Code of Conduct Policy

PURPOSE

The ACI Global Code of Conduct is intended to provide guidance for Directors and workers on the standards that ACI Global expects in the conduct of its operations.

The Code has been endorsed by the Managing Director Ian Erskine and applies to all Directors, employees, and consultants. If you are in doubt as to whether anything you are contemplating might breach the Code, ask.

If the activity can be justified in terms of ACI Global expectations and obligations and the activity being proposed involves no legal impropriety then that activity, can be undertaken.

SPECIFIC STANDARDS OF CONDUCT

Awareness of Conflicts

There may be times when our personal interest’s conflict with those of ACI Global or our interested parties. ACI Global has a statutory duty to prefer the interests of interested parties in the event of a conflict.

If the conflict is between our personal interests and ACI Global, we should take action to remove or manage the conflict to avoid detriment to ACI Global.

If you have a conflict, you must disclose that conflict to ACI Global Managing Director and together, are then responsible for putting into place measures to remove or manage the conflict. The conflict must also be recorded on the Quality Improvement Register.

Insider Trading

If you have non-publicly known, price-sensitive information such as information:

• Acquired through working on investments;
• About a proposal;
• About any other entity in which ACI Global may have an interest; or
• That has come to your knowledge through your employment with ACI Global, then you must not:
  • Deal in that entity's investments;
  • Pass that information on to another person; or
  • Encourage another person (for example, a family member) to make any investments in the entity.

Unauthorised Gains or Payments

As a general rule, we should not accept (or offer to give) gifts, services, discounts, gratuities or other gains from (or to) people who conduct business with ACI Global.

Directors, employees and consultants receiving gifts or soft dollar benefits from third parties by virtue of their employment or association with ACI Global must declare these to the Managing Director.

ACI Global Assets

These assets include office equipment, computer systems, the data on those systems (including the passwords allowing access to that data), intellectual property, brands, and corporate charge cards. ACI Global assets are provided to you for conducting the business of the company.

Duty of Care and Due Diligence

We need to exercise care and diligence in the performance of our duties. We have a responsibility to our interested parties to ensure that our work is accurate, that we attend to detail and that we make decisions based on the principles of risk and current information.

Key Principles of ACI Global

Directors, employees and consultants are expected to align their behaviour to ACI Global’s following key principles:

• Honest, Respectful, Professional, and ethical behaviour;
• Respect for people, organisations, and property;
• Promote the link between the Learner and their Sponsoring and or facilitating Organisation;
• Promote responsible Pricing for all services provided on the basis that education is not a pricing commodity;
• Legal compliance always;
• Independent verification of audit outcomes; and
• Reports are produced on a regular basis regarding adherence to this policy.

Confidential Information

In the course of performance of our duties, we may have access to confidential information about ACI Global and/or its interested parties.

It is very important not to use or distribute confidential information unless you have been given permission to do so. You must comply with the ACI Global Privacy Policy when handling personal information and sensitive information.

Fairness

ACI Global has a long-standing commitment to equal opportunity for not just workers but also learners. Discrimination, bullying or harassment of any kind is prohibited and is inconsistent with our philosophy.

All learners have the right to ongoing professional development including those with special needs.

Competitiveness

ACI Global is committed to fair competition. When competing for business we must do so fairly. This means not intentionally misleading customers, business partners, competitors, or the community; only using ACI Global’s reputation in legitimate ways; and refusing to engage in doubtful market practices.

Public Statements

Only the Managing Director may make public statements on behalf of ACI Global. We must take great care in public speaking engagements, media releases, when using social media and at official appearances.

In particular, we must be careful in the following areas:

• Sensitive information: Ensure all non-public, price sensitive information concerning ACI Global, or its businesses is disclosed to the Managing Director before it is released publicly or widely disseminated.
• The public face of ACI Global: Directors, employees and consultants must not make comments that may be construed to be representing the official view of ACI Global.
• Public Information: Any publicly available information we use (for example, in publications, memos, presentations or releases) must utilise the current form of that information located on our website or in our Product Disclosure Statements or which has otherwise been approved.
• Social media: Do not post material that is offensive, obscene, defamatory, threatening, harassing, bullying, discriminatory, hateful, racist, sexist, infringes copyright, or is otherwise unlawful on ACI Global’s social media sites or on your own personal sites. Do not imply that you are authorised to speak as a representative of ACI Global, nor give the impression that the views you express are those of ACI Global, unless you are authorised to do so.

Polictal Donations

ACI Global does not make political donations

ACI Global Responsibilities

We have a responsibility to our interested parties to deliver educational value through:

• The sustainable and efficient operation of ACI Global;
• Adoption and implementation of sound risk management processes; and
• Compliance with applicable laws and regulations. We have a responsibility to the community within which we work. We need to consider the impacts on our local and broader community when making business decisions.

This Policy has been acknowledged and accepted by the Managing Director for ACI Global Ian Erskine on the date below