Code of Ethics

Our Core Commitment @realty stands for uncompromising integrity and the highest ethical conduct. We are proud of the reputation we are establishing and we are determined to protect and enhance it. In a service business, the integrity that our brand represents is one of our most valuable assets.

From our Chief Executive Officer

Great companies are built on a foundation of integrity and respect. @realty is proudly building strong relationships with clients, customers, employees, Sales Associates, agents and local communities. We will strive to establish a corporate culture that is a differentiator in the marketplace.

We understand that the culture we will create is also one of the most important reasons why the best people want to work with us. To maintain these relationships, we aim to maintain the highest standards of ethical behaviour in our day-to-day activities.

Our Code of Business Ethics contains the policies that everyone who does business on behalf of our firm must understand and follow. Our Code cannot cover every possible ethical issue that may arise. But it does describe the basic principles that should guide our conduct. As a general rule, applying common sense, good judgment and integrity to the business issues you face will help ensure that your decisions are consistent with our values and our Code.

If you have any doubt about what to do in a given situation, seek guidance. Be sensitive to situations that could result in illegal or improper action. Communicate any possible violation of our ethical principles to a manager and submit a report through www.atrealty.com.au. Since your individual actions reflect on the firm as a whole, you must avoid any activities that may even look improper.

We stand for real value, and our outlook for the future is extremely promising. Our future success and good reputation will absolutely depend on the conduct of every person connected to the company. Being an engaged citizen is not just good policy, it is good business. Therefore, each one of us must adhere to both the letter and spirit of our Code – every day.

Nothing is harder to win, or easier to lose, than a company’s reputation for integrity. Your Directors fully support and remain actively engaged in the @realty Ethics program and the company’s social responsibility initiatives. We believe that current and prospective clients will recognise our integrity as the best in the business. That is great for all involved with @realty. We should never get complacent since one bad situation can erase everything that takes so long to create. Large and well-known companies have been brought to financial ruin by the unethical acts of just a few people. We must vigilantly guard against anything similar ever happening to us.

So we thank you in advance, the creators and protectors of the reputation for which our brand will be known.

Being recognised for integrity will help us, and you, win and keep the trust of our clients – and their business. Let the office manager know if you have suggestions for improvement to our Ethics program. Do yourself, your colleagues and our clients a favour by always conducting yourself with unquestionable integrity.

Executive Summary: Our Core Values

Responsibility to Employees

• Respect all individuals

• Do not tolerate abusive, harassing or offensive conduct

• Comply with privacy rules

• Think first, communicate second

• Do not engage in inappropriate or offensive content

Responsibility to Clients

• Comply with the best professional standards

• Protect confidential client information

• Beware of potential conflicts of interest

• Comply with legal obligations

• Use good judgment in all things

• Maintain appropriate licenses

Responsibility to Communities

• Strive to be a good corporate citizen

• Offer community service

• Respect local laws and governments

INTRODUCTION

We have adopted our Code to guide our colleagues in their responsibilities as they conduct business and it applies equally to all Directors, Staff and Sales Associates. We have structured our Code in the responsibilities we have to:

• Our colleagues

• Our clients

• The marketplace

• The communities where we are active.

   

The Spirit of our Code

We must strive to comply with the spirit of the Code and not just its basic rules. @realty recognises that compliance with our Code may sometimes place us in a less competitive position. However, complying with the Code is of greater long-term value to the company and its clients, employees and sales associates than any benefit that may be gained by compromising our integrity in the short-term

Our Code does not cover every possible situation we may encounter. Instead, we intend it to be a guide that highlights key issues, to help us use good judgment and to reach decisions that we can take pride in.

Role of our Directors

Our Directors fully support our Code and are subject to it. We will regularly report on the overall operation of our Ethics program and any significant individual violations of it.

Reporting Code Violations

You may always contact the office manager with any questions about our Code by emailing to  with any concerns or questions or to report a possible violation of our Code. You can do so anonymously, although anonymous reports are generally more difficult for us to investigate and resolve.

