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CODE OF CONDUCT

BRIS CODE OF CONDUCT

At BRIS OUR growing success is embedded in our deliberate principles of placing priority to our customers’ benefits in everything we do.

We take full responsibility for our clients, workers, investors and our host community at every point and as such comply with all applicable laws, company policies, procedures, rules, regulations and contracts terms.

These are what we live and operate by at BRISCode of Conduct & Ethics at BRIS

BRIS is committed to achieving outstanding performance and results to provide value to our shareholders, while considering the interests of employees, customers, the community and others with whom we do business. In striving for outstanding performance and results, we should not compromise our ethics or principles. BRIS places great importance on honesty, integrity, quality and trust.

No matter what your role is, or which location you work in, you are expected to:

• demonstrate the behaviours of honesty, integrity, quality and trust at all times.
• set an example for others and recognise those around you who also demonstrate these behaviours.
• speak out when you feel that these behaviours are threatened or compromised.

What is the Code of Conduct and Ethics and the Conduct and Ethics Policy Framework?

The Code of Conduct and Ethics sets standards for the way we work at BRIS.
The Code provides a practical set of guiding principles to help you make decisions in your day to day work, whatever you do and wherever you do it. The Code is supported by a number of more detailed policies that form part of the BRIS Conduct and Ethics Policy Framework. These are mentioned in this document.

You can download the full BRIS Code of Conduct here.

BRIS’s Code of Conduct principles are:

BRIS’s reputation as a trusted and respected organisation is one of our greatest assets. Each of us has the ability to build and maintain BRIS’s reputation, or to harm that reputation and undermine BRIS’s performance.

BRIS shareholders, customers and the community expect BRIS and everyone who works at BRIS to act professionally and ethically. We must do what we can to meet these expectations and support others to do the same. In everything you do, you should consider how your or someone else’s actions could impact on BRIS’s performance, reputation or other assets and take action to prevent or remedy anything that could adversely impact BRIS.

Honesty and integrity are essential to everything we do at BRIS.

Our success depends on the trust of our customers, which is earned by acting with honesty and integrity and by considering BRIS, our shareholders, customers, colleagues and the general community when making decisions.

Honesty and integrity can be just as important in the things we fail to do. For example, failing to report the suspicious or dishonest conduct of a colleague reflects on your own honesty and integrity, and may ultimately affect BRIS’s reputation for honesty and integrity as well.

BRIS values difference and is committed to achieving a truly diverse workforce that remains inclusive and respectful of each other’s differences.

We are all expected to treat all people we deal with through our work at BRIS with dignity and respect, whether they are colleagues, customers, suppliers or other third parties.

Unlawful discrimination, harassment of any kind, bullying or victimisation or other unacceptable or offensive conduct will not be tolerated.

BRIS believes the safety, security and physical and mental health of BRIS people lie at the heart of each person’s ability to contribute to our success. BRIS respects the right of all individuals to work in a safe working environment that promotes well-being.

Acting honestly and with integrity also means managing conflicts of interest and never putting yourself in a situation that puts, or appears to put, your own personal interests before those of BRIS or our customers.

The perception of a conflict of interest can do as much damage to BRIS’s reputation as an actual conflict of interest. You must be mindful of when a conflict may be perceived by others, and take action to avoid or address this risk.

In your work at BRIS, you may come across private and confidential information relating to BRIS, colleagues, customers, suppliers or other third parties. When people provide us with this type of information they are trusting BRIS.

Misuse of confidential and private information can have severe commercial and reputational consequences for BRIS and can also greatly affect those whose information is misused. If people feel they can’t trust us with their information they are unlikely to trust us with their finances or business.

BRIS is committed to maintaining the confidentiality and security of this information and you are expected to do your part to help honour this commitment.

Integrity and trust are inconsistent with improper payments, benefits or gains of any kind.

There are certain situations that have a higher risk of an improper payment, benefit or gain being made or received.

These include rewards from current or potential customers or suppliers that are out of the ordinary, such as cash, cheques, gifts, gift certificates or travel of a high value. Where rewards from a current or potential customer or
supplier create any obligation or expectation that you will give preferential treatment to the person or company offering the reward, the reward is improper and must be refused.

As a global organisation, we are subject to laws and regulations in all the locations in which we do business.

You must be familiar and comply with all relevant laws and regulations in the location or locations in which you work. Any breaches of the law can have serious consequences beyond your employment, both for BRIS and for you as an individual.

Although the laws that apply may be complex, ignorance is no excuse. You are ultimately responsible for understanding which laws and regulations apply to you and the work you do.

BRIS is committed to helping you by designing systems and processes that comply with the law, and by providing relevant policies and training.
This Code, and BRIS’s policies, procedures and practices take into account not only the strict letter of the law but also the BRIS way of doing things. In many cases, the standards expected by BRIS exceed those required by law. Wherever there is an inconsistency between an applicable law and this Code, an BRIS policy, procedure or practice, you must comply with whichever is the higher standard.

As someone working with BRIS, you are required to comply with this Code and report any conduct that may be in breach of the law, this Code, the underlying Policy Framework or any other BRIS policies or procedures as soon as you can.

Any reports of a breach of the Code will be taken seriously and investigated appropriately by BRIS. It is important that all reports are based on truth and fact. If you make a report in good faith, you will not be disadvantaged personally or in your
employment, even if the conduct that is reported is later found not to be in breach of the Code. At the same time, if you make an intentionally false or malicious report, you may find yourself in breach of the Code, and dealing with the consequences that follow.

There are many different avenues for reporting a breach – who you should raise the matter with will depend on the particular circumstances.

In most cases, you should raise breaches of the Code, the law or policies and procedures with your line manager, your human resources representative or your operating risk and compliance representative.