Code of Conduct
1. Purpose
This purpose of this Code of Conduct is to provide direction to employees, suppliers and landlords of Community Housing Corner Pty Ltd (CHC) on how to uphold the highest ethical standards, values and principles when carrying out their roles.
The Code provides clear guidance on the values CHC upholds in its work and the conduct expected when those values are applied.
2. Policy Statement
By maintaining the highest standards of practice and performance, CHC’s professional reputation is maintained and our values as an ethical, transparent and accountable community housing company are strengthened
3. Policy Principles
The ethical standards applied by CHC management and employees when implementing this Code of Conduct are:
Integrity
- We are truthful and principled in our dealings with tenants, stakeholders and each other
- We declare any conflict of interest which may have an impact on our obligation to act honestly and impartially as CHC employees.
- We comply with all Federal, State and Municipal laws and regulations, particularly those applicable to the provision and management of community housing – any breaches of law will be reported to the appropriate authority and the National Regulatory System for Community Housing (NRSCH) will be notified.
Respect
- We respect the privacy and confidentiality of people’s personal information and observe our legal and ethical obligations to protect the privacy of both tenants and employees during the collection, use, disclosure and storage of their personal information
- We display tolerance, acceptance, sensitivity and courtesy
- We acknowledge the vulnerability of some eligible tenants and respect their right to receive additional support relevant to their situation and to be represented by advocates if they request such support
- We respect and encourage diversity in our workforce and among our tenants. We do not tolerate discrimination in any form.
Accountability
- CHC employees and contractors accept responsibility for all their actions as representatives of CHC
- CHC employees or contractors will report any suspected fraudulent or unethical conduct to either CHC Management if the fraud relates to another employee or NRSCH if they believe management has acted fraudulently or behaved unethically.
- Any employee reporting suspected fraudulent or unethical conduct is protected from retaliation of any kind – see CHC Whistleblower Policy and Procedures.
Professionalism
- Through the positive leadership of its management team, CHC aims to enhance its reputation as a professional community housing manager.
- We encourage CHC employees to pursue best practice in the way they present themselves and to strive for continuous improvement in their work
- CHC provides a safe and challenging workplace where employees are supported to contribute as valuable members of a team.
Procedures
4. Roles & Responsibilities
APPLYING THE CODE TO THE WAY CHC OPERATES
Integrity
- CHC employees will be made aware at Induction that CHC is bound by legislative responsibilities, including laws and regulations which specifically relate to Community Housing Providers. Employees must familiarise themselves with any legal requirements which expressly relate to their position.
- CHC employees will not, after a tenancy agreement is executed, change its conditions.
- CHC will ensure that its promotional materials are not false, misleading or likely to deceive.
- CHC employees will not accept benefits or gifts which may be construed as bribes or which may impact on their capacity to act impartially or ethically.
- CHC employees who participate in political activities outside of work hours must ensure this involvement does not conflict with their responsibility to carry out their CHC duties in a politically neutral manner.
- CHC employees should familiarise themselves with the CHC Fraud and Corruption Prevention Policy and therefore be aware that fraud, theft or corruption will not be tolerated.
- Any employee who suspects fraud, theft or corruption should familiarise themselves with the CHC Whistleblower Protection Policy and Procedures and promptly report any suspicions.
Respect
- CHC employees and contractors will never subject tenants to harassment, intimidation or coercion.
- CHC employees and contractors respect the right of tenants to lodge complaints in line with the provisions set out in the Complaints and Appeals Handling section of the CHC Tenant Information Handbook.
- In ensuring that tenants’ privacy and confidentiality is respected, CHC employees are conversant and compliant with the requirements of privacy legislation, the 13 Australian Privacy Principles, and the privacy requirements detailed in this Code of Conduct.Respect for tenants’ privacy and confidentiality means CHC employs strict security safeguards for protecting both online and hard copy information.
- Hard copy documents containing personal information about tenants are placed in locked storage when not in use
- CHC employees do not share their passwords with each other, unless authorised by management
- CHC employees should log off or employ screensaver when leaving their computer unattended
- Personal information about tenants is never shared with anyone other than CHC colleagues or law enforcement officers who can provide legitimate evidence of need for the information
- In ensuring that our employees’ privacy and confidentiality is protected, we collect only that information which is necessary to run employment referee checks, properly conduct a community housing company and manage CHC properties:
- We do not disclose employees’ personal or health information for any other purpose without their prior knowledge
- Employees have the right to access their personal and health information kept by CHC and to request correction of any errors after providing supporting evidence.
