• Undertake your duties with care and diligence. Remember, you are accountable for the decisions you make and the actions you take.
• Deal fairly and honestly with all Chifley Securities’ customers, suppliers, competitors and any other third parties or business partners.
• Only provide advice to customers that you are authorised to provide in the course of your work. For example, you must not provide legal or tax advice or financial advice where Chifley Securities has not authorised you or you are not qualified to do so.
• Help protect Chifley Securities and its customers against potential theft or fraud.
• Help protect Chifley Securities from being associated with money laundering or terrorist financing, or from transacting with countries, entities or individuals who are subject to economic sanctions. This includes being alert to suspicious customer behavior and reporting suspicious activity.
• Exercise your authorities, including your credit discretion, expenditure commitment and payment discretions and corporate credit card funds, responsibly and within their limits.
• You are responsible for understanding your authorities, including any relevant limits, and are accountable for how they are used.
• Behave in a way that takes into account our impact on the broader community and the environment in both the short and long term.
• Use all of Chifley Securities systems appropriately and for proper purposes. This includes email, messaging, internet access, and technology and cloud systems.
• Never entertain customers or clients or participate in Chifley Securities’ activities or functions in a way that may damage Chifley Securities’ reputation, for example by consuming excessive alcohol.

• Honesty and integrity are essential to everything we do at Chifley Securities.
• Our success depends on the trust of our customers, which is earned by acting with honesty and integrity and by considering Chifley Securities, 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 Chifley Securities’ reputation for honesty and integrity as well.

WHAT YOU MUST DO:

• Immediately report any suspicions of fraud, tax evasion, theft or other dishonest behaviour by others (including colleagues or customers).
• Never improperly use your position with Chifley Securities or any information you receive through your work at Chifley Securities to further your own personal interests, or help others to do so.
• Never help a customer or anyone else to break or evade the law.
• Consider the interests and needs of the customer when providing advice, products or services to them.
• Be honest and forthright in all of your communications and dealings with Chifley Securities including with your line manager, colleagues, customers, auditors and regulators. This includes communications and dealings as a customer, as well as someone who works with Chifley Securities.
• Ensure all dealings (such as transactions or commitments) with customers, suppliers or third parties are properly recorded and transparent.
• Use Chifley Securities’ assets and funds (including corporate credit cards) for proper purposes and keep accurate and transparent records of all payments or receipts for transactions using Chifley Securities’ funds.
• Never structure or amend any transaction to disguise, conceal or misrepresent the involvement of any party or the true nature of the transaction (for example, to conceal money laundering or the involvement of sanctioned countries, entities or individuals).

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

WHAT YOU MUST DO:

• Treat all people you deal with through your work at Chifley Securities with dignity and respect.
• Make employment decisions based on merit, and not on attributes that are irrelevant to employment or performance.
• Never unlawfully discriminate, harass or bully your colleagues, customers, Chifley Securities’ visitors or anyone else in the workplace.
• This includes being aware that some behaviour may be acceptable to you but not to others, and acting appropriately.
• Contribute to promoting a safe working environment by taking responsibility for health and safety and reporting any issues as soon as possible.
• Never treat somebody less favorably because they have brought or propose to bring a genuine complaint of unacceptable behavior.

• 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 Chifley Securities or our customers.
• The perception of a conflict of interest can do as much damage to Chifley Securities’ 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.

WHAT YOU MUST DO:

• Be alert to actual or potential conflicts of interest and disclose them to your line manager, human resources representative or your operating risk and compliance representative.
• Never trade in securities if you have information that may affect the price of the security and this information is not publicly known or generally available.
• Seek approval for any outside business interest including non- Chifley Securities work (paid or unpaid), business ventures, directorships, partnerships or a direct or indirect financial interest which has the potential to be in conflict with your employment, the interests of Chifley Securities or Chifley Securities’ partners, customers or suppliers.
• Keep an arm’s length relationship when dealing with customers or suppliers and obtain written approval of Chifley Securities to do business, hold accounts, transact with or hold a direct or indirect financial interest in customers or suppliers you deal with in the course of your work with Chifley Securities.
• Never provide or maintain products or services for, or complete or approve transactions on behalf of, immediate family members or relatives in the course of your work.
• Disclose to your line manager any personal associations with a third party that you are involved in evaluating or negotiating with for Chifley Securities, whether for employment, as a customer or supplier or any other reason.

• In your work at Chifley Securities, you may come across private and confidential information relating to Chifley Securities, colleagues, customers, suppliers or other third parties.
• When people provide us with this type of information they are trusting Chifley Securities.
• Misuse of confidential and private information can have severe commercial and reputational consequences for Chifley Securities 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.
• Chifley Securities is committed to maintaining the confidentiality and security of this information and you are expected to do your part to help honour this commitment.

WHAT YOU MUST DO:

• Do all you can to keep information secure.
• This includes not sharing private or confidential information with other persons unless they need it to perform their work at Chifley Securities.
• Never release information about customers or colleagues to third parties outside of Chifley Securities unless the person the information relates to has agreed or if Chifley Securities is required to release the information under the law.
• This includes not giving any information to family members, friends or others about an account to which they are not a signatory.
• Follow procedures and requirements to protect information whenever you provide details over the phone, by email or fax.
• Follow all protocols and procedures relating to the maintenance of passwords and user profile setup. Never allow someone else to log on using your individual details.
• Collect, use, store, handle, update and destroy information, particularly personal information, in line with applicable policies and processes at all times.
• Never disclose any information about Chifley Securities or any other company or individual (including a former employer) that is not already in the public domain without the proper authority to do so.

• 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.

WHAT YOU MUST DO:

• Never accept any gift, reward or entertainment, including discounted products, free travel or accommodation, if it could create any obligation or expectation that could conflict with your work at Chifley Securities.
• Never try to improperly influence the outcome of an official decision, for example by offering a payment or benefit that is not legitimately due. These payments or benefits are unacceptable.
• Only accept gifts or entertainment in line with applicable policies and processes.
• Never make any donation or other financial contribution from Chifley Securities to a political party or candidate unless it has been approved by the Chifley Securities CEO and the Chifley Securities Board.
• Only entertain customers and business associates with lunches, dinners or other events (such as football, cricket or the theatre) if the nature and value of the entertainment is reasonable in light of the nature and value of the business relationship with Chifley Securities and the seniority of the parties attending.
• Obtain proper approval for and properly record any donations, sponsorships, charitable contributions, gifts and entertainment you accept from, or give to, a third party on behalf of Chifley Securities.

• 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 Chifley Securities 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.
• Chifley Securities 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 Chifley Securities’ policies, procedures and practices take into account not only the strict letter of the law but also the Chifley Securities way of doing things. In many cases, the standards expected by Chifley Securities exceed those required by law.
• Wherever there is an inconsistency between an applicable law and this Code, an Chifley Securities policy, procedure or practice, you must comply with whichever is the higher standard.

WHAT YOU MUST DO:

• Not take any action, or fail to take any action, that may breach this Code, the law, Chifley Securities policies, procedures or practices.
• Complete all required training and education programs to build and maintain your awareness and understanding of relevant laws, policies, procedures and practices.
• If you are unsure whether a particular law, policy, procedure or practice applies, seek guidance from your supervisor, line manager, human resources representative or operating risk and compliance representative.

• As someone working with Chifley Securities, 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 Chifley Securities policies or procedures as soon as you can.
• 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.