Policy owner and approver: Adam Cogan
Implementation: State Managers
Last updated: 15 October 2026
SSW expects everyone representing the business to act honestly, fairly and professionally. We build trust by keeping our commitments, respecting others, protecting information and taking responsibility for our decisions.
This Code sets out the standards expected of all SSW directors, employees and contractors worldwide. It applies in SSW offices, when working remotely or at client sites, during work-related travel and events, and in work-related online communications.
Everyone must comply with applicable laws and contractual obligations. Where local law imposes a higher standard, that requirement applies.
Be truthful in your communications, advice and records. Do not mislead clients, colleagues, suppliers or the public, including by leaving out material information.
Represent your skills, experience and the capabilities of SSW's services and products accurately. Be clear about uncertainty, limitations, estimates and risks. Raise mistakes promptly and help put them right.
Keep accurate timesheets, expense claims, invoices and other business records. Record work honestly and bill in accordance with agreed client terms. Do not fabricate records, conceal unauthorised charges or claim expenses that were not legitimately incurred.
Make commitments within your authority and obtain appropriate approval before agreeing to work, expenditure or obligations on SSW's behalf.
These expectations are supported by SSW's rules on communicating with candour and clarity and recording time accurately.
Treat colleagues, clients, suppliers and other people with dignity and respect.
SSW does not tolerate discrimination, harassment, sexual harassment, bullying, threats, violence or victimisation. These standards apply equally to in-person interactions, email, messaging, video calls and other work-related communications.
Give feedback constructively, listen to concerns and disagree professionally. Managers must make fair decisions, explain them appropriately and respond to concerns without retaliation.
Follow SSW's Diversity Policy. Practical guidance is available in the rules on giving and taking feedback and speaking up about unfairness.
Disclose actual, potential or reasonably perceived conflicts of interest to your State Manager promptly, preferably before becoming involved in the relevant decision or activity.
Examples include:
A conflict does not automatically mean an activity is prohibited. It must be disclosed and managed transparently.
The responsible manager will document an appropriate response, which may include approval with conditions, independent oversight, withdrawing from a decision or ending the conflicting activity. Do not participate in the affected decision until the conflict has been assessed.
Adam handles conflicts involving State Managers. Levi Jackson handles conflicts involving Adam. Nobody may approve their own conflict.
Modest, occasional gifts and hospitality may be given or received where they serve a legitimate purpose and do not compromise professional judgement.
Cash and gift cards are permitted under the same conditions as other gifts.
State Manager approval is required before giving or accepting gifts or hospitality exceeding AUD $200, or the local equivalent. Related gifts and hospitality from the same giver to the same recipient must be counted together over a rolling 12-month period. Obtain approval before an additional item takes the total above the threshold.
Do not split gifts or use intermediaries to avoid approval. Keep sufficient records of the giver, recipient, date, value and purpose to identify related gifts and demonstrate any required approval.
Adam approves gifts and hospitality involving State Managers. Levi Jackson approves those involving Adam. Nobody may approve their own gift or hospitality.
Regardless of value or approval:
SSW's guidance on showing clients they are valued must be applied within these limits.
SSW prohibits bribery, kickbacks, fraud and corrupt conduct, whether carried out directly or through another person.
Do not offer or accept payments, gifts, favours or other benefits to obtain an improper advantage. Do not make unofficial payments to secure or speed up routine official actions.
Compete fairly and make purchasing and supplier decisions on legitimate business grounds. Do not engage in price-fixing, bid-rigging or improper sharing of commercially sensitive information.
Report suspected misconduct through the channels in this Code. Approval from a manager never authorises unlawful conduct.
Protect confidential information belonging to SSW, clients, colleagues and other organisations. Access and use information only for authorised work purposes, and share it only with people entitled to receive it.
Follow SSW's Privacy Policy, security procedures, client agreements and any non-disclosure obligations.
Respect intellectual property rights and software licences. Do not copy, publish or reuse code, documents, images or other materials without the necessary rights or permission.
SSW encourages sharing knowledge, but confidential, personal and NDA-protected information must be protected. Apply the rule on making appropriate information public within those boundaries.
Confidentiality obligations continue after employment or engagement ends.
Use SSW and client systems responsibly. Protect credentials, follow access controls and promptly report suspected security incidents, accidental disclosures or loss of equipment.
Reasonable personal use of SSW equipment and systems is allowed where it:
Use AI tools in accordance with SSW's Privacy Policy, approved arrangements and client permissions. Client data may only be used with the required permission through signed terms and conditions and within any agreed restrictions.
SSW and client data must not be used to train AI models. Check relevant tool settings and terms before submitting information. Review AI-generated work for accuracy, confidentiality, security and intellectual property concerns before relying on it or sharing it.
Notify everyone on a call before enabling recording or transcription, and meet any additional applicable consent requirements.
Communicate professionally when representing SSW. Only make official statements or commitments within your authority.
When expressing personal views, do not imply that you are speaking on SSW's behalf. Do not disclose confidential information or make misleading claims about clients, colleagues, competitors or SSW.
The standards in this Code apply to work-related social media activity and online communities as well as direct communications.
Follow SSW's Work Health and Safety Policy and relevant local procedures. Report hazards, injuries, near misses and unsafe conduct promptly.
Respect human rights in business dealings and follow SSW's Anti-Slavery Policy. Raise concerns about forced labour, exploitation or other abusive practices involving SSW or its business relationships.
Report suspected breaches, unethical behaviour or pressure to act improperly promptly. You may contact:
Concerns involving Adam should go directly to Levi without CCing Adam. You do not have to confront the person involved before making a report.
Provide the facts you know and any relevant records. You do not need to prove misconduct before raising a genuine concern.
SSW will handle reports sensitively and share information only where needed to assess the concern, respond fairly or meet legal obligations. Absolute confidentiality cannot be guaranteed.
SSW prohibits retaliation against anyone who raises a concern in good faith or assists with an investigation. A concern that is not substantiated does not, by itself, indicate bad faith.
These internal channels do not limit anyone's legal rights to contact a regulator, law enforcement agency, adviser or other protected reporting channel.
SSW will assess concerns promptly and conduct a fair investigation appropriate to the circumstances.
Investigations will be handled by someone sufficiently independent of the matter. People affected will have an appropriate opportunity to respond, subject to necessary protective measures and applicable law.
Action will be proportionate to the findings and circumstances. It may include coaching, training, corrective action, a warning, dismissal or termination of a contract. Serious matters may also be referred to the appropriate authorities.
All action must comply with applicable law and contractual obligations.
Adam owns and approves this Code. State Managers are responsible for implementing it, explaining expectations, handling disclosures and responding to concerns.
Directors and managers must model the standards in this Code. Everyone covered by it is responsible for understanding and following it and seeking guidance when unsure.
Acknowledgement is required during induction or onboarding and whenever the Code is materially updated. There is no scheduled annual re-acknowledgement.
The Code will be reviewed when changes to laws, operations, incidents or feedback indicate that an update is needed.