Global Code of Conduct
Message from the Chief Executive Officer
When PMY Group (PMY) was founded in 2009, technology was disrupting industries globally and venues and major events were grappling to understand the benefits of, and business case to support, investment into technology transformation.
We saw a simple need; to combine technical expertise with commercial and operational acumen to provide clients with an independent ‘one-stop shop’ supporting the design, procurement, implementation, and commercialisation of technology.
As technology rapidly evolved so too did the need for our service and the focus of our technology solutions business was established.
This Code of Conduct (the Code) promotes a common understanding of how we will conduct our business and sets out PMY’s expectation of the conduct of its workforce in striving to achieve the company’s mission.
PMY now operates in many countries, continuously developing the scope and breadth of its services, embracing new industry sectors throughout Asia Pacific, North America, the United Kingdom, Europe and the Middle East.
To ensure that we are fulfilling our corporate social responsibility obligations and are continuing to maintain high ethical standards, PMY has prepared the below Code to guide its business across a changing and global landscape.
This Code outlines how PMY approaches current social issues, including in respect of sustainability and human rights.
Paul Yeomans
Chief Executive Officer
PMY Group
Throughout this Global Code of Conduct, “we”, “PMY”, “us” “its” and “our”, refer to PMY Group Pty Ltd and all related bodies corporate, including PMY (ANZ) Pty Ltd, PMY UK Holdings Limited, PMY USA Holdings. Inc., PMY Capital Holdings Pty Ltd and Vision S&E Holdings Pty Ltd, and all subsidiaries. A reference to an “employee”, “employees” or “people” in this Global Code of Conduct means all personnel including directors, officers, secondees, agents, labour hire workers and any person or company engaged or contracted under a contract for services.
Vision/Mission
We strive to be the global leader in our field. We partner with our clients to make transformational change through strategy and investment related to technology.
We are a company that provides valuable services and facilitates amazing outcomes for world-class events and venues, and our culture reflects this. We work in a flexible way to ensure that our people can fit work around life commitments, personal needs and everything in between.
We are a future focused company, that is constantly striving to improve as we continue our global growth.
At PMY, we believe in promoting diversity and inclusion. It is important to us that our people are included and that their opinion matters. We do not discriminate on the basis of race, religion, gender identity or expression, sexual orientation, age, marital, or disability status.
Our Values
We conduct all aspects of our business in a manner that reflects our core values.
Professional
We adhere to the highest professional standards and are committed to delivering quality outcomes for our clients.
Dynamic
We are creative, pragmatic and driven by the pursuit of excellence.
Collaborative
We care about our clients and each other and believe in sustaining a positive, mutual and enjoyable working environment.
Business Partners and Third Parties
At PMY, we aim to only work with business partners who embrace standards of behaviour consistent with those of PMY. As such, we expect our business partners (including contractors and sub-contractors, distributors, suppliers, licensees or other types of business partners) to observe and comply with this Code when producing or distributing products for, or when providing services to PMY.
We only work with reputable third parties. Acting with legitimate business purposes, we only ever use legitimate funds. We require all third parties to recognise signs of potential illegal activity, like offers to pay in cash, unusual fund transfers or unusual payment terms and act accordingly.
Compliance with Laws and Regulations
All our employees have the responsibility to deal fairly with each other, their customers and suppliers. Our employees are expected to and must comply with all laws, regulations and rules that are applicable to PMY. This includes all anti-bribery, insider trading, health, safety and environmental laws and personal data protection laws.
It is expected that PMY employees will not engage in any anti-competitive trade practices such as discussing tenders or prices with competitors or agreeing with competitors with whom to deal or not deal. All employees must reject and report, to the Chief Executive Officer or General Counsel, any attempt to collude on tenders or to engage in any anti-competitive conduct such as price-fixing, and all employees must ensure all agreements or arrangements with competitors are reviewed beforehand by the legal department.
PMY is committed to ensuring that its employees do not take any unfair advantage of anyone else through manipulation, concealment, abuse of confidential information, misrepresentation of material facts or any other unfair dealing practices.
