Policy-Standard heading

Table of contents
Introduction
What does our Code cover?
Who must follow our Code?
Values and behaviours
You and your accountabilities
Pacific Brands’ policies
Compliance with laws and regulations
Bribery and corruption
Conflicts of interest
Honesty
Political donations
Ensuring financial integrity
Communications
Continuous disclosure and public communications
Confidential information
Intellectual property
Ways of working
Speaking up
Disclaimer
Policy review
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10
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At Pacific Brands we make things everyday people love most. And we love doing it.
Working with us means something different.
Our culture is dynamic – we own it and we own its success. We are the custodians of powerful brands and we set their clear direction. Our values and behaviours underpin the way we work across all our brands. They define how we do what we do.
The Pacific Brands Code of Conduct (our Code ) is one of the ways we put our values and behaviours into practice. It's built around the recognition that everything we do in connection with our work at Pacific Brands will be measured against the highest possible standards of integrity and ethical conduct.
Our future success and reputation rely on the way we work with our customers, suppliers and other external partners. It also relies on the way we work with each other. That’s why it’s important that we have a shared understanding of how we work together and a clear framework to guide our actions and intentions, in the workplace and in the communities we operate in.
Our Code outlines our expectations for acting responsibly and ethically in the workplace across a range of issues such as:
 fair dealing
 conflicts of interest
 honesty
 communications
 continuous disclosure
 ways of working
Our Code does not include every ethical issue that we might face, nor every law and policy that applies to Pacific Brands. Sometimes when it comes to how we need to behave in business, there are no clear rules and regulations and we need to exercise good judgement.
Our Code and values and behaviours are the guiding principles we must use in any situation.
Our Code applies to everyone who works for Pacific Brands, in each country where we conduct business. Each of us - as an employee, contractor, agent, representative or director is expected to conduct business in line with our Code, and all relevant laws and regulations.
Failure to do so can result in disciplinary action, including termination of employment. Moreover, while the Code is specifically written for our employees and directors, we expect contractors, consultants and others who may be temporarily assigned to perform work or services for Pacific
Brands to follow the Code in connection with their work for us.
If you have any questions about our Code you can contact your manager, HR, GM Risk & HR
Services or the legal team.
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How we work is as important as the results we achieve. Our values and behaviours are core to our business. The way we lead, the work we do, the relationships we build and the fun we have all work towards creating amazing products that our consumers love.
Our values and behaviours come from our people and they are for our people. All employees at
Pacific Brands are required to live our values and behaviours – our shareholders expect it and it’s our commitment to one another about how we will treat each other and how we expect to be treated.
Our values are:
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Energy and Commitment
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Straight Talk
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Informed Decisions
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Ownership
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Collaboration
You can find more information about our values and behaviours from your manager or HR.
Our Code and values and behaviours are the framework for how we do business and work in conjunction with specific group, country and business unit policies. All of our policies are located on the intranet.
You need to know and understand what’s required of you when doing business. You need to comply with all relevant laws, regulations and policies that apply to your job, operate professionally and ethically, consistent with our values, and expected behaviours. You are ultimately responsible for your actions.
You need to communicate and demonstrate effective behaviours that reinforce our Code when you interact with your team and with others. This means making sure that all activities you undertake on behalf of the business are in line with our values. It also means giving your team feedback or advice so that their behaviour is consistent with our Code.
You need to take overall accountability for communication, monitoring and compliance of our
Code within your area of the business. You are also accountable for taking appropriate action if someone in your business unit breaches any part of our Code.
The Pacific Brands values are at the core of all our activities and by demonstrating and adopting each of these values, we will maintain a high standard of ethical and socially acceptable conduct.
We are committed to a respectful workplace with regard for others, and this means we don’t:
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 insult people
 put down people or their ideas
 send emails which are rude or disparaging
It’s simple - don’t be rude or dismissive to, or about your colleagues or management.
