Our Code of Conduct

Our promise
to each other,
creating better
outcomes for all
 2

Content Welcome 03 How we do Business 22

Welcome to Woolworths Group 03 How we do Business 23

Being a Part of Our Team 05 Navigating Conflicts of Interest 25

Being a Part of Our Team 05 Using Information Technology 26

Purpose 06 Personal and Confidential Information 27

Values 07 Food Safety 29

Ways of Working 08 Preferred Dress 30

Respectful Workplace 09 Expectations of our Leaders 31

Diversity & Inclusion 10 Expectations of our Leaders 32

Creating a Respectful Workplace 11 Questions and Help 33

Identifying Inappropriate Behaviour 12 Questions, Speak Up and Help 34

How we Act 15

Our Safety 16

Team Benefits 18

How we use Social Media 19

Opportunity with Media 21

 3

Code of Conduct
Wooloworths Group
1

Welcome

Welcome
to Woolworths 2

of Our Team
Being a Part
Group 3

Workplace
Respectful
To be part of Woolworths Group is to To make Woolworths Group the best
be part of an amazing team, guided by place to work and shop, we’ve set out our
a shared purpose of creating better expectations for us all to follow. Whether
experiences together for a better you’ve been with Woolworths Group for
tomorrow. 180,000 hearts and minds,
turning everyday actions into moments of
years, or you’re just beginning your journey,
it’s important that you understand and
4

Act
How we
meaningful impact—always ready to care follow these expectations. We all have a
for our customers, the communities we role to play if we want to be better together,
serve and, most importantly, each other. and it’s our collective engagement and
participation that will make Woolworths
Group the best it can be. Thank you for
joining us on our journey.
5

Business
How we do
With respect,

– Brad Banducci 6

Expectations
Leadership
7

& Help
Speak up
Questions,
Our Code of Conduct

Being a Part
of Our Team
 5

Code of Conduct
Wooloworths Group
Being a Part
of Our Team 1

Welcome
This Code of Conduct outlines what is
expected from each of us as team members.
This includes all employees, contractors,
board members, and everyone working within
Woolworths Group across Australia, New
2

of Our Team
Being a Part
Zealand, Asia or anywhere in the world, as part
of Woolworths, Countdown, BIG W, Primary
Connect, our Support Team, or any of our other
businesses.

We ask that you read this document carefully, 3

and reach out if you have any trouble

Workplace
Respectful
understanding it. This Code of Conduct sets
out our expectations for working at Woolworths
Group. Every team member has a responsibility
to follow this Code of Conduct, to do the right
thing, and to encourage others to do the same. 4

Act
How we
We all have a responsibility to not just protect
Woolworths Group, but grow its reputation in
People Partner or People Advisory if there is Office, Distribution Centre) and any other work site,
the eyes of our many stakeholders. By following
anything that feels unclear, or if you have any as well as working remotely;
this Code, our aim is that we can work together
to encourage an inclusive, productive and
enjoyable workplace for the whole team.
further questions.
• even if not during working time, especially 5
Working as a contractor if there is a sufficient connection to the workplace

Business
How we do
(including conduct on social media outside
We take our Code of Conduct very seriously, as
If you are doing work for Woolworths Group working hours);
it firmly reflects our purpose and our values. Not
as a contractor, or you are employed by
following this Code may result in disciplinary
another company but are working alongside • if attending any temporary alternative workplace;
action, including counselling, warnings or
termination of employment/engagement.
Woolworths Group team members, we expect
• during overnight stays away from the workplace
6
you to follow these guiding principles while you

Expectations
Leadership
are working with us. Failure to do so could lead on work business or work-related events;
From time to time, we will ask you to complete
to termination of your engagement.
training to remain up-to-date. This training • during attendance at work-related functions
is a requirement of your role, and must be (including training, educational and social
When does this Code of Conduct
undertaken when it is due. activities); or
apply?
7
As you read through this document, please • in any situation which may involve a sufficient
• In the workplace (including Store, Support

& Help
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Questions,
don’t hesitate to talk to your team leader, connection to the workplace.
 6

Code of Conduct
Wooloworths Group
Our Purpose

No matter who we are, what our role is, or what business

we work for, we’re all connected by our Group purpose:
1

We create

Welcome
better experiences 2

of Our Team
Being a Part
together
for a better
3

Workplace
Respectful
tomorrow. 4

Act
How we
What we mean by We What we mean by Together
It all starts with ‘We’ - all of us working together Valuing that we are better together,

