Crown Melbourne Limited. Employee Code of Conduct

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Employee Code of Conduct

Crown Melbourne Limited

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employee code of conduct

Published December 2010

Foreword

Crown has built an enviable reputation as Australia’s leading Hospitality Company and employer. We promise to our stakeholders – our customers, our community, our government and our suppliers – that we will deliver all our services with the highest levels of integrity, quality, and creativity. This means that each of us, in all our workplace behaviours will act responsibly and represent the Crown brand proudly, as we serve our customers.

Upholding minimum legal and regulatory standards is not enough for a company such as Crown. We are also responsible for ensuring we adhere to an ethical Code of Conduct expected by our stakeholders and those bodies regulating our operations. This Code governs how we behave with those entities with which we have business contact, and each other. It supports integrity, trust, respect, fair play and teamwork – these being the standards by which Crown’s management and employees are measured. This Code of Conduct booklet explains the standards of behaviour expected for all our people. We are all required to read and become familiar with it, and act in accordance with the Code at all times.

This Code applies as a term of our contract of employment with Crown. It is important to be aware that if any of us breach this Code, we may be subject to disciplinary action, which may range from counselling to the termination of our employment.

The Crown Employee Code of Conduct serves to guide our behaviour as we continue to grow Crown’s business. We ask that in all our actions we demonstrate pride in Crown, in ourselves, and in those we work with, and that we live up to the standards and expectations that exemplify what it means to be part of the Crown team.

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If you believe that another person within Crown is breaching the expected standards of conduct, you should discuss that other person’s behaviour without risk or reprisal, with your immediate supervisor or communicate your concerns to your Business Unit Human Resources Manager or Executive General Manager.

If you would prefer to direct your concerns outside of your business area, you may confidentially raise any issues with the Executive General Manager - Human Resources, or via Stopline, a “whistleblower” organisation contracted by Crown.

Please note that all topics listed below are listed in alphabetical order – not in order of importance.

Appropriate Workplace Behaviour

In accordance with the law and under the “Appropriate Workplace Behaviour” Policy, Crown is committed to providing equal opportunity and to eliminating discrimination, harassment, bullying and other forms of unacceptable behaviour from the workplace.

Discrimination or harassment based on sex, race, colour, religion, age, marital status, disability, pregnancy, family responsibilities, sexual preference, political belief or activity, industrial activity, physical features or other prohibited grounds will not be tolerated.

Crown has a network of Contact Officers throughout the workplace. These officers are trained to provide advice to employees on how to handle any concerns of this nature.

Any breaches of the Policy should be reported to a supervisor or manager or to a Human Resources Manager. No one will be victimised for raising any concerns or for making a legitimate complaint relating to equal opportunity, discrimination, harassment or workplace bullying.

Introduction

It is a fundamental principle of Crown that all of our business affairs shall be conducted legally, ethically and with strict observance of the highest standards of integrity and professionalism. This Code of Conduct is based on this guiding principle and forms a fundamental term of your employment with Crown.

Why a Code of Conduct?

Our Code of Conduct sets the standards required of us all within Crown. It provides information to assist in the understanding of the ethical values and standards of behaviour that apply in all of our daily business activities. These are the values and standards on which Crown’s reputation will be based. Adherence to these values is fundamental to building a partnership of trust between Crown and its stakeholders.

To whom does the Code apply?

The Code applies to all of us. It is a condition of employment that you read and become familiar with and comply with the Code. Whilst not directly governed by the Code of Conduct, we also expect our contractors and suppliers to behave in a manner consistent with these principles.

What if the Code is breached?

This Code of Conduct is applicable to everyone and forms part of our induction, so that we know the standards required as part of Crown. It is therefore expected that the Code will not be breached. It sets down standards of behaviour which, if not observed, may result in disciplinary action. Such disciplinary action may range from counselling to termination of employment where there are persistent or serious breaches. The Code assumes that all relevant laws – Commonwealth and State – will be observed and upheld.

What if I am unsure?