Vendor Code of Conduct

You must take reasonable steps to ensure that the vendors, buyers, consultants and other agents you engage to represent or provide services to or for @realty, or for the benefit of our clients, are carefully selected and comply with our standards of fair trade.

No Retaliation Policy

@realty will not retaliate against any staff or a sales associate who reports, in good faith, any potential Code violation. “Good faith” means you have reported everything you know and you believe that it is true. We will not tolerate retaliation, and we take claims of retaliation very seriously. If you believe that you or a fellow co-worker hasbeen retaliated against for reporting an ethics violation, you should immediately contact the office manager.

@realty strives to conduct its business in compliance with the applicable laws, rules and regulations of Australia and the state and communities in which we operate.

Effect of Local Laws 

We intend our Code to apply consistently to all of our employees and sales associates. However, should a provision of our Code violate an applicable law or regulation within Australia, then we will consider that provision to be void and of no force or effect.

Our Responsibility to Staff and Sales Associates

As we seek to attract and retain the best people in the property industry, our staff and sales associates are our most valuable asset. Accordingly, we should strive to treat each other with respect and fairness, and we encourage an atmosphere of open communication and honesty.

Policy against harassment

Abusive, harassing or offensive conduct, whether verbal, physical or visual, is unacceptable. Examples include:

• derogatory comments based on racial, ethnic or physical characteristics, religious beliefs, age, gender identity or sexual orientation

• deprecating remarks concerning a person’s disability, and

• unwelcome sexual advances.

   

Respect for all individuals

We should treat each other just as we wish to be treated ourselves, and we must behave appropriately and professionally with our colleagues, clients and vendors inside and outside the office. We respect the differences of our people. We encourage diversity within our company, because broader perspectives will enhance the value we bring to our clients.

Privacy

We will respect our staff and sales associates’ rights to privacy as enshrined in the laws of Australia. We will also take adequate measures to ensure the security of staff and sales associate’s data. That said, in order to efficiently and effectively operate our company, we need the ability to process and transfer data about our staff and sales associates, both internally and externally, for the purposes of complying with applicable laws, processing payroll and administering other human resources requirements. By their employment with us, our staff and sales associates agree to the use of their data for those and other essential purposes. Our staff and sales associates have the ability to review and correct inaccuracies in their data.

Personal relationships

As the pillar of our company culture, we place great value on mutual respect and professional interactions between our staff and sales associates. Therefore, it is inappropriate for our personnel to have an intimate personal relationship beyond simple friendship with those who are subject to their supervision, or with whom they have a reporting relationship. This is also the case with any outside party with whom they have dealings as representatives of @realty (including clients, contractors and vendors).

Safety and health

We are all responsible for maintain a safe workplace by establishing and following safety and health rules and policies, and by exercising good judgment and commonsense. Staff must immediately report accidents, injuries and unsafe working conditions to the office manager.

Use of company communication systems

We understand the need for and permit the occasional use of our communications systems for personal reasons. However, such personal use of the firm’s communications systems is a privilege, not a right and the company may remove that privilege at any time. The company may monitor, review and store any message sent or received on our communications systems. You should not have any expectation of privacy with respect to these communications.

Personnel must not use our communications systems to view, receive or send inappropriate materials or materials that may be offensive to co-workers, and must always exercise good judgment when communicating on behalf of the firm, which means you, should communicate with professionalism. A good rule to follow always is to assume that whatever you communicate may someday be made public, in which case you will not want to have said or written something that will damage your reputation or that of the company. This also applies to any client or vendor communications system to which you may be granted access to as a representative of the company. Remember: think first, communicate second.

Our Responsibility to Clients

We pride ourselves in placing our clients’ best interests first in all that we do. We must always strive for exceptional client satisfaction through the highest level of service. Without the loyalty and support of our clients, our business cannot succeed.

Client information

We should protect sensitive, private or confidential client information just as carefully as we protect our own. This includes understanding and abiding by the terms of any applicable contracts with our clients. We should not discuss or disclose client information either inside or outside of @realty unless we know we have been properly authorised to do so. If asked by the media to comment on a client matter, you should make sure you have the client’s approval first, and you should also review your proposed responses with social media administrator.

