Heron Island Resort – General Policy

Code of Conduct

This Code of Conduct (the “Code”) is intended to provide a general statement of the high
ethical standards that each director, officer and employee should adhere to while acting on
behalf of Aldesta Heron Island Resort Pty Ltd (Heron Island), its directly and indirectly owned
subsidiaries and affiliates, and each of their operating divisions and units.

POLICY
All employees shall comply with all laws, rules and regulations that are applicable to Aldesta
Heron Island Resort Pty Ltd (Heron Island)’s activities. Aldesta Heron Island Resort Pty Ltd (Heron
Island) may from time to time provide training and information to promote awareness of various
laws, rules and regulations. It is, however, the responsibility of all employees to ensure that they
are informed and comply with all laws applicable to their activities on behalf of Aldesta Heron
Island Resort Pty Ltd (Heron Island). Additionally, all employees should abide by this Code and
ensure that it is adhered to in their dealings with other employees and with suppliers, vendors,
business partners, customers and agents of Aldesta Heron Island Resort Pty Ltd (Heron Island).

Employees must also be familiar with, and abide by, all applicable corporate policies which are
incorporated into handbooks and work rules and regulations.

Conflicts of Interest
No employee is to misuse their position with Aldesta Heron Island Resort Pty Ltd (Heron Island) or
their knowledge of Company affairs to obtain personal gain, whether directly or indirectly. This
would include behaviour such as, but is not limited to:
 Having an interest in, or relationship with, an organization or individual doing or seeking to
do business with Aldesta Heron Island Resort Pty Ltd (Heron Island) where such interest or
relationship has the potential to interfere with your duty of loyalty to Aldesta Heron Island
Resort Pty Ltd (Heron Island).
 Having an outside business or engaging in employment that interferes or adversely impacts
the employee’s obligations to Aldesta Heron Island Resort Pty Ltd (Heron Island)/render any
managerial, consulting or similar service to any organisation which does business with or is a
competitor of Aldesta Heron Island Resort Pty Ltd (Heron Island).
 Using for one’s own benefit, directly or indirectly, or revealing to any third party any
confidential information regarding Aldesta Heron Island Resort Pty Ltd (Heron Island).
 Using or permitting others to use the service of the employees or Company materials or
equipment for personal use or gain.
 Breaching specific Aldesta Heron Island Resort Pty Ltd (Heron Island) policies relating to gifts
and gratuities and close personal relationships between employees in line of authority.

All potential conflicts of interest should be disclosed to the General Manager in writing.
Relevant action should then be taken to manage or further report the conflict to more senior
management.
Confidentiality
Employees must maintain the confidentiality of all confidential information entrusted to them by
Aldesta Heron Island Resort Pty Ltd (Heron Island) or its customers or suppliers, except where
disclosure may be required by law. Confidential information includes all non-public information
that might be of use to competitors or harmful to Aldesta Heron Island Resort Pty Ltd (Heron
Island) or its customers or suppliers if disclosed. This includes, without limitation, financial
information, or information regarding potential bids or acquisitions, as well as client and
customer information and information relating to Aldesta Heron Island Resort Pty Ltd (Heron
Island)’s pricing, products and services. Confidential information must be held in strictest
confidence, and must not be used in any way other than as required in performing
employment duties.

Disclosure of confidential information to any internal or external source, including without

limitation, media, former employees, suppliers or others is strictly prohibited. To avoid
inadvertent disclosure of confidential information, employees shall not discuss confidential
information with or in the presence of any unauthorised persons, including without limitation
employees of other companies operating within a shared facility, family members and friends.
Additionally, confidential information should be disseminated within Aldesta Heron Island Resort
Pty Ltd (Heron Island) on a need to know basis.

The obligation to preserve confidential information continues even after employment with
Aldesta Heron Island Resort Pty Ltd (Heron Island) ends.

Accounting Practices
The maintenance of accurate books and records is fundamental to the protection of the
business of Aldesta Heron Island Resort Pty Ltd (Heron Island), its shareholders and creditors, and
Aldesta Heron Island Resort Pty Ltd (Heron Island)’s relationships with:
 governmental agencies,
 its suppliers,
 customers, and
 clients,
 as well as prospective purchasers of Aldesta Heron Island Resort Pty Ltd (Heron Island)’s
assets.

Accordingly, Aldesta Heron Island Resort Pty Ltd (Heron Island)’s books and records are to be
kept in accordance with generally accepted accounting principles, and with established
finance and accounting policies. All employees are expected to adhere to Aldesta Heron
Island Resort Pty Ltd (Heron Island)’s Accounting Practices Policy, which contains detailed
internal accounting controls and procedures. Additionally, all employees shall cooperate fully
with internal and outside auditors during their examination of Aldesta Heron Island Resort Pty Ltd
(Heron Island)’s books, records and operations.