If you are unsure of any aspect of this Code you should discuss the issues with your immediate supervisor. All employees are required to familiarise themselves with the Code and breaches will not be excused by alleged ignorance of the Code’s terms.

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Community Interests

Good relations with the community in which Crown resides and conducts business are essential. We are dedicated to delivering quality service and products, and partnering with various community organisations to improve the community of which we are a part.

Crown encourages all employees and contractors to participate in local activities that address needs of the communities in which they reside and work.

Company Assets

We all share responsibility for maintaining and protecting Crown property. Crown property includes any intellectual property (such as copyright materials, trademarks, trade secrets etc). Employees must not remove or destroy any Crown property, assets or services regardless of age or damage (unless authorised to do so). This includes using any company property, assets or services for personal gain or any other improper purpose. Employees agree to cooperate in any necessary searches to enforce this requirement. Crown’s property must not be given away, lent, destroyed or otherwise disposed of unless authorised in advance by the relevant manager in accordance with policy.

Compliance

A compliance culture with respect to industry (VCGR) regulations, legislation and self-imposed internal controls is required at Crown.

All employees are expected to act in accordance with compliance practices and procedures as a part of their employment.

Bribes

Employees must not solicit, encourage or accept any form of bribe from anyone, including a supplier, customer or fellow employee as an inducement for business, information or any other purpose.

Business Records

Employees must not destroy or alter in an unauthorised manner business documents and records that are required by law to be maintained for a statutory period, nor must any records be falsified or tampered with. This includes any records that are provided by an external party for business purposes and includes wage records, medical certificates and records in an electronic or other form.

Communication and Teamwork

We are committed to providing effective channels of communication among employees, contractors and management. Not only do open communications foster teamwork and facilitate a healthy working environment, but free and open channels promote the sharing and exchange of ideas and information and enable Crown as a whole to realise greater potential than the sum of its individual business units.

Employees should make it a habit to speak to their peers, subordinates and managers to share information and practices as appropriate and take advantage of the focus groups, information sessions and various other forums that are informative and fun to ensure that as a Company we benefit. Naturally, employees are expected to refrain from circulating or promoting rumours or other information that is negative or possibly inaccurate. Crown recognises there are some circumstances where confidentiality is essential in the best interests of the organisation. Where information is provided confidentially, employees must maintain confidentiality as appropriate and necessary (for example, in an equal opportunity complaint).

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If, however, a recognised law enforcement agency (e.g. Victoria Police, the Australian Federal Police or the Australian Crime Commission), an officer from the Victorian Commission for Gambling Regulation (VCGR) or other government or regulatory body lawfully approaches you for any of the above information you should refer them to your supervisor/manager or the Compliance Manager if it relates to the conduct of gaming or is otherwise required by law or to answer a claim against Crown. The obligation regarding confidential information will continue after the termination of your employment.

Conflict of Interest

A conflict of interest exists where loyalties are divided. As an example, a conflict of interest can arise where an employee holds an interest in a company or organisation, which may have business with or is in competition with Crown.

Employees are required to guard against any potential conflict of interest during employment by Crown.

It is impossible to outline all areas of potential conflict. To ensure that a conflict of interest does not arise, the following situations must be avoided: • Making, influencing or participating in Crown business decisions that

provide personal benefit or benefit to friends, family or associates; and • Involvement in any business activity or decision with relevance to Crown

that is fraudulent or corrupt or may be inconsistent with Crown’s activities. Employees are required to immediately inform Crown of any possible or potential conflict of interest for the purpose of eliminating or minimising the conflict. The onus is on all employees to disclose such information and non-disclosure is regarded as a serious breach of this Code.

Computer Technology

All employees will use Crown’s information technology systems and equipment in a lawful manner consistent with the employee’s employment terms and Crown’s policies and procedures. This includes, for example, a prohibition on using computer technology to carry or to access and/or download defamatory, obscene or offensive material, pornographic material or material of a sexual nature.

