Statement of Business Ethics

Doing business with McCullough Robertson

McCullough Robertson Lawyers and its related entities including McR Defence and Allegiant IRS (referred to in this document as weus or our), are committed to responding to the needs of our clients and conducting business in a safe, sustainable and equitable manner, consistent with all Australian and international laws, regulations, codes and standards relevant to our work.

This statement sets out ethical principles by which we abide in all our dealings.  This includes internal dealings with our colleagues, but also our external interactions – such as with our clients, external professional colleagues, our suppliers, the environment and the communities in which we live and work.

Our business partners

We value and are committed to forging strong, long term and collaborative relationships with all people and organisations we do business with, including our third party suppliers (collectively referred to in this document as our business partners).

We expect our business partners to also abide by the principles outlined in this document, and to ensure their own business partners do so as well.  This expectation is embedded in our procurement and engagement processes.

We are committed to working with our business partners to enhance and develop their understanding of, and support their compliance with, these principles.

People, inclusion, health and safety

We support responsible labour practices that contribute to the development of fair, safe, supportive and inclusive workplaces.  Human rights (such as those set out in the Universal Declaration of Human Rights), must be protected, and we are dedicated to the active identification and management of human rights issues.

We believe that everyone benefits from the creation of inclusive and diverse workplaces, free from bullying, harassment or any discrimination prohibited by law – including discrimination on the basis of gender identity, age, religion, disability, ethnicity, cultural affiliation or sexual orientation.

All people are entitled to fair and appropriate pay, benefits and working conditions.  We are committed to encouraging gender equality across our supply chain.  We and our business partners must comply with Workplace Gender Equality legislation and have appropriate and supportive processes and policies in place.

In no circumstances will we engage in or facilitate any form of child labour, or forced or involuntary labour.  We strictly comply with our obligations under Australian Modern Slavery legislation.

We are also committed to maintaining healthy and safe work environments in all of our places of work, and complying with all relevant health and safety laws.

Environmental sustainability

We recognise the importance of environmental sustainability and its critical connection to our people, clients and the communities in which we live and work.

We are dedicated to acting responsibly by minimising and managing any adverse environmental impacts of our business operations, and strictly complying with all relevant laws, regulations, codes and standards.

Community and reconciliation

We are dedicated to building collaborative relationships with communities by respecting local interests, cultures and beliefs.

We recognise and acknowledge the unique position of Aboriginal and Torres Strait Islander Peoples in Australia’s culture and history; including as the first owners of the land and waters.

We are committed to reconciliation, consistent with our Reconciliation Action Plan, published on our website.

Confidentiality and privacy

We understand the critical importance of maintaining the confidentiality and privacy of information with which we are entrusted, and strictly comply with our obligations in this regard (including, in relation to our legal services, those obligations under the Australian Solicitors Conduct Rules).

The Privacy Act 1988 (Cth), Australian Privacy Principles and registered privacy codes govern the way in which we must manage personal information.  Our Privacy policy is published on our website and sets out how we collect, use, disclose and otherwise manage personal information.

Anti-fraud, corruption and bribery

We are fundamentally opposed to all forms of fraud, corruption, and unethical financing or facilitation, including bribery, extortion, and corruption.

We will only accept a client’s instructions if those instructions are lawful, and we will not allow our business to be used for any unlawful purpose.

We are dedicated to compliance with applicable anti-corruption and anti-bribery laws including the Criminal Code Act 1995 (Cth), the Bribery Act 2010 (UK) and the Foreign Corrupt Practices Act 1977 (US).

We will never give or receive (directly or through an intermediary) any gift, bribe or other form of inducement, in order to facilitate any improper or illegal preferred treatment (in our favour, or in favour of someone else) in breach of any applicable laws, or policies of our clients.

International trade controls and sanctions

We comply with international sanctions, including those imposing import and export controls.

We will not do business with individuals or entities that are subject to international trade sanctions or financial restrictions implemented by nations and international organisations such as the European Union and the United Nations.  We also will not assist any proposed transaction where there is any doubt, on some other basis, about the legality or propriety of a proposed transaction.

Anti-money laundering and counter‑terrorism financing

We are committed to compliance with all applicable anti‑money laundering and anti-terrorism laws.

We carry out robust enquiries to ensure that we do not facilitate any money laundering or terrorist financing activity.

Conflicts of interest

We acknowledge the critical importance of ensuring we are able to provide objective and proper representation of our clients, without any conflict of interest.

We have robust systems in place to ensure that we avoid or appropriately manage any potential, perceived or actual conflicts (arising due to either personal or business relationships).  In relation to our legal services, this is done strictly in accordance with the Australian Solicitors Conduct Rules.

Anti-competitive conduct and insider trading

We are committed to upholding fair, ethical and open competition.  We will not participate or assist in price fixing, market sharing or other cartel conduct.

We acknowledge that we are a trusted advisor to companies whose shares or other financial instruments are traded on regulated markets, making us privy to market sensitive information.  We will never engage in, or facilitate, insider trading (whether directly or indirectly).

Proactive risk management

We have a robust and proactive risk management framework.  We understand that the sooner any potential risks or breaches are identified and notified, the better the potential solution or impact for all concerned.  We have a whistle-blower policy in place to protect people who raise concerns in good faith.

We expect our business partners to also proactively manage and mitigate risks.  This includes notifying us as soon as possible of any risks or breaches of the principles and obligations in this document, and cooperating with any of our compliance audits or investigations.