As an employee, contractor, agent or representative of Pacific Brands you must carry out your obligations and responsibilities to the organisation appropriately, extend normal business courtesies in a professional manner and act with trust, loyalty and respect towards your colleagues, suppliers, customers and other key stakeholders.
You are responsible for reporting any concerns you have about potential violations of our Code to your manager, HR or the GM Risk & HR Services. If you feel unable to raise an issue in this way, you can make a confidential, anonymous call to the “Faircall” line, administered by KPMG, to report unacceptable or undesirable conduct.
Contact numbers for “Faircall” are:
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Australia: 1800 500 965
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New Zealand: 0800 777 720
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North China: 108006500620
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South China: 108002652593
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Hong Kong: 800905509
United Kingdom: 0808 234 7091
Malaysia: 1800 806 400
Indonesia: 8 0365 7094
Pacific Brands believes it is important that employees who wish in good faith to report any improper conduct be empowered to do so without fear of reprisal.
Improper conduct is any conduct that is prohibited under our Code.
If an employee reasonably suspects that another employee is or could be involved in any improper conduct which is of a serious nature, the employee should report it to Pacific Brands’ legal team or the “Faircall” line.
KPMG or Pacific Brands’ legal team will investigate any reported improper conduct while protecting the confidentiality of the identity of the whistleblower. The identity of the whistleblower will only be disclosed where it becomes necessary because of pending litigation or where there is some other overriding reason for disclosure. Disclosure will be made only after the whistleblower has been informed of the need for it.
All reports will be investigated discreetly, and only those persons who need to know the fact, and the details, of a report, will be informed of it. This may include the board of directors or the
Chief Executive Officer in serious cases or where the report alleges a breach of the
Corporations Act. Where necessary, we might engage external resources to assist with an investigation.
Pacific Brands will not tolerate any form of harassment or retaliation against employees who, in good faith and without malice, report improper conduct in accordance with this Code. A whistleblower’s confidentiality also receives statutory protection under the Corporations Act where a report relates to a potential breach of the Corporations Act.
Pacific Brands has policies and guidelines in relation to a range of matters impacting your conduct in the workplace, including:
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 continuous disclosure of material information
 guidelines for dealing in securities (shares)
 occupational health and safety
 equal employment opportunity
 privacy
 email and internet
 online behaviour and social networking
 drugs & alcohol
 avoidance of bullying
You need to be familiar with and adhere to the requirements of each of these policies and guidelines at all times.
Copies of all relevant policies and guidelines are available on the Pacific Brands policies page on the intranet. If you have any questions regarding any of the Pacific Brands policies at any time, you should contact your manager or HR.
The purpose of the Delegated Authorities and Limits Policy ( DALs ) is to provide authority to certain managers and employees whilst maintaining appropriate internal controls.
The DALs outline general principles which reflect how we expect our employees to behave when exercising their authority as well as some specific limits to indicate at which level an activity can be approved.
Compliance with the DALs is mandatory and all employees should ensure they are aware of and understand the authority levels that apply to their role. The DALs can be found on the policies page of the intranet.
Every person covered by our Code, whatever their role and position, should be aware of, and comply with, the duties and obligations which apply to us under any laws, legislation or regulations relevant to our work.
We encourage you to participate in our various training programs to ensure that your knowledge remains up to date and that you remain abreast of relevant legal and industry developments.
All employees are responsible for abiding by the rules of the Competition and Consumer Act in
Australia and relevant legislation in other countries in which Pacific Brands operates.
Pacific Brands and its employees have an obligation to comply with the requirements of the
Competition and Consumer Act (and equivalent overseas legislation) when dealing with external parties. This involves avoiding the use of misleading or deceptive statements, refraining from engaging in collusive or anti-competitive conduct with other companies and so on.
The legislation was written to ensure that businesses compete on an equal and fair basis. It forbids a number of “anti-competitive” activities. It also provides a set of standards to protect consumers.