- CHC employees will respect the confidentiality of the organisation’s operational and financial information which they were party to, both during and after their employment
- CHC management and employees treat each other with respect, fairness and equity adhering to the requirements of anti-discrimination legislation
- Bullying, intimidation or harassment of CHC colleagues will not be tolerated.
Accountability
- CHC adheres to those ASX Corporate Governance principles as they may apply to non-listed entities
- CHC manages its finances and other resources with careful oversight and within a strict legal and ethical framework. Our processes and financial records are subject to external auditing.
- CHC will, when asked, willingly provide the name and contact details of the person responsible for handling complaints about its work or an employee – usually the Property Manager.
- CHC is fair, transparent and responsive in managing complaints it receives. Any complaints received by CHC are initially dealt with and hopefully resolved by CHC itself. If resolution is not possible, tenants will be referred to the Complaint and Appeals Handling section of the CHC Tenant Information Handbook for next steps.If the complaint has been lodged by a neighbour or a related party and CHC is unable to resolve it, the complainant will be provided with a copy of the NRSCH Factsheet – Complaint Handling – Information for neighbours and related parties, July 2016 so that they can take next steps.
Professionalism
- CHC ensures that all new employees commencing work at the Company commit to complying with this Code of Conduct when they sign their Letter of Offer. Breaches of the Code may result in disciplinary action.
- Training opportunities are provided to CHC employees so that they can enhance their professionalism and excel in their roles.
- CHC is committed to presenting a professional image to tenants and stakeholders. Employees must therefore be well presented – clean and neat – in order to comply with this commitment.If provided with a uniform, it should be maintained in a clean and undamaged condition. If there are Work Health Safety requirements in relation to work attire (for example, specific types of boots), the requirements must be fulfilled.
- CHC employees must not present for work under the influence of alcohol or illegal drugs or bring alcohol or illegal drugs into the workplace or to community housing properties.
- CHC employees who smoke tobacco must not do so on CHC premises or in a vehicle owned or leased by CHC.
- CHC employees must exercise care and responsibility both during and after work hours to ensure that any information, casual comment or actions taken by them do not reveal any private or confidential information, contravene this Code of Conduct, misrepresent or cause reputational damage to CHC or its stakeholders. This includes information conveyed through social and/or other media.
- Intellectual property developed by an employee during or as a result of their employment at CHC is the sole property of CHC unless governed by law or agreed otherwise in writing by CHC.
5. Definitions
Term | Definition |
Bullying | Is repeated, unreasonable behaviour that could reasonably considered to be humiliating, intimidating, threatening or demeaning to a person, which creates a risk to health and safety |
Discrimination | When a person is treated unfavourably because of a particular legally protected (C’Wealth & NSW law) attribute e.g. sex, marital status, pregnancy, parental or carer status, breastfeeding, age, colour, race, nationality, ethnicity, disability, sexual orientation, transgender status, religion, criminal record, medical history, trade union activity, political opinion. |
Employee | Any employee of CHC, including contractors, sub-contractors, trainees |
Fraud | The intentional use of false representations or deception to avoid an obligation, or gain an unjust advantage, personal or financial |
Harassment | Repeated behaviour by an individual that is directed at an individual or group of individuals; and is offensive, intimidating, humiliating, or threatening; and is unwelcome and unsolicited; and a reasonable person would consider being offensive, intimidating, humiliating, or threatening for the individual or group in all the circumstances |
Interest | A term used in relation to declaring personal interests or conflicts of interest. The term ‘interest’ means direct or indirect personal interests. Interests may be pecuniary (financial or economic forms of advantage) or non-pecuniary (non-financial forms of advantage) |
Personal Information | Personal information identifies a person and includes: name; date of birth; occupation; email and postal addresses; telephone numbers; Medicare and health insurance details; emergency contact details; signature |
6. Related legislation and documentation
Legislation
- NSW Residential Tenancies Act 2010
- NSW Community Housing Providers (Adoption of National Law) Act 2012
- Privacy Act 1988 (C’wealth)
- Australian Privacy Principles (C’wealth)
- Privacy and Personal Information Protection Act 1998 (NSW)
- Corporations Act 2001, including the Act’s Whistleblower protections
Government Policy
- The National Regulatory Code for the National Regulatory System for Community Housing (NRSCH)
- NRSCH Provider Notification to the Registrar Guidelines – February 2016
- NSW Affordable Housing Ministerial Guidelines