Company Entertainment
Gifts, favours and entertainment may be provided at Aldesta Heron Island Resort Pty Ltd (Heron
Island)’s expense only if they are consistent with Aldesta Heron Island Resort Pty Ltd (Heron
Island)’s policy. Any such expenses shall be of sufficiently reasonable and limited value and in
a form that could not be construed as a bribe, payoff, kickback, illegal political contribution, or
other illegal or unethical payment. All employees shall ensure that such entertainment is not in
contravention of applicable law or generally accepted ethical standards, and that public
disclosure of the circumstances surrounding any gift, favour or entertainment would not
embarrass Aldesta Heron Island Resort Pty Ltd (Heron Island) or the recipient thereof.
Anti-Harassment
Aldesta Heron Island Resort Pty Ltd (Heron Island) is committed to maintaining a productive
work climate that is free of harassment. Harassment of any kind by management or co-workers
at any level will not be tolerated. In addition, Aldesta Heron Island Resort Pty Ltd (Heron Island)
will seek to protect employees, to the extent possible, from reported harassment in the
workplace by non-employees.

Employees must act in accordance with Aldesta Heron Island Resort Pty Ltd (Heron Island)’s
Respect and diversity in the workplace policy, which details prohibited forms of harassment,
including sexual harassment and prohibits retaliation against employees exercising their rights
under the policy. The Respect and diversity Policy also outlines the procedure for reporting
harassment.

Any employee who is aware of harassment prohibited by Aldesta Heron Island Resort Pty Ltd
(Heron Island)’s Respect and diversity policy is required to report it.

Management and Supervisory Employees

All employees with supervisory responsibility are accountable for the activities of their
subordinates in the course of their employment with Aldesta Heron Island Resort Pty Ltd (Heron
Island). All employees with supervisory responsibility have a duty to ensure that the activities of
their subordinates are conducted in compliance with all applicable laws, rules, regulations and
this Code, and will face disciplinary action for failing to do so.

Other Acceptable/Unacceptable Behaviour

The purpose of this section of the Code is to ensure that acceptable standards of conduct and
work performance are clear within Aldesta Heron Island Resort Pty Ltd (Heron Island) and to
ensure that individuals are treated in a consistent and fair manner.

General community and common law standards of behaviour will generally apply, in
conjunction with the following indicative examples:

(a) Acceptable Behaviours

It is expected that all employees will demonstrate the following behaviours at work:

 Carry out work in a conscientious and proficient manner and to a standard acceptable
to Aldesta Heron Island Resort Pty Ltd (Heron Island);
o Present for work punctually and appropriately dressed (as per Aldesta Heron
Island Resort Pty Ltd (Heron Island)’s grooming standards);
o Treat fellow employees, contractors and visitors in a co-operative, fair, dignified,
professional and open manner, consistent with the principles of fair treatment and
non-discrimination;
o Comply with all proper and safe instructions from immediate supervisor, manager
and other Company officials;
  Comply with all Company Policies and Procedures and relevant statutory regulations;
o Ask their immediate supervisor or manager if they are unsure of a course of action
they are about to take;
o Provide efficient service and prompt attention to customers, visitor’s etc.;
o Ensure the health, safety and welfare of employees, customers and themselves is
not endangered;
o Immediately report any damage to property, incidents, near misses, or accidents
to their immediate supervisor.

(b) Unacceptable Behaviours

The following behaviours are indicative of what is not acceptable:

 Interference with any other employee to the detriment of that employee’s safety and/or
performance of their duties;
 Carelessness;
 Negligence;
 Dishonesty;
 Excessive absenteeism from work, tardiness or poor time keeping, including lack of
proper advance notification;
 Unauthorised absence from the workplace;
 Excessive breaks;
 Repeated failure to achieve acceptable standards of work performance in respect to
quality, quantity and timeliness;
 Loitering around a site 20 minutes or less prior to the commencement or after the
rostered shift ends. Loitering at other outlets during rostered breaks or rostered days off is
also forbidden;
 Failure to observe safety rules and procedures or working or acting in an unsafe manner;
 Failure to report an accident;
 Food Safety/Sanitation violations;
 Misuse or damage to Aldesta Heron Island Resort Pty Ltd (Heron Island)’s property;
 Leaving the place of work without proper authority;
 Reporting to work in a manner which gives the manager reasonable grounds to believe
that the employee is unable to perform their usual duties properly;
 Failure to wear Company approved clothing or failure to use appropriate supplied safety
equipment;
 Sleeping on Company premises during recognised working hours;
 Utilising Company time or equipment for private or personal use unless authorised;
 Giving away Aldesta Heron Island Resort Pty Ltd (Heron Island)’s product;
 Working of overtime without management's approval;
 Lack of professionalism or other conduct that adversely affects the workplace;
 Breach of Aldesta Heron Island Resort Pty Ltd (Heron Island)’s policies and procedures.