Confidential Information

During your employment at Crown, you will be exposed to business related information which must be treated confidentially. Any unauthorised use or disclosure of information or data relating to the conduct of Crown’s operations, including customers and employees, may adversely affect Crown’s reputation, legal obligations and your future at Crown. Neither during your employment, nor after its termination, will you disclose or use any confidential information except in the proper course of your duties. In particular it is of vital importance that details of a customer’s visit to Crown remain confidential and not be used in an unauthorised manner. This includes their identity and any gaming data (including amounts of money won and lost). Everyone’s cooperation is necessary to assure our customers that we are a professional organisation.

Examples of information that must remain confidential include, but are not limited to:

• Marketing plans

• Identities of representatives and other persons with whom Crown has a special business relationship or potential business relationship • Financial information such as business forecasts and budget projections • Financial data and analysis

• Details of actual or potential risks and problems

• Information concerning the identities and capabilities of employees or other personal details

• Other forms of confidential data, for example personal information of patrons, employee or customer lists and lists of excluded persons.

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Diversity

Crown is an Equal Opportunity Employer. As such Crown respects the diverse nature of its workforce and is committed to ensuring that all employees are given the opportunity to make the most of their talents and abilities. Crown’s intention is to help create an environment in which equity and diversity are recognised as being essential to the high performance of Crown and are incorporated into day to day business.

Drugs and Alcohol

While recognising that the responsible serving of alcohol to patrons is an integral part of many of Crown’s businesses, Crown seeks to establish and maintain for its employees an environment that is free from the effects of, and impairment arising from the use of, drugs and alcohol. This includes drugs of an illicit, prescription and over-the-counter nature.

In order to ensure a safe and enjoyable working environment, Crown prohibits the use by employees of alcohol and illicit substances during work, or at times when it will result in your work being affected or you or others’ safety being put at risk.

Crown has the right to refuse entry to any employee or contractor who is considered to be under the influence of alcohol or illegal drugs or impaired by other drugs.

Employee Grooming and Presentation Standards

Crown has published the grooming and presentation standards that are expected of employees. These standards should be adhered to at all times whilst on shift.

These grooming and presentation standards are put in place to ensure all employees display professional grooming, consistent with Crown’s five-star standard.

Environment

All employees should consider the impact of their activities on the

Customer Service

Employees will deliver quality customer service to our customers by conducting themselves with integrity and in a manner that ensures: • Our employees and customers are provided with our products and

services at the highest possible standards;

• All decisions and actions are evaluated in terms of their impact on customers;

• There is a safe and friendly environment at all times for our employees and customers; and

• All employees, customers and others are treated fairly and without discrimination or harassment.

Dealing with Suppliers

Employees who are required to deal with external suppliers of goods and services to Crown must avoid placing themselves in situations of a potential conflict of interest. Suppliers include, but are not restricted to, those from whom Crown purchases: merchandise or goods for sale; equipment; maintenance and construction services; and consultancies.

Where an employee has an existing financial interest in an actual or potential supplier to Crown, that interest must be declared to their immediate supervisor. The employee should take no part in any deliberations or decisions affecting that supplier. Where any doubt exists the principles to be considered are: • The capacity of the employee to influence dealings that Crown may have

with a third party;

• The improper personal benefit that may flow to the employee or a relative, friend or other third party through the exercise of that influence; or • Whether the activity is fraudulent, corrupt or is an irregular transaction. When an employee is dealing with a supplier in whom another employee (including a director) has an interest, the employee must ensure that he/she deals with that supplier on the same basis as Crown would with any other

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Non Licensed Employees

Employees who do not hold a Special Employee Licence issued by the VCGR are governed by the gifts, tips and gratuities policy. Non-licensed employees may only accept tips in line with the policy developed in the outlet, room or department in which they work. Employees have an obligation to fully disclose any tips they receive.

Health and Safety

Crown is committed to protecting the health and safety of the people who work with us, and the people who visit and use our facilities. This commitment is integral to the way we do business.

