Ethics & compliance
All employees are provided with an employee handbook that outlines the values, policies, procedures and standards of conduct to be adhered to in all situations.
Compliance seminars are held annually for key staff on legal requirements and procedures. It is the responsibility of each employee to understand Scentre Group’s values and policies and report any conduct or activities that might be in breach of these values.
The whistleblower policy ensures that concerns regarding unethical, unlawful or improper conduct may be raised without fear of reprisal. Under the policy, Scentre Group has an appointed Whistleblower Protection Officer in both Australia and New Zealand. Employees are encouraged to report any genuine matter or behaviour that they believe contravenes our code of conduct, policies or the law. Matters may include any actual, or suspected, conduct or practices which are illegal, corrupt activities, theft or fraud, misleading or deceptive conduct of any kind, harm to public health or safety or the health or safety of any Scentre Group employee.
We investigate all reported concerns appropriately and will, where applicable, provide feedback regarding the outcome of the investigation. We take any necessary action in response to a report and where no action is taken, an explanation will be provided. Where appropriate, a third party may be engaged to assist in the investigation. Every six months a report is provided to the Audit and Risk Committee summarising the whistleblower activities for the period.
In looking at the key drivers for maintaining a sustainable business, the Group also analyses the key risks that could impact the business. The Group’s Risk Management Framework forms part of the Group’s everyday business processes and is supported by a dedicated risk management function.
A number of important strategic risks are listed below, and how the Group manages and monitors such risks are available in more detail in the DMAs online:
- Property ownership risks
- Property management and development risks
- Financing risks
- Economic downturn
- Regulatory changes
- Workplace health and safety
- People and culture
In line with ASX Corporate Governance Principles and Recommendations (7.4), in 2015 the Group conducted a review to identify any economic, environmental and social risks that may materially impact the business. No material risk has been identified which was not already documented in the corporate and divisional risk registers. Divisional and business unit risk registers have been updated and amended with new identified non-material sustainability risks and controls, and are continuously reviewed as part of the annual Enterprise Risk Management process.
Fines and sanctions
In 2016 Scentre Group received no significant fines or non-monetary sanctions for non-compliance with any laws and regulations, including those relating to the environment and the provision of goods and services. The Group defines significant fines as being $100,000 or above.
Gifts and Entertainment Policy
In 2016 we updated our Gifts and Entertainment policy and requested that our employees register any benefits received over a $100 threshold. This is to ensure that appropriate guidelines and personal accountability and responsibility standards are in place to maintain integrity in all business relationships.