THE CODEWE WORK BY.

This Employee Code of Conduct sets out the standards of behaviour, integrity, professionalism and workplace conduct expected of all employees. It supports a safe, respectful, productive and ethical workplace and must be read together with The Digital Plug’s disciplinary code, employment contracts and applicable policies and procedures.

Employees are expected to familiarise themselves with and comply with this Code. A breach may result in corrective or disciplinary action in accordance with The Digital Plug’s disciplinary procedures and applicable law.

This Code applies to all employees, irrespective of position, seniority, location or employment status, whenever they are performing work, representing the Company, using Company property or systems, attending work-related activities, working at client or supplier premises, travelling on Company business, or engaging in conduct that has a material connection to the employment relationship.

• Report for work punctually and remain available for duty during agreed working hours.
• Comply with starting times, finishing times, breaks and attendance procedures.
• Notify the appropriate manager or HR of absence or late arrival in accordance with Company procedure.
• Do not leave the workplace, allocated post or workstation without appropriate permission where permission is required.
• Submit required daily updates, reports, timesheets, registers, job cards or other work records accurately and within required deadlines.
• Do not falsify attendance, biometric, timekeeping or work records, and do not clock in or out for another employee.
• Where overtime is lawfully agreed or otherwise lawfully applicable, comply with the agreed arrangements unless there is a reasonable justification for being unable to do so.

• Perform duties with reasonable care, skill, attention and diligence.
• Meet reasonable quality, productivity and operational standards relevant to the role.
• Carry out lawful and reasonable instructions issued by authorised managers or supervisors.
• Do not deliberately refuse or defy legitimate managerial authority.
• Take reasonable care to prevent mistakes, loss, damage, waste and avoidable rework.
• Raise uncertainty about instructions, safety or required standards promptly with the relevant manager.

Where an employee is unable, rather than unwilling, to meet a performance standard because of incapacity, lack of competence or ill health, the matter should be managed through the appropriate performance or incapacity process rather than automatically as misconduct.

• Treat all people professionally and respectfully.
• Do not engage in abusive, threatening, intimidating, insulting or violent conduct.
• Racism, unfair discrimination, harassment, sexual harassment, bullying and victimisation are prohibited.
• Do not retaliate against a person for raising a genuine grievance, reporting suspected wrongdoing, participating in an investigation or exercising a lawful workplace right.
• Do not knowingly make false or malicious allegations against another person. An allegation that is made in good faith but is not substantiated does not, by itself, amount to misconduct.
• Resolve disagreements professionally and use the appropriate grievance, reporting or management channels.

• Act honestly in all dealings with the Company and its employees, clients, suppliers and stakeholders.
• Theft, attempted theft, fraud, forgery, bribery, corruption, misappropriation and deliberate dishonesty are prohibited.
• Do not submit falsified documents, claims, qualifications, medical certificates, declarations or other records.
• Do not deliberately conceal material information where there is a clear duty to disclose it.
• Do not request, offer, accept or provide an improper benefit, inducement, kickback, bribe or favour.
• Comply with Company rules governing gifts, entertainment, hospitality and benefits.

• Act in the legitimate interests of the Company when performing Company duties.
• Disclose actual, potential or reasonably perceived conflicts of interest promptly.
• Do not use a Company position, information, opportunity or resource for improper personal gain.
• Do not improperly compete with the Company, further the interests of a competitor, or undertake conflicting outside work contrary to contractual or policy requirements.
• Employees involved in procurement, appointments, supplier selection or commercial decisions must disclose relevant personal or financial relationships.

• Protect confidential Company, employee, client, supplier, commercial, technical and financial information.
• Only access, use, copy, disclose, retain or process personal and confidential information where authorised and required for legitimate work purposes.
• Do not send confidential Company information to personal email accounts or unauthorised storage locations without permission.
• Comply with applicable Company privacy, records-management and information-security policies.
• Confidentiality obligations continue after employment ends where applicable.

• Use Company devices, systems, email, networks and internet access responsibly and primarily for authorised purposes.
• Do not access another person’s account, restricted files or systems without authority.
• Keep passwords, authentication codes, access cards and other credentials secure and do not share them contrary to Company requirements.
• Do not disable, bypass or interfere with security controls.
• Do not install unauthorised software or connect unauthorised equipment where prohibited.
• Immediately report suspected phishing, malware, loss of devices, compromised credentials, data breaches or other cybersecurity incidents.

