Telstra Values, the Telstra Group Code of Conduct & Business Principles (TGCoC&BPs) and Telstra’s company policies promote and provide guidance on ethical and responsible decision making and behaviour. The TGCoC&BPs underpins the Telstra Values and sets out Telstra’s commitments to good corporate governance, responsible business practice, its customers, its workforce, society and the environment. Telstra’s company policies give effect to the principles embodied in the TGCoC&BP. A mandatory training program for all employees is also in place to reinforce Telstra’s legal, regulatory and compliance responsibilities.
The Telstra Values, TGCoC&BPs and some of Telstra’s key Company Policies are available on these Webpages.
- Privacy at Telstra
- Whistleblowing
- Anti Bribery & Anti Corruption
- Securities Trading
- Market disclosure
- Telstra's 3Rs of Social Media Engagement
Privacy at Telstra
Telstra is serious about its commitment to protect the privacy of its customers, including the information that they provide to Telstra. Telstra has adopted a policy and a set of privacy principles in accordance with the Commonwealth Privacy Act 1988 and Telecommunication Act 1997, which set out Telstra’s commitment to the protection of its customers’ personal information. They outline the ways Telstra protects customer personal information, how and why Telstra collects it, how Telstra may use and disclose it, how Telstra keeps it secure and accurate, as well as how customers may access it. Telstra’s Privacy Statement, which it gives to its customers, also describes how Telstra collects, uses, discloses and secures the personal information it collects from individuals.
Further information on Privacy at Telstra is available in the sustainability reporting included in Telstra’s 2012 Annual Report and at this link (including copies of Telstra’s Privacy Policy, Privacy Principles and Privacy Statement).
Whistleblowing
Telstra has a Whistleblowing policy and a confidential whistleblowing service which provides its staff with an avenue to report suspected unethical, illegal or improper behaviour. The whistleblowing process is supported by an independent service provider specialising in receiving sensitive reports or disclosures. All reports or disclosures are treated as confidential and can be made anonymously. Telstra’s Ethics Committee, which is made up of senior managers, monitors all reports and disclosures made under this process. This Committee also monitors all investigations, recommendations and the implementation of actions.
The Audit Committee oversees the whistleblowing program, receives reports from the Ethics Committee, and provides an escalation channel for the Ethics Committee where required.
Anti Bribery & Anti Corruption
Telstra’s policy on anti bribery and anti corruption aims to ensure that Telstra complies with applicable anti-bribery and anti-corruption laws and regulations. It states that employees and contractors of Telstra must show integrity and be honest and trustworthy in all their dealings with others. It provides that bribes, pay-offs, secret commissions, kick backs and any like payments (including facilitation payments) are strictly prohibited and staff should never make or accept, or agree to make or accept, such payments. The policy also provides that when staff give or receive a gift, prize, or hospitality, they must consider the implications of the giving or acceptance of that gift, prize or hospitality, to ensure that it cannot reasonably be considered a bribe, pay-off or kick-back, or be construed as being likely to improperly influence a business outcome.
In addition, Telstra’s policy on gifts, prizes and hospitality provides a process for employees and contractors to obtain approval for, and notify details of, certain gifts, prizes and hospitality that they are offered as a result of, or in connection with, their employment or engagement by Telstra.
Telstra also has a policy in place regarding conflicts of interest and outside activities, which provides a process to manage conflicts of interest, and assist employees, contractors and managers to understand what Telstra considers to be a conflict of interest and how to deal with any actual or potential conflicts.
Securities Trading
Telstra’s securities trading policy sets out the procedure relating to buying, selling and otherwise dealing in Telstra securities by Directors, the CEO, senior management and certain other designated employees (Designated Persons), through a trading windows approach.
Under the policy, Designated Persons must not buy, sell or otherwise deal in Telstra securities if they possess non-public, price-sensitive information and may generally only deal during a period of one month commencing 24 hours following the release of the annual results, the release of the half-yearly results or the close of the AGM.
Designated Persons are also prohibited from using Telstra shares as collateral in any financial transaction (including margin loan arrangements), engaging in any stock lending arrangements in relation to Telstra shares, and buying, selling or otherwise dealing in Telstra shares on a short-term trading basis. Further, Designated Persons are prohibited from entering into arrangements which effectively operate to limit the economic risk of their security holdings in Telstra allocated under Telstra’s equity plans during the period the shares are held in trust on their behalf by the trustee or prior to the exercise of any security.
Market disclosure
Telstra has policies and procedures in place which are intended to ensure that it complies with its continuous disclosure obligations and releases price-sensitive information in a timely fashion to the various stock exchanges on which its shares and debt securities are listed. In particular, a continuous disclosure policy is in place and is reviewed and updated on a regular basis. The policy outlines responsibilities and sets out the process for the approval of ASX announcements, including where Board approval is required in respect of announcements that relate to certain significant matters. The policy also outlines the role of the CEO, CFO and Continuous Disclosure Committee in relation to disclosure matters.
The Continuous Disclosure Committee (consisting of the Company Secretary, the General Counsel - Finance & Strategy, the Deputy CFO, the Director - Investor Relations and a representative of Corporate Affairs, or their delegates) is responsible for monitoring potentially disclosable information provided by management and overseeing systems to ensure that material information is identified and reported to the ASX as required. Telstra has implemented several practices internally to keep the Continuous Disclosure Committee informed about potentially disclosable matters and to reinforce the importance of its continuous disclosure obligations.
Telstra’s Investor Relations Communication Policy governs communications and the provision of information to shareholders, brokers and analysts. The aim of this policy is to ensure that Telstra provides investors and the financial community with appropriate and timely information whilst at the same time ensuring that the Company fulfils its statutory reporting obligations under the Corporations Act and the ASX Listing Rules.
Telstra provides advance notification of significant group briefings, such as its results announcements, and makes them widely accessible through the use of webcasting and placing all announcements made to the market on its website.
Telstra's 3Rs of Social Media Engagement
Social media offers opportunities for people to gather online to share, connect and engage with like-minded people and communities. Telstra embraces social media as an important tool to engage with staff, customers and the public every day. With the rapid growth and application of social media, Telstra recognises the need to have a policy that ensures employees and contractors who use social media, either as part of their job or in a personal capacity, have guidance. They need to understand Telstra's expectations as a staff member when they talk online about Telstra, its products and services, its people, its competitors and/or other business related individuals or organisations.
Telstra’s 3Rs of Social Media Engagement policy requires employees and contractors to be aware of the guidelines when engaging in social media, stipulating that they be clear about who they are representing, that they take responsibility for ensuring any references to Telstra are factually correct, accurate and do not breach confidentiality requirements, and that they show respect for the individuals and communities they interact with.
Approval and accreditation is required before employees or contractors can become authorised to use social media for business purposes on behalf of Telstra. The 3Rs policy also covers the requirements for the personal use of social media if references are made to Telstra, its people, products or services, business partners or its competitors.