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Examples of activities that are prohibited by this legislation include:
 deceiving a customer about the price or discount of a product
 making a false claim about the warranty or performance of a product or where it was made
 imposing any conditions on the purchase of a product, e.g. forcing a customer to get a necessary component from another party
 making an agreement with a competitor to fix credit terms or prices
 making derogatory comments about a competitor or their products
Pacific Brands offers training to employees to ensure they understand their obligations under this legislation. For further information and advice or if you are faced with a situation which you think may be a breach of the Competition and Consumer Act (or its equivalent), contact the legal team.
Like all businesses, Pacific Brands is subject to numerous laws in the countries in which it operates that prohibit bribery in virtually every kind of commercial setting.
The rule here is simple - don't bribe anybody, anytime, for any reason.
You should also be careful when you give gifts or pay for entertainment or other business courtesies on behalf of Pacific Brands. You must avoid the possibility that the gift, entertainment or other business courtesy could constitute or be perceived as, a bribe, so it's always best to provide such business courtesies infrequently and, when you do, to keep their value modest.
Gifts, donations and hospitality are discussed in more detail further in this policy.
Please ensure your read and understand the Pacific Brands Fraud and Corruption Policy on the intranet and if you need further information or if you are faced with a situation which you think may involve bribery or corruption, please contact the legal team, GM Risk & HR Services or contact the Faircall line if you would prefer to remain anonymous.
In working at Pacific Brands, we have an obligation to always do what's best for the company and our customers. When you are in a situation where competing loyalties could cause you to pursue a personal benefit for you or your friends or family at the expense of Pacific Brands or our customers, you may be subject to a conflict of interest.
All of us should avoid circumstances that present even the appearance of such a conflict.
When faced with a potential conflict of interest, ask yourself:
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Would this relationship or situation embarrass me or Pacific Brands if it showed up on the front page of a newspaper?
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Am I reluctant to disclose the relationship or situation to my manager or HR?
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Could the potential relationship or situation create an incentive for me, or be perceived by others to create an incentive for me, to benefit myself, my friends or family or an associated business, at the expense of Pacific Brands?
If the answer to any of these questions is 'yes,' the relationship or situation is likely to create a conflict of interest, and you should avoid it.
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Any person covered by our Code is responsible for notifying their manager or HR if he or she suspects that there is a conflict of interest or a potential conflict of interest. If you are concerned that you have a potential conflict of interest you should disclose and discuss the matter with, and seek direction from your manager, HR, GM Risk & HR Services or our legal team.
The following are examples of a conflict of interest:
 working for a competitor at week-ends or night shift
 owning a business in competition with Pacific Brands
 engaging in a family business which interferes with your performance or achievement of
KPIs
Set out below is a discussion of some common examples of activities or interactions that may constitute actual or apparent conflicts of interest that should be avoided, but this is not intended to be an exhaustive discussion of potential conflicts of interest.
You should not exploit your position with Pacific Brands for personal gain. For example, conflicts of interest can arise when you or a member of your family receives improper personal benefits as a result of your position.
Pacific Brands has extensive dealings with companies based in countries where gift-giving has important cultural significance and plays an important role in business relationships. While you should be aware and respectful of such cultural practices, we encourage you to remain mindful that accepting gifts or entertainment from a customer, supplier, partner or competitor can easily create the appearance of a conflict of interest.
We encourage you not to accept a gift in circumstances in which it would appear to others that your business judgement has been compromised, nor put yourself or Pacific Brands in a position that would be embarrassing if the gift was made public.
The following principles should be adopted when considering gifts:
 never solicit goods or services from our business contacts for personal benefit
 don’t accept gifts or services where it is apparent that they are being given with the intention of influencing Pacific Brands business dealings
 you may accept an unsolicited gift or benefit where the value is less than $100 or of an inconsequential or trivial nature and there is no apparent influence intended.
 where the value is estimated to be greater than $100 and refusal may offend, you need to speak with your manager (unless your manager approves this, it should be returned without delay with an explanation of the company policy)
 prizes won as a result of conducting official business must be reported to your manager and where the value is greater than $100 they should be donated to a charity or raffled off, with the proceeds going to a charity
 never accept gifts of cash or cash equivalents (e.g. gift certificates or prepaid gift cards)
However, if you are in doubt as to the appropriateness of a gift please check with your manager,
Human Resources manager, the GM, Risk and HR Services or the General Counsel.