• Take reasonable care of Company property, equipment, devices, documents, tools and other resources entrusted to you.
• Do not intentionally damage, sabotage, misuse, remove, consume or dispose of Company or third-party property without authority.
• Private or incidental use of Company resources must comply with applicable Company rules.
• Return Company property when requested and upon termination of employment.
• Report loss, theft, damage or malfunction promptly.

• Comply with occupational health and safety rules, procedures and lawful instructions.
• Wear prescribed personal protective equipment and use safety equipment correctly.
• Do not tamper with, disable or bypass safety devices or controls.
• Report accidents, injuries, near misses, hazards, unsafe conditions and material safety incidents promptly.
• Do not engage in horseplay, unsafe practical jokes or conduct that endangers yourself or others.
• Employees must be fit to perform their duties safely. Reporting for or remaining on duty materially impaired by alcohol, unlawful drugs or other mind-altering substances is prohibited.
• Substance dependency or other health-related incapacity should be distinguished from wilful misconduct and handled through the appropriate Company process where applicable.

• Only authorised and appropriately licensed employees may operate Company vehicles or restricted equipment.
• Use Company vehicles only for authorised purposes and comply with applicable fleet rules.
• Drive responsibly and take reasonable care of vehicles and passengers.
• Report accidents, vehicle damage, defects, fines or incidents promptly in accordance with Company procedures.
• Do not permit unauthorised drivers or passengers where prohibited.
• Employees working at tower sites, client premises or field locations must comply with applicable access, safety, security and site requirements.

• Do not possess, consume, distribute or use unlawful drugs at the workplace or while performing Company duties.
• Alcohol may not be consumed or possessed at work except where expressly authorised by the Company and consistent with applicable policy.
• Employees may not perform duties while materially impaired in a manner that creates an operational, performance or safety risk.
• Employees using prescribed medication that may materially affect safe performance should follow applicable Company health and safety procedures and seek appropriate guidance where necessary.

• Communicate professionally with colleagues, clients, suppliers and members of the public.
• Do not represent personal views as official Company views without authority.
• Do not disclose confidential or personal information through social media, messaging platforms or other communication channels.
• Employees must not engage in conduct, including off-duty conduct, where there is a demonstrable and material connection to employment and the conduct materially prejudices legitimate Company interests, safety, reputation or the employment relationship.

• Observe reasonable Company access-control and security procedures.
• Do not allow unauthorised persons into restricted Company areas.
• Recording or distributing confidential workplace meetings or conversations must comply with lawful and reasonable Company rules, privacy requirements and confidentiality obligations.
• Company access cards, keys, passwords and security credentials must not be lent or transferred without authority.

Employees are encouraged to raise suspected misconduct, fraud, harassment, discrimination, safety risks, conflicts of interest, data incidents or other serious concerns promptly and in good faith through the appropriate manager, HR or designated reporting channel.

• Reports should be truthful and made in good faith.
• Employees must co-operate honestly with legitimate workplace investigations.
• Retaliation or victimisation against a person who raises a genuine concern or participates in an investigation is prohibited.
• Confidentiality should be maintained as far as reasonably practicable during investigations.

Managers and supervisors carry an additional responsibility to model the standards in this Code. They are expected to communicate standards clearly, act consistently, address misconduct promptly and fairly, protect confidentiality, escalate serious concerns appropriately and avoid retaliation or favouritism.

A breach of this Code may result in corrective or disciplinary action. The appropriate response will depend on the facts and seriousness of the conduct, culpability, actual or potential harm, the employee’s circumstances and disciplinary record, consistency, mitigating and aggravating factors, prospects of correction and the effect on the employment relationship.

The Company applies corrective and progressive discipline where appropriate. Serious misconduct may, depending on the circumstances, justify a final written warning or dismissal for a first offence where the sanction is fair and appropriate. The disciplinary schedule is a guideline and does not create automatic penalties.

Employees will be afforded a fair and reasonable opportunity to respond to allegations before disciplinary decisions are made, in accordance with the Company’s disciplinary procedure and applicable labour law.

This Code must be read together with the Company’s Disciplinary Code and Procedure, employment contracts and applicable policies, including policies dealing with leave and attendance, grievances, harassment, health and safety, IT and information security, privacy and personal information, confidentiality, fleet/vehicles, alcohol and drugs, conflicts of interest, gifts and ethics, and any other applicable workplace rules.

Where legislation, a collective agreement or binding bargaining council instrument provides a more specific or mandatory requirement, the applicable legal or collective requirement will prevail to the extent of any inconsistency.