Professional standards and conduct; quality assurance

We must comply with the local professional standards in the states where we do business. When on our clients’ premises, we must behave appropriately and professionally, project an image that will reflect positively on the company, and follow our client’s own internal rules. If the company policies are more onerous than a client’s policies, you must still follow the @realty policies.

Service quality for our clients is a key to @realty’s success. Simple steps – proof reading; using updated templates; obtaining peer reviews; and confirming scope, client expectations, and contractual obligations – will significantly improve service quality and avoid costly mistakes or reputational damage. Each of us is responsible for assessing his or her own actions in order to implement the service quality steps that will allow us to perform at our best.

Client conflicts of interest

We will not act for a client where there is a potential conflict of interest with any other @realty client, or with the company itself, without first disclosing the potential conflict, and receiving each client’s written confirmation that the client nevertheless wishes us to continue. You must refer any unresolved conflict of interest to the office manager. The office manager will, with any necessary guidance from the directors, decide whether and under what circumstances @realty can continue to act upon those client instructions.

Licensing

Australia requires special licenses to engage in real estate transactions, financial services businesses and other professional or technical services. Some licenses apply to the Company and some must be held by individual staff and sales associates. We must all only perform services for which we are licensed.

Our Responsibility to the Marketplace

Anti-trust, fair dealing and competition

We must deal fairly with @realty’s customers, suppliers and competitors. We do not take unfair advantage of anyone else through manipulation, concealment, disparagement, abuse of privileged information, misrepresentation of material facts or any other unfair dealing practice. We must comply with applicable anti-trust and competition laws (including those which relate to price discrimination, price fixing, restraint of trade and monopolies) in Australia.

In all of our business dealings, we should:

• Compete vigorously and with integrity.

• Not discuss pricing or any matter affecting pricing with our competitors with the

  intention of price fixing, fee fixing, setting minimum prices or establishing other

  business terms in a market where we compete.

• Make clear to all suppliers that we expect them to compete fairly for our

  business.

• Build long-term relationships with our clients by demonstrating honesty and

  integrity; and

• Engage in accurate and truthful marketing and advertising. It is never acceptable

  to use deliberately misleading messages, omit important facts, or make false claims about @realty or our competitors.

While gathering information about our competitors is a legitimate business activity when done lawfully and ethically, it is never appropriate for our people to obtain information about a competitor through improper means, such as theft of documents, misrepresenting one’s identity, inducing an employee of the competitor to divulge confidential information, or gaining improper access to a competitor’s confidential information, directly or through third parties.

Expenditures

Ensure that the business expense is valid, that goods or services have been received consistent with specifications, and that the invoice meets legal requirements and otherwise complies with our purchasing policies.

Without full internal disclosure and receipt of appropriate approvals, you may never knowingly cause or direct the company to purchase goods or services from a vendor that is owned or controlled by @realty staff, or a sales associate, or a relative of company staff or a sales associate. This applies to goods or services of any kind, for @realty or for any of our clients.

The company purchases goods and services only on the merits of price, quality, performance and suitability. You may not enter into any improper or illegitimate transactions, or transactions that have the appearance of impropriety or illegitimacy, or that are intended in any way to misrepresent the accuracy of reports or results of any party to the transaction.

You must never request or accept any gift (whether in cash, entertainment or other consideration such as free goods or services) or any inducement from any vendor or subcontractor from which you are purchasing goods or services on behalf of the company or any of its clients. The only exception to this rule is that you might accept token gifts, business meals or entertainment of small or nominal value if refusal would be embarrassing from a business perspective in your ‘good faith’ judgment and if the gift or entertainment is not intended, nor is taken, to change what the best purchasing decision would otherwise have been.

Consistent with the legal requirements in Australia, we must also carefully select the individuals we hire to work for us. This includes taking reasonable steps to assure ourselves that they have provided correct information on their applications for employment and that there is nothing in their backgrounds that might make them undesirable as employees.

We will not do business with others who are likely to harm @realty’s reputation. For example, we will avoid doing business with any company or person who intentionally and/or continually violates the law. We will not do business with any company or person where doing so would be prohibited by applicable law or regulations. Finally, we will not hire a third party to perform any acts prohibited by law or prohibited by our Code.