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Where invitations to local sporting, social and cultural functions are offered, care should be taken to ensure that your presence does not imply an inappropriate relationship with the host or preference in your dealings with that person. Entertainment of (or by) clients and suppliers should be modest in nature and not extend beyond a level reasonably required to maintain an arms length business relationship. Importantly, if attending a function, any related travel or accommodation costs are your personal responsibility.
Take care when accepting any items so that there is no misunderstanding created in terms of there being any reciprocation or “tied” benefit.
Hospitality may be common during a period of deal or contract negotiation; however it is likely to give the appearance of undue influence. As such employees who are offered hospitality in these circumstances should clear it with their General Manager to avoid an appearance of undue influence.
You should avoid having an ownership interest in any other enterprise if that interest compromises or appears to compromise your loyalty to Pacific Brands. This will not normally apply to interests in listed entities. However, if you have any doubt about such an interest, you should consult with your manager, HR, GM Risk & HR Services or the legal team.
In particular, you must not:
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engage in any business transaction with Pacific Brands unless you have the express written approval of the General Counsel
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own an interest (other than a minor shareholding in a publicly listed company) in any organisation doing or seeking to do business with Pacific Brands (this may include a supplier of products or services or an interest in a property leased by Pacific Brands)
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perform services for a competitor (or likely competitor) of Pacific Brands
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have an interest in any competitor or likely competitor of Pacific Brands. Should you own an interest in any organisation which becomes a competitor (other than a minor shareholding in a publicly listed company), you must address this immediately with the
General Counsel.
You should advance Pacific Brands’ legitimate interests when the opportunity to do so arises and should not take advantage of property, information, your position or other opportunities arising from your position for your personal benefit .
You should ensure that company property is used in accordance with ethical standards of conduct - outlined below in the section covering “Honesty”.
Below are some clear guidelines:
 if you learn of a business or investment opportunity through the use of corporate property or information or your position at Pacific Brands, you should not participate in the business or make the investment without approval from the General Counsel
 you should not participate in a joint venture, partnership or other business arrangement with
Pacific Brands without approval from the General Counsel
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 you must not acquire any interest (real estate, patent rights, securities or any other type of property) on the basis of an opportunity resulting from your employment or in which you are aware Pacific Brands has or might acquire any interest
 you must not participate in employment or activities that would detract from your job performance with Pacific Brands (e.g., through long hours affecting physical or mental effectiveness) or conflict with any obligations to Pacific Brands including those under your terms of employment.
Please note that these guidelines also extend to friends, family and associates.
Each of us - as an employee, contractor, agent or representative of Pacific Brands – is expected to conduct business in line with
Pacific Brands’ values and behaviours and all relevant laws and regulations.
Good business practices, and Pacific Brands values, mean that as an employee you:
 avoid deception, unfair practice, fraud, misrepresentation, improper personal gain (including trading for personal gain) or any behaviour which would reflect badly on Pacific Brands
 act with honesty and in good faith in all dealings and relationships
 have respect for the trust placed in you to take proper care and protection of all Pacific
Brands assets, resources and information
 understand that how you go about business activities on behalf of Pacific Brands is as important as what you achieve
We will not tolerate any fraudulent activity or the improper use of or theft of Pacific Brands goods, money or property. For further information about how we manage fraud and theft, please see the Pacific Brands Fraud and Corruption Policy on the intranet.
Company resources are to be used for the purposes of doing business on behalf of Pacific
Brands and you are expected to use these resources responsibly and appropriately. This includes the use of any Pacific Brands business names and brands, which must be done in line with our business guidelines. It also includes the use of email and the internet.
On occasion, you may need to use the phone or company internet for personal business while you are at work. The guide here is to understand that excessive use of company resources is not appropriate and to act responsibly in this situation.
