ACN 609 323 257

Code of Conduct

1. Commitment to values and the code of conduct

1.1 This Code of Conduct reflects our Company values and our high standards of professional conduct and ethics in dealing with all of our stakeholders and our commitment to complying with all applicable state, national and international laws.

1.2 The Company endeavours to be recognised as an organisation committed to the highest ethical standards in business.  

1.3 This Code applies to the Company’s Personnel.

1.4 The Company is firmly committed to compliance with the Code.  Any action contrary to the Code will be treated very seriously.

1.5 The Company will periodically review and update the Code.

2. Integrity and professionalism

2.1 All Personnel are expected to act honestly and with integrity in all of their dealings for the Company.

2.2 The highest levels of professional conduct are expected in interactions with colleagues, business partners and in representing the Company in the community.

2.3 All conduct on behalf of the Company is expected to be truthful, not misleading, not involve false statements nor mislead by omission.  Promises or commitments that the Company does not intend, or would be unable, to honour should not be made.

3. Responsibilities to shareholders and the financial community

3.1 In addition to this Code, the Company complies with all provisions of its Constitution, the Corporations Act 2001 and all other applicable rules and legislation.


3.2 The Company wishes to have a positive relationship with its shareholders and will always attempt to respond to their inquiries and requests as quickly as possible.

3.3 The Company is committed to delivering value for shareholders and exerts its best efforts to maximise shareholder benefits.

3.4 The Company treats all shareholders equally.


3.5 The Company values communication with its shareholders, other stakeholders and the public at large, and will fulfil its duty to make full, fair and timely disclosure of relevant information to shareholders.

3.6 Personnel should not make public statements about the Company unless authorised by the CEO or a Director.

4. Employment practices

Equal opportunity and diversity

4.1 The Company is an equal opportunity employer.  This means that the Company does not discriminate on the basis of racial origin, gender, age, ethnicity, marital status, disability, religious or philosophical beliefs, sexual preference or political affiliation.  The Company considers allegations of harassment and unlawful discrimination as extremely serious and will take appropriate action.

4.2 The Company promotes and supports a diverse workforce at all levels of the Company.  It is our belief that creating a work environment that enables us to attract, retain, and fully engage diverse talents leads to enhanced innovation and creativity in our products and services.

Health and safety

4.3 The Company strives to protect the physical and emotional health of all Personnel in the workplace.

Training and potential

4.4 The Company believes in enabling Personnel to develop to the extent of their full capabilities.  

Drug and alcohol use

4.5 Personnel should not be under the influence of drugs or alcohol in any situation where they are identifiable in relation to the Company or at any time in the course of their employment or employment-related activities.

4.6 Smoking is not permitted in the workplace.


4.7 Personnel must exercise extreme care when giving or receiving business-related gifts and should comply with the Company’s Anti-Bribery and Corruption Policy at all times.

5. Conduct of business

Use of Company funds and resources

5.1 Personnel must not use Company funds, property, equipment or other resources for personal benefit.

5.2 Personnel should use Company funds sensibly and effectively.  Personnel must report expenditures accurately.  The Company will treat submission of a fraudulent expense report as serious misconduct.


5.3 Personnel are required to protect proprietary, commercial and other information that is confidential to the Company and its customers.  Obligations of confidentiality continue after an individual’s employment or contract of service with the Company ends.

5.4 Information that is not publicly available concerning the activities, results or plans of the Company must only be used for authorised purposes.

Conflicts of interest

5.5 Personnel are expected to act at all times in the Company’s best interests and to exercise sound judgment unclouded by personal interests or divided loyalties.

5.6 Personnel must avoid the appearance of, as well as actual, conflicts of interest in both in their performance of duties for the Company and in their outside activities.

5.7 Personnel must disclose any material personal interests or other actual or potential conflicts of interest in accordance with the law and in the interests of full transparency.

Fair trading and dealing

5.8 The Company is committed to fair competition and trading in all markets in which it operates.

5.9 Personnel should treat customers, business allies and suppliers fairly and will not engage in anti-competitive practices that unlawfully restrict the free market economy.  The Company is therefore firmly committed to upholding all applicable anti-trust or competition laws and regulations.

5.10 Discussions with competitors regarding potential anti-competitive behaviour is a violation of Company policy and will subject the individual to disciplinary action as well as the potential for criminal prosecution.


5.11 The Company's objective is to compete in the marketplace on the basis of superior products, services and competitive prices. Personnel must at all times comply with the Company’s Anti-Bribery and Corruption Policy.

6. Responsibilities to the community

Environmental protection

6.1 The Company respects the environment and protects natural resources.  

Human rights

6.2 We support human rights consistent with the Universal Declaration of Human Rights and the Company respects those rights in conducting the Company’s operations around the world. Specifically, the Company does not tolerate any practices involving the use of slavery, servitude, inhuman or degrading treatment or punishment, forced or compulsory labour or human trafficking.

Political involvement

6.3 The Company does not directly or indirectly participate in party politics.  The Company does not make payments to political parties or individual politicians in any country.

7. International compliance

7.1 Where the Company operates outside of Australia, the Company will comply with all applicable local and international laws and regulations.  Personnel are expected to know and follow the laws of the relevant market where the Company operates.

8. Observance of the Code

8.1 It is the responsibility of all Personnel to promote the Code.

8.2 Breaches of the Code should be reported to the Chief Executive Officer or the Chair of the Board, and they will take any action that is considered appropriate in the circumstances.

8.3 The Company will not permit any form of retribution against any person, who, in good faith, reports known or suspected violations of the Code or any other Company policy.

9. Definitions

In this this Code the following meanings apply:

(1) Board means the board of directors of the Company;

(2) Code means this Code of Conduct as approved by the Board;

(3) Company means Kyckr Pty Limited ACN 609 323 257 and, where the context requires it, all or any of its subsidiaries;

(4) Director means a director of the Board of the Company;

(5) Personnel means Directors, Senior Executives, officers, employees, contractors and any temporary staff;

(6) Secretary means the company secretary appointed by the Board; and

(7) Senior Executives refers to the senior management team as distinct from the Board, being those individuals who have the opportunity to materially influence the integrity, strategy and operation of the Company and its financial performance and includes, as the context requires, any executive directors, the CEO, the CFO and other persons as determined by the Board from time to time.  A list of those considered to be Senior Executives will be agreed by the Board periodically.  

Approved by the Board - 25 January 2023