(c) Serious Misconduct

While not an exhaustive list, the following are examples of serious misconduct:

 Unauthorised possession or removal of any property or material belonging to Aldesta

Heron Island Resort Pty Ltd (Heron Island), a client or another employee;
 Theft of Aldesta Heron Island Resort Pty Ltd (Heron Island)’s funds or property, including
documentation, intellectual property and other materials;
 Wilful or criminal damage to and/or misuse of Aldesta Heron Island Resort Pty Ltd (Heron
Island)’s property or gross negligence resulting in damage or loss to Aldesta Heron Island
Resort Pty Ltd (Heron Island);
 Deliberate failure to follow appropriate Aldesta Heron Island Resort Pty Ltd (Heron Island)
cash handling procedures relating to handling cash and cash registers;
 Falsification of Aldesta Heron Island Resort Pty Ltd (Heron Island) records or time sheets /
attendance records/training records/medical records or any other records that would
result in payment or other benefits to which an employee is not entitled. This includes
signing in a co-workers’ time sheet/employee ID card or the misuse of identification
cards;
 Failing to obey a lawful and reasonable instruction issued by a supervisor or refusal to
perform work which is neither unsafe nor illegal and which an employee might
reasonably be expected to do;
 Possession, sale or manufacture of illegal drugs or alcohol while at the workplace which
includes its staff accomodation, except in accordance with Aldesta Heron Island Resort
Pty Ltd (Heron Island) Drugs and Alcohol policy;
 Consumption of illegal drugs at the workplace which includes its staff accomodation;
 Consumption of alcohol at the workplace, except in accordance with Aldesta Heron
Island Resort Pty Ltd (Heron Island) Drugs and Alcohol at Work policy;
 Working under the influence of drugs or alcohol that leads to impairment of an
employee’s performance and/or gives rise to a situation where other employees’ safety
is endangered;
 Possession of illegal weapons at the workplace;
 Harassment, including stalking, use of abusive or threatening language, intimidating
behaviour, fighting, verbally abusing or physically assaulting another employee,
customer or any other person. This behaviour need not occur at the workplace or during
working hours if it has its root cause in the employment relationship;
 Engaging in practical jokes or irresponsible actions, which could put at risk the safety of
employees or customers; or endanger life or cause damage to property;
 Deliberate breach of any safety regulation or wilful misconduct endangering the safety
of other employees, customers or visitors;
 Disclosing confidential information or breaches of confidentiality agreements between
an employee and Aldesta Heron Island Resort Pty Ltd (Heron Island);
 Accepting or offering bribes;
 Committing a serious breach of Aldesta Heron Island Resort Pty Ltd (Heron Island) policies
and procedures;
 Misuse of Aldesta Heron Island Resort Pty Ltd (Heron Island)’s email or internet facilities;
 Permitting an untrained person, as defined by Responsible Service of Alcohol Policy, or
minor person in a position of alcohol service within the site/venue;
 Serving alcohol to a visibly intoxicated customer;
 Serving alcohol to a minor;
 Service of more than the allowed number of alcohol drinks to a customer.
 Breach of Aldesta Heron Island Resort Pty Ltd (Heron Island)’s Corporate Credit Card
policy, including the misuse of a corporate credit card for unaccountable,
inappropriate or fraudulent expenditure.
Acceptable Use Policy
Aldesta Heron Island Resort Pty Ltd (Heron Island) provides each employee with reasonable
access to technology required to fulfil the responsibilities of his or her position. In doing so,
Aldesta Heron Island Resort Pty Ltd (Heron Island) has taken appropriate steps to safeguard the
computing environment to ensure appropriate integrity of the data generated, maintain the
confidentiality of our clients’ and customers’ account information and protect Aldesta Heron
Island Resort Pty Ltd (Heron Island)’s investment in technology, while maintaining the
appropriate availability of data as required. All company provided computer hardware,
software and data that is owned and operated by Aldesta Heron Island Resort Pty Ltd (Heron
Island) is the sole property of Aldesta Heron Island Resort Pty Ltd (Heron Island). It is the
responsibility of each individual employee (user) to adhere to Aldesta Heron Island Resort Pty
Ltd (Heron Island)’s Acceptable Use Policy, which includes policies and procedures on
technology related security, licensing, internet service, email services, encryption services,
computer threats, remote access, personal use of technology, and equipment care.

