Code of Conduct

Archipelago Asia Pacific Pty Ltd (AAP) Code of Conduct

Approved: Gord Snell, Director



This Code of Conduct sets out standards of conduct applicable to Archipelago Principals, Employees and Associates, and is to be read along with any standards or codes of any employing organization or agency, the law, and any customary practice relating to individual or company behavior.


  • In undertaking your duties you must not deliberately contravene the law or relevant administrative requirements, policies and
  • You must not act in any way to cause intimidation, harassment, verbal abuse, discrimination, or disadvantage.
  • You must exercise a high degree of care and diligence in carrying out your functions
  • You must show fairness and equity in all your dealings.
  • You must consider issues consistently, promptly and fairly with due regard to project milestones and deadlines.
  • You must deal with matters in accordance with established procedures, and in a non-discriminatory manner.
  • You must not harass, discriminate against, or support others who harass and discriminate against any person, including but not limited to race, religion, disability, medical condition, sex, sexual preference, pregnancy, age, or marital
  • You must always conduct yourself in a way that does not bring AAP or its employing organization or agency into


You have a duty to act honestly, to declare any interests that may affect your duties, and to take steps to resolve any potential or actual conflicts. You must: obey the law; follow policies and procedures; observe this code of conduct; disclose actual or potential conflicts of interests; and exercise delegated power strictly in accordance with the reason and limits conferred.


You must conduct yourself with the utmost integrity and never place yourself under any financial or other obligation to any individual or organization that might influence you in the performance of your role.


You have a duty to make decisions and provide recommendations and advice in an impartial way, considering only relevant matters.

Accountability and Transparency

You are accountable for any decisions you make and any recommendations or advice you provide. You are required to conduct your role in a transparent way within the terms and conditions of any contract or agreement.


In all matters you must act with due probity showing the qualities of strong moral principles, honesty and decency, ensuring all processes are fair and transparent to the fullest extent.

Openness and Confidentiality

You have a duty to be as open as possible when going about your work, within the constraints of any contract or agreement – whether written or verbal, including explaining reasons for any decision, advice or recommendation, co-operating to the fullest extent possible with the employing organization or agency, and providing information and communications clearly. You are required to keep information that is not in the public domain confidential other than when required to make it known by law.


You must treat others with respect at all times. You must not use derogatory terms towards others, and you must observe the rights of other people. You must treat all people with courtesy when undertaking your role.


You must observe legitimate direction from leaders and promote and support leadership through examples of ethical behavior. You must treat others as you would have them treat you.


You have a duty to make decisions and provide recommendations and advice in interest of the employing organization or agency. You must not act to gain future financial or other benefits for yourself, your family, friends or business interests.


You have a duty to act at all times in a manner that ensures your health and safety and the health and safety of others with whom you are working. Any actions that might cause physical or emotional harm are not to be tolerated.


You have a duty to report any breach of this code, or any other behavior you may believe is inappropriate or unlawful either to a company Director, or to the appropriate law enforcement agency.


A conflict of interest exists where a reasonable and informed person would perceive that you could be influenced by a particular set of circumstances in the exercise of your duties, in particular where a potential pecuniary interest can be identified to you, a partner, spouse, friend or family member, no matter how remote.

It is your duty to avoid or appropriately manage any actual, potential, or perceived conflicts of interest as soon as they arise. The onus is on you to identify these circumstances and to take the appropriate action to manage the situation.


A gift or benefit includes any item greater than $10 in value, for example free meals, beverages or refreshments, invitations to attend concerts, social, cultural or sporting events, and gifts of alcohol, ties, scarves, caps, etc.

No amount of potential value of gift or benefit is too small to be considered a potential inducement and you are required to advise and record by email to a company Director such benefit(s) if there is any reasonable potential for a conflict of interest to be perceived. Any email is to be titled – “DECLARATION OF GIFT OR BENEFIT”.


Any complaint can be addressed to or in writing to:

Archipelago Asia Pacific Pty Ltd

Unit #1, 6 Phipps Close, Deakin, ACT, 26