Crown has a Health and Safety Management System which outlines how we provide a safe work environment for our employees, contractors, patrons and visitors. It is expected that employees and contractors are familiar with CrownSAFE Procedures relevant to your area of work. These procedures can be found on the Crown Intranet and provide you with guidance as to how to perform your job safely and reduce Health and Safety risks as low as reasonably practicable.

In order to achieve our commitment of providing a healthy and safe work environment, Health and Safety is everyone’s responsibility. As such any breach of the expectations as outlined in the CrownSAFE Procedures may result in disciplinary action.

Insider Trading

Employees who may consider themselves to be in possession of share price sensitive information concerning publicly listed companies, including Crown Limited, must make themselves familiar with the legislation governing “insider trading” and related issues.

In relation to Crown Limited securities, employees who are aware of the likely results for a reporting period or other information that could be price sensitive must not trade in those securities before the results or information has been announced.

Ethical Standards

It is a fundamental principle of Crown that all of our business affairs shall be conducted legally, ethically and with strict observance of the highest standards of integrity and professionalism.

Employees concerned that unethical behaviour is taking place should report it to their Human Resources Manager or their Executive General Manager, or alternatively to the Executive General Manager – Human Resources or to “Stopline”.

Employees are protected from reprisals for reporting unethical behaviour or wrongdoing.

Gifts, Tips and Gratuities

Licensed Employees

The receipt of gifts, tips and gratuities is often part of normal business practice. In the case of Crown’s licensed employees, section 79A of the Casino Control Act 1991 provides that no person who holds a Special Employee License is permitted to receive a gift, tip, gratuity or benefit from a customer. If a gift, tip or gratuity is received due to unique circumstances, it must be promptly reported to your manager, and the item surrendered to the General Manager, Security for recording on the “Gifts, Tips and Gratuities Register”.

If you do not hold a Special Employee’s License you should refer to your departmental Human Resources policies and procedures.

In conjunction with these policies and procedures you should also adhere to the following:

• Do not accept any gift, tip or gratuity from any actual or potential customer, supplier or competitor of such value or nature under any circumstances that the donor expects to influence your business decisions, performance or your duties or that causes a conflict of interest. • Ensure that your supervisor or manager is informed immediately if a gift,

tip or gratuity is forwarded to you.

• Unsolicited promotional materials of little or nominal value such as pens, pencils, key rings, diaries are not gifts for the purpose of this Code of Conduct.

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Media Comment

Crown maintains a professional image by ensuring that any commentary to the media is truthful, honest and consistent. Accordingly, no officer or employee of Crown, with the exception of the Chief Executive Officer, Chairman and those with direct responsibility for media contact are authorised or permitted to make any comment (no matter how incidental or trivial) to media representatives regarding any activity or event associated with Crown, its employees or customers.

Misuse of Company Information

In addition to keeping Crown information confidential, employees must not use information obtained at Crown for their private business purposes. This includes information about Crown’s business systems and contracts, and information about business opportunities available at Crown.

Misuse of Employee Benefits

Crown provides its employees with many and varied exciting benefits and employees are expected not to abuse these benefits.

Personal Conduct

Much of our professional image and continued success at Crown depends on the manner in which we conduct ourselves. At all times we must be mindful of, and conduct ourselves, according to the following responsibilities: • Treat others with honesty, courtesy, equality and respect;

• Handle all customer contact professionally and courteously, in particular, it is unacceptable to improperly fraternise with customers;

• Respect and safeguard the property of Crown, its customers and fellow employees;

• Complete all jobs and tasks in a safe, responsible and effective manner; • Work within Crown’s policies and procedures and relevant legislation; • Reinforce Crown’s commitment to ensuring that the highest standards

Investments

Employees may own shares or other interests in any public or private company. In most cases these interests will not present a problem. However, employees should carefully assess the potential for a conflict of interest where they, their partners, or other relatives own shares or other interests in a company or firm that is a trade customer of, supplier to, or competitor of Crown.

If a potential conflict of interest appears to exist, then the facts of the matter should be disclosed to the employee’s immediate supervisor.

