Ethical Conduct


Policy

Sigma Strategy has a strong commitment to ethical conduct and transparency. We believe we have a responsibility to serve the community, our people and our clients by doing the right thing and acting fairly and transparently.

The purpose of this policy is to:

  1. set out the responsibilities of the Company and its subsidiaries, our employees, operations and suppliers in observing and upholding the Company’s position on ethical conduct and transparency; and
  2. provide information and guidance to our employees on how to recognise and deal with ethical issues.

This policy is endorsed by the Company’s board and management, who have ultimate responsibility for its implementation.

Scope

This policy applies to all directors of the Board, management, staff and contractors engaged and undertaking work on behalf of the Company.

This policy applies to our operations, activities and all of our dealings with third parties whether they be with private organisations, individuals or any representatives of such persons. Compliance with this policy is the responsibility of all Company personnel, failure to uphold this policy can result in disciplinary action.

Meaning of Ethical Conduct

Ethical conduct means acting with honesty, integrity, probity, diligence and fairness, and not benefiting from practices which may be dishonest, unethical or unsafe. Ethical conduct ensures that corruption or misconduct is identified and addressed.

Ethical Standards

The Company endeavours to ensure that we and our personnel comply with all laws within our operations and activities.

  1. we act with integrity,
  2. we avoid conflicts of interest or corrupt practices,
  3. suspected wrongdoing is reported and investigated impartially,
  4. appropriate action is taken, and 
  5. any outcomes are communicated transparently.

Public Interest Disclosure Act 2013 (Cth)

The Public Interest Disclosure Act 2013 (Cth) ensures that disclosers who suspect wrongdoing within the Commonwealth public sector can raise their concerns. The Act offers protection to disclosers and witnesses from reprisal action.

For further information, please visit the Commonwealth Ombudsman website.

The National Anti-Corruption Commission (NACC)

The NACC is an independent Australian Government agency that detects, investigates and reports on serious or systemic corrupt conduct in the Australian Government public sector. There are four types of corrupt conduct under the NACC Act. A person engages in corrupt conduct if:

  • they are a public official and they breach public trust
  • they are a public official and they abuse their office as a public official
  • they are a public official or former public official and they misuse information they have gained in their capacity as a public official
  • they do something that could cause a public official to behave dishonestly or in a biased way when they carry out their official duties – any person can engage in this type of corrupt conduct, even if they are not a public official themselves.

For further information, please visit the Attorney General’s Department website.

Contact

For any questions or notifications under this policy please email [email protected]

To make a PID disclosure, please visit https://www.ombudsman.gov.au/complaints/public-interest-disclosure-whistleblowing

To make a report to the NACC, please visit https://www.ag.gov.au/integrity/national-anti-corruption-commission/how-make-referral-nacc