Insider Trading
In some circumstances, PMY employees will have access to material, which is not public, that contains confidential information relating to PMY and its related bodies corporate. When these situations arise, PMY employees are not permitted to use or share the information for securities trading purposes or for any other purpose except the conduct of the companies’ business.
Anti-Bribery and Corruption
PMY is committed to operating in accordance with all applicable laws and regulations in accordance with the highest standards of ethical behaviour at all times. As part of this commitment, PMY prohibits any activity that seeks to bribe or otherwise improperly influence any individual or entity in the public or private sector, to act (or omit to act) in a way that differs from the proper performance of their role of function. Bribery and corruption has a detrimental impact on business by undermining good governance and distorting free markets.
PMY has a Global Anti-Bribery and Corruption Policy in place which applies to all employees, who are required to comply and familiarise themselves with its contents.
Respecting Human Rights
PMY is dedicated to conducting its business in accordance with the highest standards of integrity and uses its best endeavours to integrate ethical and socially responsible practices into all aspects of its operations.
At all times, PMY complies with state, federal and international laws applicable to its business.
PMY respects the protection of human rights internationally proclaimed in the Universal Declaration of Human Rights, and the fundamental principles and rights at work which recognise:
• freedom of association;
• the right to collective bargaining;
• the elimination of all forms of forced or compulsory labour;
• the abolition of child labour; and
• the elimination of discrimination in respect of employment.
Human Trafficking and Modern Slavery
PMY respects the inherent dignity and the human rights of all its people, in particular in relation to the fundamental freedoms and rights at work. PMY has a zero-tolerance policy against all forms of human trafficking, modern slavery and related activities. PMY is committed to protecting its people’s rights and is against the trafficking of any person.
Safety
PMY is committed to a workplace of zero harm.
The Board of Directors of PMY recognise and accept the responsibilities placed on them as a 'person conducting a business or undertaking’ by the Health and Safety Acts and Regulations of each State and Territory of Australia, as well as globally.
PMY considers the health, safety and welfare of employees, contractors and of persons other than employees who may be affected by our activities to be of paramount importance, and that creating and maintaining a healthy and safe working environment is a prerequisite to achieving the Company’s objectives. To this end, PMY is committed to achieving the effective implementation of PMY’s Health and Safety Policies.
Conflicts
PMY employees must avoid any conflicts of interest. If an employee becomes aware of any potential or actual conflict of interest, or if the employee is uncertain whether a conflict exists, or if they become aware that a bribe or improper inducement has been offered, the employee must report the matter to their relevant manager, CFO or General Counsel.
A conflict of interest may exist where an employee of PMY has:
a) a financial interest in a transaction or a matter with which PMY is involved;
b) friends or relatives who have a financial interest in a transaction or a matter with which PMY is involved;
c) directorship/management/ownership or part ownership/shareholding greater than 5% of an external enterprise that PMY engages or contracts with;
d) engaged a contractor or supplier to work for PMY on non-commercial terms for a personal job or under circumstances where they are a decision maker or influencer in the award of work by PMY to this supplier or contractor;
e) secondary employment, business, commercial, or other activities outside the workplace which impact on an employee's duty and obligations to PMY; and
f) received, or is aware of, an offer of an inducement.
Whistleblower Protection
PMY empowers and encourages its employees to report any breaches of this Code or unethical conduct in accordance with PMY’s Whistleblower Policy.
Breaches of this Global Code of Conduct
Any determination about whether there has been a breach of this Code will be made in accordance with any other relevant PMY policies and procedures, and after considering all of the circumstances, including any explanation provided by those involved. Where there has been a breach of this Code, disciplinary or other action may be taken, up to and including termination of an employee’s employment.
Revision of this Global Code of Conduct
This Code will be kept up to date, particularly as the business changes in nature and size. To ensure this, the code and the way in which it has been implemented will be reviewed annually.
Last updated: December 2023