:

• Payments to or from a third party in a country other than where the service was provided;

• Payments to a third party in a country known as a “tax haven”;

• Payments to or from third parties different from those specified in approved agreements;

• False, misleading or incomplete business records, including time reporting records;

• Pressures to make an inaccurate entry in your accounts or to omit relevant information;

• Unrecorded funds or financial accounts;

• Revenues or expenses that have been unduly shifted between time periods;

• Corporate cards used for illegitimate business expenses.

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We speak on behalf of our organisation only if authorised to do so and take care when posting on social media.
Our reputation depends on the transparency, accuracy and consistency of our public statements. That’s why we have measures in place to ensure the right information goes out. These measures apply to statements made publicly on social media or in articles, papers, speeches or other statements relevant to our organisation. While we promote freedom of expression, each of us is responsible and may be held accountable for social media posts that are inconsistent with our values.

As a member, we expect you to:

• Use good judgment and protect confidential information about our organisation;

• Make clear that your views are your own and that you do not speak for our organisation (unless you are authorised to do so);

• Not post anything that would cause embarrassment or harm to our reputation.

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Communicating responsibly...

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I’ve received a straight-forward question about the IDAPNG from a friend. May I respond?
We love speaking about what we do, but it all depends on what was asked. You cannot share confidential information, but you are, of course, encouraged to share officially published information. The key is to take a moment to think about this carefully before answering. You can ask members of our executive team if you need further guidance on what can and cannot be discussed openly.

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I’ve received an invitation to speak at an IDAPNG Summit/Conference. Do I need permission to speak?
The first step is to get approval from your line manager and notify Marketing & Corporate Relations. Generally, when speaking at conferences, focus on your own area of responsibility and personal opinions and observations – do not share sensitive or confidential company information.

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We respect the right to privacy and freedom of expression, as the two most salient human rights related to the services we deliver.
We fundamentally believe that our offerings bring positive change to people. At the same time, we work to mitigate and minimise the risk of potential misuse of our various programs. We do this by conducting due diligence in our engagements to assess, prevent and mitigate potential negative impacts on human rights. We also advocate strongly for freedom of expression and privacy protections. This includes raising concerns about new legislative, administrative, license or law enforcement rules if they may negatively impact individuals’ freedom to express their views or protect others from intrusion.

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We empower corporate communities to drive performance and positive impact.
We are proud of our various programs. They allow members to volunteer their time to serve the corporate community and make a positive impact in society. All active IDAPNG members are eligible to participate. Before volunteering, you must approve the terms and conditions within the program and adhere to the guidelines related to eligible volunteer activities.