Employees have a responsibility to protect assets under their control. This includes information, cash and financial assets, plant, equipment, inventory and supplies. If removed from our premises assets should be stored in a secure manner and covered by appropriate insurance.
Employees who leave Pacific Brands must immediately return all company property in their possession.
If you have any questions about your responsibilities you should consult with your manager,
HR, GM Risk & HR Services or the legal team.
Pacific Brands does not permit donations to be made to political parties on behalf of the company.
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Financial integrity is a core aspect of good corporate governance. The money we spend on behalf of Pacific Brands is the company's and, ultimately, our shareholders'. Each person at
Pacific Brands has a role in making sure that money is appropriately spent, our financial records are complete and accurate and internal controls are being complied with.
Below are some principles that underpin financial integrity:
Each time you enter into a business transaction on Pacific Brands’ behalf, there should be documentation recording that agreement, approved by the Legal team.
Never sign any contract on behalf of Pacific Brands unless you are authorised to do so under our Delegated Authorities and Limits Policy and the contract has been approved by the Legal team.
If your job involves the financial recording of our transactions, make sure that you're aware of all of the policies that apply. Immediately report to your manager, any transactions that you think are not being recorded correctly.
You should never interfere in any way with the preparation or auditing of Pacific Brands' financial records. Similarly, you should never falsify any record or account.
If you suspect or observe any irregularities relating to financial integrity, no matter how small, immediately report them to the General Counsel or Chief Financial and Operating Officer.
It's important that we keep records for an appropriate length of time.
Our record retention policy suggests minimum record retention periods for certain types of records. In addition, if asked by the Legal team to retain records relevant to litigation, audit or investigation, do so until the Legal team tells you retention is no longer necessary.
If you have any questions regarding the correct length of time to retain a record, contact the
Legal team.
When you submit an expense for reimbursement or spend money on Pacific Brands behalf, make sure that the cost is:
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reasonable
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directly related to company business
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supported by appropriate documentation
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reported accurately and in accordance with our procedures
If you're uncertain about whether you should spend money or submit an expense for reimbursement, check with your manager.
Managers are responsible for all money spent and expenses incurred by their direct reports, and should carefully review such spend and expenses before approving.
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Our communication facilities (which include both our network and the hardware that uses it, such as computers and mobile devices) are a critical aspect of our company's property.
Be sure to follow all security policies.
If you have any reason to believe that our network security has been, or could be, violated, for example, you lose your laptop, iPad, blackberry, iPhone or mobile phone or think that your network password may have been compromised, please promptly report the incident to the IT
Helpdesk.
Employees must use software approved by Pacific Brands at work and must not duplicate company software (other than for backup and archival purposes) for business or personal use.
This includes proprietary or internally developed software.
Breach of this policy may expose Pacific Brands to prosecution and severe penalties under copyright law.
Employees should use Pacific Brands email and internet for business purposes only, except for incidental and occasional personal use. It is important to be aware that any messages transmitted by email are treated as business messages and constitute the property of Pacific
Brands.
Employees must all read and be familiar with the Pacific Brands Email and Internet Policy and
Online Behaviour Policy, both of which can be found on the intranet.
Any requests by the media or its representatives for information relating to Pacific Brands should be referred to the Chief Executive Officer or Chief Financial and Operating Officer.
Pacific Brands values its customers and respects their privacy. We collect information in an effort to improve our customers' experience in dealing with us and to communicate about our products.
We recognise that we must maintain and use customer information responsibly and we will use good faith efforts to respect customer preferences about how we use their information.
We ask you to familiarise yourself with and comply with privacy laws and Pacific Brands’ privacy policy, (you can find it on the intranet) to ensure that you are aware of and discharge your obligations under relevant laws. If you are unsure of your obligations, please contact the Legal team.
Pacific Brands has adopted a continuous disclosure policy (you can find it on the intranet) relating to its obligations under the Corporations Act and the ASX and NZX Listing Rules. The objective of this policy is to keep the market fully informed of information which may have a
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You should ensure you are aware of the requirements of the policy, and if it applies to you, you must act in accordance with the policy. You are responsible for the integrity of the information, reports and records under your control and are expected to exercise the highest standard of care in preparing materials for public communications.