Leaving Crown

On leaving Crown each employee must return all Crown property, including documents, materials, software, keys, passes or any other Crown property or items containing confidential or business information, including any copies within your possession or control. This includes intellectual property that may have been created whilst working with Crown and any other property. The employee agrees that Crown may withhold any monies owing, including payment in lieu of any notice period not actually worked after resignation, from the employee’s salary and entitlements at termination.

Maintaining Outside Employment

Employees may engage in employment outside Crown. Employees must, however, disclose any outside employment or activities to their supervisor or manager to ensure those commitments are not in conflict with their employment at Crown.

Employees are advised not to engage in any outside employment that may in any way be inconsistent with their employment at Crown, or that may be inconsistent with the terms of their Special Employee’s License. For example, full-time and part-time employees are expected to ensure their employment with Crown takes precedence over any other employment they choose to maintain.

Management and supervisory employees must exercise discretion in engaging in outside employment, as these employees are expected to

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Surveillance

All Crown employees should be aware that, given the nature of its operations, Crown operates surveillance devices in and about the Casino Complex. In working at Crown, all employees and contractors acknowledge and consent to the lawful:

a) Audio, optical and other surveillance of your activities, including monitoring and recording your conversations; and

b) Use and disclosure by Crown of audio, optical and any other surveillance records of your activities for the purpose of Crown performing its functions or as otherwise required by law.

When you are a Customer

Crown wants its employees to use the Crown entertainment facilities. Subject to your strict adherence to the guidelines below, you are not required to obtain permission for a private visit; however it is a requirement that you advise your immediate supervisor or manager prior to entering gaming areas of the complex before or after your shift or while on an RDO or leave.

These guidelines are designed to make this possible with maximum convenience and minimum difficulties. They apply to all employees. • You are not to gamble at any facility within the complex.

• Your behaviour generally should never diminish the experience of any other customer, nor the reputation or business prospects of Crown. • Do not wear your costumes or any Crown identification.

• Do not drink alcohol if you are commencing a shift soon after a private visit (as a guide, you should not consume any alcohol within eight hours prior to the commencement of your next shift).

• Confine yourself to customer areas – stay away from areas to which you have access only when working, including the

staff restaurant.

Photo Identification

You must wear your ID badge on the left side of your jacket or shirt/blouse in full view of the public or other staff and free from any stickers or labels, whenever working or training on Crown premises.

Employees who are issued with a gold badge may wear this as an alternative to the ID badge.

Professional Conduct

We are committed to having our employees develop and advance professionally in a manner consistent with their abilities. Although difficult decisions may arise in hiring, evaluating performance, promoting, disciplining or terminating employees, Crown expects such responsibilities to be carried out with fairness, discretion and respect for privacy, as well as compassion for the individuals concerned.

Public Appearances

In accordance with the policy on public appearance, consistency must also be maintained in the course of public speaking engagements on behalf of Crown.

Any request for an appearance for or on behalf of Crown or any invitation for a speaking engagement must be approved by the Executive General Manager – Human Resources, Chief Operating Officer, Chief Financial Officer or Chief Executive Officer.

Special Employee’s Licence

All Crown employees who hold a Special Employee’s Licence issued by the VCGR have a responsibility to maintain and uphold the provisions and conditions of the licence.

You are required to regularly make yourself familiar with the current provisions and conditions of the licence.

Any material change in your circumstances (including your home address) or any inquiries relating to the Special Employee’s Licence should be directed to the Compliance Department.

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• If you are accompanying people who are gambling, you are not to use your knowledge or influence to assist in the play of a game, nor must it appear that you are doing so. Stand back from the game and do not pass money to those gambling.

• If you will be staying at a Crown hotel as a guest or if you are booking a room on behalf of family or friends, you must identify yourself as an employee of Crown upon the making of a reservation and upon check-in.

• Let working employees provide quality service to customers – don’t get involved with or distract other employees while they’re working. • You must not solicit complimentary privileges from other employees

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Crown Melbourne Limited. Employee Code of Conduct

Employee Code of Conduct

Crown Melbourne Limited

employee code of conduct

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