We must carefully consider the clients, vendors, agents, consultants, subcontractors and alliances with which the company associates.

You are responsible for familiarising yourself, to an extent appropriate under the circumstances, with the background, reputation and standards of conduct of:

• Clients

• Potential clients

• Vendors, and

• Those companies or people that we engage to act on our behalf or otherwise do

  business with.

  Protection of @realty information, ideas and intellectual property

  Information, intellectual property and innovative ideas are valuable @realty assets. We must identify, manage and protect these intangible assets since their disclosure to competitors can damage the company’s competitive advantage and may therefore be harmful to our business. Information the company maintains that is confidential and otherwise not publicly available, and that must be protected from misuse, includes but is not limited to:

• Acquisition and divestiture plans

• Internal financial information

• Proprietary technology and software

• Proprietary research and data

• Customer information, including pricing information, profit and loss models,

  prospects, requests for proposals and legal documentation

• Client lists, and portfolio and property information

• Business strategies and models

• New product and marketing concepts

• Employee records

• Employee compensation and compensation plans

• Litigation strategies and information

• Processes, trade secrets, business know-how and best practices that are

  intended to provide competitive advantages

• Risk management and insurance information and

• Confidential information that we maintain on behalf of clients.

   

It is appropriate to disclose the firm’s confidential information only when it is necessary to do so for valid business purposes or when we are legally required to do so in the case of litigation. Even when you are disclosing our confidential information for a valid business reason, it will typically be a good idea to protect the information by the use of a confidentiality agreement.

In the event you leave the company, you have a continuing obligation not to use the confidential information you obtained while you worked at the company. If you do so, you (and your subsequent employer) may be liable to the company for damages that result from it. Additionally, there are laws that have criminalised trade secret theft that include substantial fines for corporations and jail terms for responsible individuals.

Prior employment obligations

We respect the continuing obligations that new and prospective @realty staff and sales associates may have with their prior employer. These may include restrictions on use or disclosure of confidential or proprietary information and restrictions on the incoming staff or sales associate’s services.

We expect all of our people to uphold their contractual, confidentiality and fiduciary obligations to their prior employers and to notify @realty immediately if they are bound by any such restrictions. As a condition to signing an employment agreement / contract with us, incoming staff and sales associates must resolve any impediment to the employment duties for which the company has hired them.

Treatment of our brand

The @realty name, brand identity and logo (and any other service marks we may adopt to identify our businesses) are powerful and valuable assets that differentiate us from our competitors. Our words and actions as @realty people, and the business decisions we make, must support and advance our name, brand identity, brand positioning and personality. We go to market with one brand, and we must treat the @realty name and brand in all activities and transactions in a consistent manner. We should never grant to third parties any rights to use our name or brand except with appropriate approvals, legal review and compliance with our naming and brand policies.

Document retention

You must maintain the firm’s business records (which include physical documents as well as documents and e-mails that are stored electronically) in accordance with applicable laws. Documents (both in physical and electronic form) that are not necessary to memorialise any transaction of our business should not be considered to be business records and should be destroyed rather than saved.

You must never knowingly destroy company records that may relate to on-going litigation or if you have been told by the firm’s legal advisors that you must retain certain documents as part of a ‘litigation hold’ requirement.

Receipt of legal documents; reporting and managing litigation matters

If you are served with a legal document, it demands immediate attention, immediately inform our office manager and your General Counsel and promptly forward the document to both.

Any significant claims made or threatened by clients or other parties against @realty, even if not contained in legal documents, must be treated in the same manner. You may not manage any actual or potential litigation matter or dispute without the involvement of one of the lawyers representing @realty.

Our Responsibility to Communities

Our company plans to operate extensively, from the largest cities to smaller local markets. In all locations, we should make every effort to improve the communities in which we work.