Documents should:
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comply with any applicable legal requirements
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fairly and accurately reflect the transactions or occurrences to which they relate and be supported by accurate documentation
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not contain any false or intentionally misleading information, nor intentionally misclassify information
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be in reasonable detail and recorded in the proper account and in the proper accounting period
Employees must not disclose or use in any unauthorised manner confidential information about
Pacific Brands, its customers or its affairs that they acquire during their employment, unless the information is already legitimately public knowledge. This obligation extends after an employee leaves Pacific Brands.
“Information” in this context means any information in respect of Pacific Brands’ business which is not available to the public and includes documents, books, accounts, processes or other
“know how” which is supplied to the employee and/or generated by an employee in the course of performing his or her work for Pacific Brands.
Examples of confidential information are:
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price lists/cost sheets
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trading terms
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lists of customers
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employee (personal) details
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details of marketing programs
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technical information
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information about suppliers
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computer systems
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business strategies
However, our responsibilities extend beyond not revealing confidential material, we must also:
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safeguard confidential information that Pacific Brands receives from others
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take steps to keep our trade secrets and other confidential intellectual property secret
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return all company property including any documents or confidential information on termination or on the request of Pacific Brands or its representative
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destroy or delete any confidential information stored in electronic, magnetic or optical form so that it cannot be retrieved or reconstructed in any way if requested by Pacific Brands.
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If you are unsure if information should be treated confidentially, contact the legal team.
All intellectual property, including inventions, discoveries, computer software processes and improvements made by an employee during his or her employment with Pacific Brands, remain the property of the Pacific Brands.
This means Pacific Brands will hold all proprietary rights to intellectual property and trade secrets. This includes all ownership rights, copyright, exclusive rights to develop, make, use, sell, licence or benefit from any inventions, discoveries, processes and improvements made during an individu al’s employment with Pacific Brands.
Employees must not act in any way that could cause harm to the reputation or market position of Pacific Brands both during and after their employment.
Importantly, employees at all levels represent Pacific Brands – both during and outside of working hours. This includes travelling on company business, attending functions on behalf of
Pacific Brands or work related conferences, training programs, seminars etc. Your behaviour in all of these circumstances reflects on Pacific Brands and its reputation.
Employees that conduct themselves inappropriately will be subject to disciplinary action.
Our values are at the heart of providing a safe and healthy workplace and operating appropriately in the communities where we work. That’s why Pacific Brands has standards in place which guide our actions and intentions in the workplace.
We are committed to providing a safe and healthy workplace for our employees, contractors, customers, visitors and the communities we operate in. Nothing is so urgent that anyone’s safety, health or the environment should be compromised by anything any of us do. Every employee has the accountability to stop any task at anytime if there is a perceived hazard to themselves, others or the environment.
We value and encourage people to take personal and collective accountability for preventing workplace incidents by identifying and resolving workplace risks to eliminate injuries and illnesses. We also value look ing out for each other’s safety and wellbeing through teamwork. All employees have obligations to operate in this way, at all times.
You must be aware of and understand the Pacific Brands safety, health and environment policies and procedures so that our workplace is safe and without risk to the health of others or yourself. You must also follow any lawful and reasonable instructions consistent with the policy and associated procedures.
Smoking is prohibited in the workplace. All employees must comply with the non-smoking policy applicable in each work location and where applicable, employees may only smoke in the designated areas and at designated times.
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The use of drugs and alcohol may impair an individual’s capacity to perform their job safely, efficiently and with respect for work colleagues and customers. The Pacific Brands drug and alcohol guidelines prohibit the unlawful use of alcohol, and drugs at the workplace or when conducting company business.
Employees are not permitted to:
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use or possess illegal drugs at any Pacific Brands site
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attend work suffering from the effects of drug use, alcohol or illegal substances
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consume alcohol at work unless at an authorised company sponsored event (refer below)
Employees have a responsibility to ensure that any prescription drugs do not impair their ability to perform the role safely and efficiently.