Social Media Policy

Aldesta Heron Island Resort Pty Ltd (Heron Island) has adopted a Social Media Policy
containing certain restrictions and procedures relating to the use of Social Media by
employees. Social media includes, but is not limited to, multi-media and social networking
websites (such as Instagram, Facebook, Twitter and YouTube), blogs (both Company blogs and
personal blogs) and Wikis (such as Wikipedia and any other site where text can be posted). In
short, only “Authorised Spokespersons” are permitted to use social media on behalf of Aldesta
Heron Island Resort Pty Ltd (Heron Island). Generally, it is not the intent of Aldesta Heron Island
Resort Pty Ltd (Heron Island) to restrict an employee’s off duty use of social media, except to
the extent that such conduct is illegal, violates the legal rights of others, or violates the Code,
corporate policies or applicable work rules. For further information, please contact your Line
Manager.

Searches in the Workplace

Aldesta Heron Island Resort Pty Ltd (Heron Island) reserves the right to conduct searches of
workplace property, personal property and vehicles at any time. This right does not include the
right to be in physical contact with a person, in accordance with Australian legislation. Desks,
telephones and computers provided by Aldesta Heron Island Resort Pty Ltd (Heron Island) are
the property of Aldesta Heron Island Resort Pty Ltd (Heron Island). Aldesta Heron Island Resort
Pty Ltd (Heron Island) reserves the right to enter or inspect an employee’s work area including,
but not limited to, desk and computer storage disks, email, PDAs and other electronic media
with or without notice.

Searches may be conducted by Aldesta Heron Island Resort Pty Ltd (Heron Island)
management, client management or by local authorities, where relevant. All searches must be
approved by the General Manager and the People and Culture Manager prior to being
conducted.

Individual searches of workplace property, personal property and vehicles shall not take place
unless the employee concerned is present, or alternatively, the employee has given permission
for such a search to take place in their absence. Where a search is to take place in the
employee’s absence, the employee may nominate some other responsible employee to be
present during the proposed search. If the employee is present and refuses the search, such
refusal may result in discipline.
Reporting
Any employee of Aldesta Heron Island Resort Pty Ltd (Heron Island) who learns of an apparent
violation of law, rule or regulation, unethical conduct relating to the business or activities of
Aldesta Heron Island Resort Pty Ltd (Heron Island), or any other violation of this Code shall report
such violation or conduct to his/her supervisor or other manager or to the General Manager.

If an employee does not wish to follow the foregoing procedure, or if it would be inappropriate
to follow such procedure, that individual may use the Employee Hotline.

No employee will suffer any retaliation for good faith reporting of any suspected misconduct or
impropriety. Further, reports of misconduct or impropriety may be anonymous to the extent
permitted by applicable law.

RESPONSIBILITIES
 All employees are responsible for behaving in a way that is consistent with the principles set
out in this Code when dealing with other employees, suppliers, vendors, business partners,
customers and agents of Aldesta Heron Island Resort Pty Ltd (Heron Island).
 Any employee of Aldesta Heron Island Resort Pty Ltd (Heron Island) who learns of an
apparent violation of law, rule or regulation, unethical conduct relating to the business or
activities of Aldesta Heron Island Resort Pty Ltd (Heron Island), or any other violation of this
policy shall report such violation or conduct to his/her supervisor or other manager, to the
Legal Manager or to any Executive.

If a violation of any applicable law, rule, regulation or this Code is detected, Aldesta Heron
Island Resort Pty Ltd (Heron Island) will take all reasonable steps to respond appropriately to
such violation and to prevent further similar violations. Such steps may include, without
limitation, appropriate disciplinary action of the individual(s) involved and/or, after full
investigation and if appropriate under the circumstances, reporting a violation of any
applicable law or regulation to an appropriate governmental authority.

All disclosures in accordance with this policy should be recorded in writing and placed on the
relevant employees’ file.
Acknowledgement Form
Thank you for taking the time to read over this policy.

Please complete the following Acknowledgement Form:

I acknowledge that I have received and read the “Code Of Conduct” and I understand that it
includes fundamental terms and conditions that govern my employment with Heron Island
Resort.

I understand my requirements to comply with the code of conduct and other practices as
described in this handbook. I also understand that Heron Island Resort may update or add to
any of the above conditions and I will be notified during the course of my employment.

I also understand that if I have any questions or concerns regarding any aspect of my
employment or conditions I should speak directly with my Line Manager for clarification.

Lais de Oliveira Mendes 03/11/2022

Name: Signature: Date:

Manager: Signature: Date: