Wilderness Internal Conduct Policy

Objective

To outline the expectations of behaviour of all of our team members whilst employed by or representing the company.

Background

Our company values and commonly accepted professional standards form the basis of the behaviours we expect from all team members. Overall the company expects that all team members, whilst employed: do not break the law; act towards colleagues and customers with honesty, integrity, and respect, and always represent the company in a positive and professional manner. This policy applies to all team members while working on our premises and/or from home or other locations and while representing our business and while using any company equipment including electronic devices. It specifically requires them to comply with what is outlined in this conduct policy. Failure to do so may result in formal disciplinary action being taken.

This policy, in conjuction with other company protocols, supersedes all previous company policies and protocols.

Policy

1. Serious misconduct
   • may include but is not limited to the following:
     • Falsification or misrepresentation of employment or company records
     • Theft, unauthorised possession or deliberate or careless damage of any company property or the property of any employee or customer
     • Unauthorised or unsafe use of company vehicles, equipment, resources, time, materials or facilities
     • Failure to ensure the company’s premises, property including vehicles and systems are secure
     • Any attempt to falsify or interfere with a testing process or test result
     • Disruptive behaviour that interferes with the functioning and flow of the workplace and/or hinders or prevents team members from carrying out their responsibilities
     • Discrimination, harassment and/or bullying, as outlined in section 3 of this policy
     • Threatening behaviour and/or bringing weapons on work premises
     • Excessive participation in rough and boisterous play while on duty or on work premises
     • Fighting or provoking a fight during work hours or on work premises
     • Committing a fraudulent act or breach of trust in any circumstances
     • Engaging in criminal conduct whether or not related to position performance
     • Sharing proprietary or confidential company information or posting any content online that is defamatory, derogatory, inflammatory, or which may bring the company into disrepute
     • Engaging in any online behaviour that puts the company, its systems, property, and/or people at risk including but not limited to opening emails from unknown senders, viewing adult content on work devices, downloading apps from outside official app stores, installing new applications without IT approval, and using social media for personal reasons on company time
     • Repeated breach of any company policy and/or protocol including team and departmental policies and protocols.
2. Suspension and investigation
   • The company may be required to suspend the team member from work to complete an investigation in relation to any matter that may concern the team member. In these situations, the team member will be consulted and any required suspension will be on the team member’s full pay.
3. Discrimination, harassment and/or bullying
   • The company does not accept any form of discrimination or harassment in the workplace or where the conduct negatively affects the working environment.
   • Unlawful harassment and/or discrimination because of gender, race, ancestry, physical disability, mental condition, marital status, age, or any other protected basis includes but is not limited to:
     • Verbal such as derogatory comments, unwanted sexual advances or comments
     • Visual such as derogatory posters, photography, drawings or gestures
     • Physical such as assault and unwanted touching
     • Online harassment including cyberbulling
     • Retaliation for having reported or threatened to report harassment
   • Team members who witness or are subject to harassment, intimidation, and/or bullying are required to report this to their leader or via the compliance helpdesk immediately
   • All complaints will be treated confidentially, investigated promptly and practical solutions will be taken to prevent any repetition of such behaviour.
4. Drug & alcohol use
   • The use, making, sale, purchase, transfer, distribution, consumption, or possession of drugs or alcohol on company property or in a company vehicle is prohibited. The use of alcohol in a company vehicle is accepted when the team member is covered by a Wilderness Motorhomes rental agreement.
     • The CEO may, at his sole discretion, authorise the consumption of alcohol on company property and at company events e.g. team day and Christmas parties, for special occasions
     • Team members who consume alcohol on company property and at company events do so under the understanding that they are responsible for their own behaviour and that irresponsible drinking may result in disciplinary action.
   • All team members must notify their team leader if they:
     • Suspect that another team member is adversely affected by drugs and/or alcohol.
     • Feel unfit to work due to the influence of drugs and/or alcohol.
     • Are prescribed medication that may affect their ability to work.
   • The company reserves the right to conduct searches for drugs or alcohol, including, but not limited to, searches of work vehicles, lockers, desks, packages, etc. which are on the company’s property or premises. Any drugs or alcohol found as a result of such a search will be confiscated and the occupant or user of the object searched will be subject to disciplinary action, up to and including termination of employment.
   • All team members are expected to report fit for duty for scheduled work and be able to perform assigned duties safely and acceptably without any limitations due to the use or after-effects of alcohol, illicit drugs, non-prescription drugs, prescribed medications, or any other substance.
   • The company may require a team member to complete a drug and alcohol test as per the terms set out in the team member’s employment agreement if their role is designated safety sensitive. The company may also require the team member to complete an alcohol and drug test where it is believed the team member shows signs of being affected by drugs, alcohol and/or has been involved in a workplace accident or near miss, is unable to perform their normal work safely, or has shown unreliability (e.g. absent or routinely late). This will be done following a discussion with the team member to provide the team member with the opportunity to comment.

   • When drug and alcohol testing may occur:

     • Pre-employment medical for safety sensitive roles: Any employment offer to a safety sensitive role may be made subject to a drugs and alcohol test.

     • Random testing: All team members in a safety sensitive role may be tested on a random basis. For random testing, oral fluid testing (saliva) may be the preferred method, as this gives an immediate result, is less invasive, and is cost effective. If there is a non-negative (failed) test result, a urine test will then be required for further analysis.

     • Post incident testing: All team members may be tested for the presence of drugs and alcohol where they are involved in:

       • an incident involving death or a serious harm injury

       • an incident requiring treatment by a medical professional

       • an incident or near miss that has significant potential to cause serious harm

       • an incident involving damage to vehicle, property, plant or equipment

     • Reasonable cause: Where a team member acts in a manner suggesting alcohol or drugs may be impacting their ability to work effectively and safely.

   • All drug and alcohol testing information is confidential. This includes the collection and destruction of the specimens after testing, the management of the testing records, and the communication of test results.

   • Rehabilitation is at the discretion of the company regarding the impact of drugs and alcohol in safety sensitive roles. Wilderness may refuse to refer the team member to such a programme, and instead treat the matter as one of serious misconduct.

   • Wilderness will make a return to work decision based on the nature of the team member’s role. If the normal role is declared “safety sensitive”, alternative employment may be considered. If no such alternative employment is available, the team member is not to return to any form of work until a further drug and/or alcohol test has been returned below the “cut-off” level. (Appendix D: Rehabilitation Procedures)

5. Formal oversight

   1. Wilderness is committed to ensuring that all organizational activities are conducted ethically and in compliance with local laws and company policies, and protocols.

   2. The Senior Leadership Team provides governance and oversight across the organization. The team monitors compliance, reviews reports of misconduct, and recommends corrective actions.

   3. Roles and responsibilities

      1. Board of Directors: Provides overall guidance.

      2. Senior Leadership Team: Monitors compliance, reviews and investigates potential breaches, and implements corrective actions.

      3. Department Head: Implements oversight mechanisms within their department and reports on compliance.

   4. Regular internal audits are conducted to assess compliance with organizational policies and regulatory requirements. Periodically, independent external auditors may also be engaged to assess compliance and effectiveness objectively.

   5. The organization will conduct regular risk assessments to identify potential areas of non-compliance and ethical concerns. Mitigation strategies will be developed and implemented to address identified risks and ensure continuous compliance with organizational policies.

6. Whistleblowing

   1. Whistleblowing is defined as reporting suspected or actual wrongdoing within or by the company. This may include but is not limited to:

      1. illegal acts

      2. regulatory violations or breaches of law

      3. health and safety risks or environmental hazards that are being neglected

      4. any other form of misconduct

   2. Team members are encouraged to report their concerns through the following channels:

      1. Team leader: Team members should report concerns to their immediate supervisor whenever possible.

      2. Senior Leadership Team: Team members may also directly report to the Senior Leadership Team via the compliance section on the helpdesk.

   3. Wilderness strictly prohibits retaliation against individuals who report concerns in good faith. Any form of retaliation, including dismissal, harassment, or discrimination, will be subject to disciplinary action. Whistleblowers who believe they have been retaliated against should report this to the Senior Leadership Team.

   4. All reports are treated seriously and investigated thoroughly, and the investigation results are shared with the whistleblower.

   5. All reports will be treated with the utmost confidentiality. The whistleblower's identity will not be disclosed without their consent, except where required by law. The company will make every effort to protect the whistleblower’s identity throughout the investigation process.

   6. While the company encourages reporting genuine concerns, it takes deliberate false reporting very seriously. Any team member found to have intentionally made a false report will be subject to disciplinary action.

7. Corruption

   1. Bribes and kickbacks

      1. Team members, contractors, and any individuals associated with the company are strictly prohibited from offering, giving, soliciting, or receiving any form of bribe, whether in cash, goods, services, or any other benefit. This includes any attempt to influence or be influenced by the actions or decisions of any individual or organization.

      2. Wilderness prohibits the acceptance or payment of kickbacks (any money, fee, commission, credit, gift, gratuity, thing of value, or compensation of any kind that is provided directly or indirectly to any party to improperly obtain or reward favourable treatment in connection with a contract or transaction)

      3. Team members are prohibited from accepting or offering gifts, entertainment, or other hospitality that could be construed as a bribe or an attempt to influence business decisions. Any gift or hospitality must be of nominal value and must not create an appearance of impropriety. Team members must report any offers or receipts of gifts or hospitality that exceed NZ$100 via the compliance section on the helpdesk.

      4. It is prohibited to offer, solicit, or accept any portion of contract payments or other financial incentives that are not explicitly detailed in the contract. All financial transactions and contract terms must be transparent, properly documented, and comply with applicable laws and company policies.

      5. Team members must promptly report any suspected or actual instances of bribery, kickbacks, or other forms of corruption via the compliance section on the helpdesk.

      6. The company reserves the right to pursue all available legal remedies against individuals or entities involved in bribery or corruption.

   2. Political contributions

      1. The company prohibits making any direct or indirect political contributions, including donations to political parties, candidates, or political action committees, without prior approval from the board of directors. This includes any financial support, provision of goods or services, or any other form of contribution intended to influence political activities.

      2. Any proposed political contribution must be submitted via the compliance section on the helpdesk for review and approval by the board of directors. The request must include the contribution's purpose, amount, and justification. Approval will only be granted if the contribution complies with applicable laws and does not conflict with the company’s values and interests.

   3. Charitable donations and sponsorships

      1. Charitable donations and sponsorships must align with the company’s core purpose and values.

      2. Directors must approve all charitable donations and sponsorships. Any donations or sponsorships exceeding NZ$10,000 in value must be approved by the board of directors and published on our website for public declaration.

8. Conflict of interest

   1. Team members must avoid any situation in which their personal, financial, or other interests could conflict or appear to conflict with their duties and responsibilities to the company or impact their judgment. This includes but is not limited to:

      1. Financial interests

      2. Family relationships

      3. Any other relationships that could influence or be perceived to influence an employee's objectivity.

   2. Any potential or actual conflict of interest must be disclosed via the compliance helpdesk as soon as they become aware of it or observe it. Retaliation against employees who report potential conflicts of interest in good faith is strictly prohibited.

   3. Team members must not have any financial interests in or engage in business activities with competitors, suppliers, or clients that could compromise or be perceived to compromise their ability to make impartial decisions in the company's best interest. Any ownership or interest in such entities must be disclosed immediately.

   4. Team members should not supervise, be supervised by, or be in a position to influence the employment conditions of family members or individuals with whom they have a close personal relationship. Any such relationships must be disclosed to ensure appropriate measures can be taken to prevent a conflict of interest.

   5. Before engaging in any outside employment, consulting, or other business activities, team members must obtain approval from the senior leadership team. Such activities must not interfere with the team member's ability to perform their duties for the company and must not present a conflict of interest.

   6. Team members must not use confidential or proprietary information obtained through their employment with the company for personal gain or to benefit others. Misusing such information constitutes a conflict of interest and is strictly prohibited.

   7. All board members are required to complete an annual conflict of interest questionnaire. This questionnaire will identify any potential or actual conflicts of interest. The completed questionnaires must be submitted to the board secretary annually for review and record-keeping. Failure to complete the questionnaire may result in disciplinary action by the Board.

   8. Actions to address actual or potential conflicts of interest may include, but are not limited to:

      1. Removing the individual from the decision-making process related to the conflict.

      2. Reassigning job duties to avoid the conflict.

      3. Requesting the individual to divest of the financial interests causing the conflict.

      4. In the case of board members, recusal from board discussions and votes related to the conflict.

9. Child labour and forced or compulsory labour

   1. The company strictly prohibits child labour and any form of forced or compulsory labour in our operations or supply chains.