Managers and supervisors have a responsibility to direct any employee at work, under the influence or reasonably suspected of being under the influence of drugs and alcohol, away from the workplace and to report any such incidents to HR.
Pacific Brands is committed to conducting its activities in a manner that encourages the responsible service and consumption of alcohol. It is preferred that company sponsored events are run offsite at suitably equipped venues. If management run an in-house company sponsored event with alcohol, these will be of short duration with food and non alcoholic drinks also provided. Management will be responsible for ensuring the responsible service and consumption of alcohol at in-house events.
Pacific Brands expects all employees to maintain professional standards of personal presentation. The key guideline is to use common sense, having regard to the nature and circumstances of your role and any safety requirements such as personal protective equipment
(e.g. hi-visibility vests, closed toe or steel capped footwear).
A manager or supervisor may send an employee home to change if the employee’s dress is unsuitable for work. Where an employee is sent home for this reason, their absence from the workplace is considered unpaid leave.
Pacific Brands seeks to maintain a work environment where diversity is valued and respected, to attract and retain people who can contribute towards our business objectives and to identify and remove barriers that prevent employees from performing to their full potential.
Discrimination, harassment and bullying will not be tolerated under any circumstances.
Complaints or allegations of discrimination, harassment, victimisation or bullying will be investigated. Where a breach is substantiated, appropriate action will be taken, ranging from counselling to termination of your employment
Employees should read and be familiar with the Pacific Brands Equal Opportunity Policy, which can be found on the intranet.
Employees are not permitted to carry or bring any dangerous weapons onto company premises including, in company vehicles. This includes firearms of any description, knives and explosives.
Pacific Brands will not tolerate violent behaviour in the workplace. This includes acts of physical violence, aggressive behaviour, bullying, verbal threats or abuse directed at another employee or to/from a customer or visitor.
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Pacific Brands has adopted specific guidelines for dealing in Pacific Brands’ securities (shares) by directors, officers and employees of Pacific Brands. You should read and be familiar with that policy (it can be found on the intranet) to ensure you comply with it
Pacific Brands is committed to doing business in an environmentally responsible manner and identifying environmental risks that may arise out of our operations. Pacific Brands has policies and procedures in place to address our obligations under various environmental regulations.
If you become aware of, or suspect that an action is in breach of the applicable laws and regulations or that it is not environmentally responsible you should report the matter to your
Manager or HR, so that it can be escalated and addressed.
We expect all employees to be guided by both the letter and the spirit of our Code. If you are uncertain about how to act in a particular situation, talk to someone and seek advice before you act. Speak to your colleagues to get their view or talk to your manager, or someone from the appropriate support function, Legal, HR or Finance – before you act.
You are responsible for reporting any concerns you have about potential violations of our Code to your general manager, either through your manager or your HR manager. Alternatively, if you feel unable to raise an issue in this way, you can make a confidential, anonymous call to the
Faircall line to report unacceptable or undesirable conduct.
You are required to comply with any investigations into concerns about breach of our Code or
Pacific Brands’ policies and procedures. Any person who breaches our Code (including by failing to report a suspected breach or by victimising another for reporting a concern) may be subject to disciplinary action, which may include termination of employment.
This Code of Conduct is a statement of certain fundamental principles, policies and procedures that govern actions in the conduct of Pacific Brands’ business. It is not intended to, and does not create any rights in any employee, client, customer, supplier, competitor, security holder or any other person or entity.
At least annually the GM, Risk and HR Services will initiate a review of this policy. Any proposed changes to this policy must be approved by the Board of Directors.
© Pacific Brands
Revision December 2011
Version 1.0
Page 16 of 17

Version control page
Document description Code of Conduct
Document applies to Pacific Brands Limited
Document owner CEO
Document approved by Board
Version number 1.0
December 2011 Creation date
© Pacific Brands
Revision December 2011
Version 1.0
Page 17 of 17