Student Data Systems

STUDENT DATA SYSTEMS CODE OF ETHICS AND CONDUCT

Student Data Systems is committed to conducting its business in a way that is open and accountable.  We believe our corporate governance practices as a private company are rigorous and of a high standard. 

PURPOSE OF THE CODE

Student Data Systems employees are bound by a Code of Ethics and Conduct (“Code”).  The objective of the Code is to ensure that:

• high standards of corporate and individual behaviour are observed by all Student Data Systems employees in the context of their employment with Student Data Systems;
• employees are aware of their responsibilities to Student Data Systems under their contract of employment; and 
• all persons dealing with Student Data Systems whether it be employees, shareholders, suppliers, customers or competitors can be guided by the stated values and policies of Student Data Systems.

 

For the purpose of this document “employees” includes Student Data Systems contractors and directors.

Employees will adhere to the Code both in letter and in spirit.  Adherence to the Code is a term of employment with Student Data Systems.  Violation of the Code by any employee, or unethical behaviour which may affect the reputation of Student Data Systems, may be subject to disciplinary action including termination of employment.

Student Data Systems and its employees must act with high standards of honesty, integrity, fairness and equity in all aspects of their employment with Student Data Systems.

Student Data Systems and its employees must comply fully with the content and spirit of all laws and regulations which govern the operation of Student Data Systems, its business environment, and its employment practices. 

Employees will not knowingly participate in any illegal or unethical activity.

Employees will not enter into any arrangement or participate in any activity that would conflict with the interests of Student Data Systems or prejudice the performance of professional duties.

Employees must actively promote compliance with laws, rules, regulations and this Code.

Employees shall not do anything which would be likely to negatively affect Student Data Systems reputation.

Student Data Systems RESPONSIBILITIES TO BENEFICIARIES

It is Management’s task to achieve and oversee the delivery of value through the sustainable and efficient operation of the company, sound reporting and risk management practices and exemplary compliance with a continuous disclosure regime.  The mechanisms to achieve this include the risk management structures, internal audit function, and oversight of strategic and business objectives. 

CARE AND DILIGENCE
Student Data Systems and its employees should exercise due care and diligence in the performance of their duties and responsibilities. This should include such activities as ensuring the accuracy of all decision-making information, attending to detail in all aspects of work, being mindful of the sensitivities of others, protecting confidentiality and being courteous, open and honest.

The products and services provided by Student Data Systems will be of high quality.  Student Data Systems and its employees will deliver these products and services to its customers in a timely and equitable manner, and give customer satisfaction high priority.  Where the quality of products and services provided by Student Data Systems is not satisfactory to its customers, Student Data Systems will take prompt remedial action.

CONFLICTS OF INTEREST
Where a conflict of interest arises or may arise, an employee must disclose the conflict to his or her supervisor.  The supervisor will ensure that measures are put in place to protect parties affected by the conflict of interests from that conflict.  Depending upon the nature and extent of the conflict, the measures taken to protect against conflict of interest may include ensuring that the conflicted or potentially conflicted employee does not participate in the relevant decision or activity, or disclosing the conflict to third parties affected by the conflict and ensuring that the conflicted or potentially conflicted employee is not the sole decision maker on the matter.  

Employees who are directors of Student Data Systems or its subsidiaries will be guided by the constitution of Student Data Systems or the subsidiary and will ensure that they abide by the provisions in the Corporations Act governing conflicts of interest.  Where there is doubt the matter should be raised with the CEO of Student Data Systems or the relevant subsidiary.

Employees will not take advantage of property, information or position, or opportunities arising from these, for personal gain or to compete with Student Data Systems.  

Employees will not breach Student Data Systems confidentiality or make use of confidential information obtained from Student Data Systems for personal gain or ‘in a manner which would be detrimental to Student Data Systems.  Confidential information of Student Data Systems will not be used except in ways which are authorised by Student Data Systems or legally mandated.  The same applies to confidential information belonging to third parties which an employee may obtain in the course of their duties.

Student Data Systems will respect the confidentiality of its employees.

FAIR DEALING
Student Data Systems complies with Australian Trade Practices Act 1974.  

Student Data Systems and its employees will comply with the content and spirit of all relevant laws and regulations concerning employment, such as anti-discrimination, equality of employment, health and safety.  Student Data Systems will endeavour to ensure that all employees are treated fairly, equitably, and honestly.

Student Data Systems assets must be acquired, maintained and used in an efficient manner and for legitimate business purposes.

Student Data Systems Privacy Policy regulates the handling of any personal information that Student Data Systems collects. It contains detailed information on Student Data Systems functions and activities, and privacy issues and its privacy policy provisions. A copy of the policy is available on our website, http://studentdatasystems.com . 

Student Data Systems also requires employees to comply with the following policies as amended from time to time:

• Diversity, EEO and Appropriate Behaviour Policy
• Occupational Health and Safety
• Internal Directorships;
• External Directorships;
• Email Use;
• Internet Use;
• Personal references required by Student Data Systems Business Rules;
• Acceptance of gifts and hospitality;
• Use of drugs and alcohol; and                         
• Property and information belonging to Student Data Systems.
• These policies are available to all employees

MONITORING COMPLIANCE WITH THE CODE

Student Data Systems’s internal auditor monitors compliance with this Code.

Employees are required to report violations of the Code with procedures to ensure employees are not disadvantaged in any way for reporting violations of the Code or other unethical conduct, that the matter is dealt with promptly and fairly and that the procedures are not used maliciously or mischievously.