Corporate political contributions

Contributions to political parties, candidates or causes may be specifically regulated by the laws of Australia and local jurisdictions in which we will conduct business. You must not make any contributions to political parties, candidates or causes in the name of @realty because you may inadvertently be causing the firm to violate those laws, which can carry serious penalties. You must make sure that any political contributions proposed to be made on behalf of the company and in which you may be involved are made with the appropriate internal approvals and legal review, have a valid business purpose and are made in compliance with applicable laws.

Community service

@realty, its staff and sales associates may provide generous financial and other support to many worthwhile community programs. You are free to support community charity and political organisations and causes of your choice as long as you do not represent your views and actions as those of @realty. In the performance of your community services, you should not use any confidential, proprietary or trade secret information of @realty, its clients or vendors. Your outside activities should not interfere with your job performance. No staff or sales associate may coerce another staff or sales associate to support a cause that is contrary to a personal belief or to contribute to or support political, religious or charitable causes. You should also contact the social media administrator before making any public statements in the context of any community services. There may be appropriate situations when we will permit staff to use company time to pursue charitable or community service, and this is a matter for you to discuss with the office manager, whose approval you should obtain in advance.

Reporting and Corporate Governance

Limits to confidentiality

The company understands that there may be cases when you might want to report concerns about our Code anonymously or with confidentiality. To the extent possible, the firm will keep reports confidential. If you do not identify yourself, however, the firm might not be able to respond appropriately to your concern. Further, there may come a time when the firm cannot proceed with the investigation without obtaining additional information from others or without disclosing information that you provided. In all events, we will use our best efforts to investigate Code compliance matters professionally and with respect for all concerned. It is the company’s policy to cooperate fully with any valid governmental investigation and to provide any information in the firm’s possession that is appropriate to such an investigation.

No retaliation

If you report a possible violation of our Code in good faith or ask questions about our Code, you will not be subject to retaliation for doing so. “Good faith” does not mean that a reported concern must be correct or turn out to have been a Code violation, but it does require that you are truthful when reporting a concern or asking a question. Retaliation, retribution or harassment against any employee who in good faith asks any questions or raises any concerns regarding our Code is strictly prohibited.

With many legal and ethical issues, it is easy to determine right from wrong. If the law or professional standards clearly dictate a course of action, the answer is simple. But sometimes the questions and answers are not so clear. It is impossible to prepare in advance for all possible problems. So the best course of action is to understand the way to solve such problems. When difficult ethical issues arise, here are some steps you can take to try to resolve them successfully.

•  Get all the facts: Without a thorough understanding of the facts, it is impossible to reach an appropriate solution.

• Ask yourself: What am I specifically being asked to do?

• This should aid you to focus upon the specific question facing you and the alternatives you may have.

• Clarify your responsibility

• Most situations we face involve shared responsibility. Are all the parties informed? By getting the other appropriate parties involved, and discussing the problem, a good course of action often will come to light.

• Is it fair?

• When the problem is not a clear-cut matter of law or company policy, this simple question is often a useful guide. If a course of action seems unfair, ask why it seems unfair and who specifically may be wronged. In many cases, the best course for ethical purposes is also the one that seems fairest to all concerned and is fully disclosed to everyone involved so that their questions and concerns may be taken into account.

• How will it look in the media?

• A useful consideration is to think about how you would feel if the matter were disclosed in the newspaper or on the Internet, and your client, manager or a family member was to read it. If it would embarrass you or the firm, there is a good chance there is something unethical about it.

• Discuss the problem with the office manager

• This should be considered during any of the above steps. In most cases, the office manager will have broader experience and will appreciate being brought into the decision process at an early stage. If you are uncomfortable discussing the problem with the office manager, you may proceed directly talking with a director of the company.

Our Core Commitment

@realty stands for uncompromising integrity and the highest ethical conduct.

We are proud of the reputation we are establishing and we are determined to protect and enhance it. In a service business, the integrity that our brand represents is one of our most valuable assets. 

Our Core Commitment @realty stands for uncompromising integrity and the highest ethical conduct. We are proud of the reputation we are establishing and we are determined to protect and enhance it. In a service business, the integrity that our brand represents is one of our most valuable assets.

CODE OF ETHICS

Creted: 30.01.2014

Updated: 1.02.2018