5
with each other and in partnership
What we mean by Better
What we mean by Tomorrow

Business
How we do
Consistently innovating to lead and
exceed expectations Understanding the plans we make and the
actions we take today, are an opportunity
What we mean by Experiences to leave a positive impact for generations
Meaningful moments, both big and small to
make positive impacts on the lives of teams,
to come
6

Expectations
Leadership
customers, communities and partners

& Help
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Questions,
 7

Code of Conduct
Wooloworths Group
Our Core Values

We care deeply.

Welcome
We listen and learn. 2

of Our Team
Being a Part
We do the right
thing.
3

Workplace
Respectful
Our values are what we stand for as
individuals and as a Group. They guide
4

Act
How we
the way we interact with each other,
our partners our customers and our
communities.

Business
How we do
6

Expectations
Leadership
7

& Help
Speak up
Questions,
 8

Code of Conduct
Wooloworths Group
Our Ways
of Working

1
We are Customer 1st,

Welcome
Team 1st. 2
We are always improving.

of Our Team
Being a Part
We deliver end to end.
We encourage freedom 3

Workplace
Respectful
in a framework.
We keep things simple. 4

Act
How we
Our ways of working guide everything we
do. It’s how we work together as a team
every day, to make a positive difference to 5

Business
How we do
our customers.

Expectations
Leadership
7

& Help
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Questions,
Our Code of Conduct

Respectful
Workplace
 10

Code of Conduct
Wooloworths Group
Upholding
Diversity 1
& Inclusion

Welcome
2

of Our Team
Being a Part
3

Workplace
Respectful
4

Act
How we
At Woolworths Group, our goal is to be a truly We know that people are happier and more
inclusive workplace, where every team member fulfilled if they can be themselves, and bring
feels valued. We acknowledge our differences,
and believe in the possibilities these differences
their whole selves to work. That’s why we
strive to create an inclusive environment that
5

Business
How we do
create for our workplace culture and business celebrates the diversity of our team, giving all We expect our team to always behave in a
outcomes. team members the opportunity to feel valued, manner that is in accordance with our policies,
respected and empowered. these principles, and the law. Please refer to:
Whatever our gender, age, ethnicity, religion,
race, colour, marital status, family or carer’s
responsibility, disability or sexual orientation,
There’s never been a better time to be, and
stay, true to ourselves—as individuals and as a
Diversity and Inclusion Policy 6

Expectations
Leadership
we value and celebrate the diversity of our collective. As well as having a positive impact
teams at all levels to help every team member within our teams, customers are also reassured
Respectful Workplace Policy
feel safe and welcome. Diversity amongst our when our team members are a reflection of
leadership is critical in setting the tone for the themselves and their communities.
kind of inclusion we want to see throughout our
business. Gender Diverse and Gender Affirmation Policy 7

& Help
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Questions,
 11

Code of Conduct
Wooloworths Group
1

Welcome
2
Creating a
Identifying inappropriate behaviour 2. Harassment and sex-based harassment

of Our Team
Being a Part
Creating an inclusive workplace, and looking Harassment of team members, customers,

Respectful after the health and wellbeing of our team

members and customers is of utmost
suppliers or others is not acceptable.
Harassment is any unwanted behaviour that

Workplace
What would you do in
importance. This means it is not acceptable for might humiliate, offend, embarrass or intimidate
this scenario?
any of us to engage in the following types of another person. This could be a single incident,
behaviours at work: or happen repeatedly over time, and may Ahmed has concerns with 3
be intentional or unintentional. Harassment Steve’s performance and has

Workplace
Respectful
We strive to provide a positive workplace where 1. Bullying includes (but is not limited to): been meeting with him regularly
everyone is treated with care and respect. to coach and develop him in
Bullying is repeated, unreasonable behaviour • Offensive or demeaning comments, the areas of concern. Steve is
That means we must all: towards another person (or group of people) jokes or banter (including based on still not performing at the level

treat customers, team members and others

that creates a risk to their physical and mental
(psychological) health and safety.:
someone’s actual or perceived race, required, so Ahmed continues
to manage his performance,
4
age, religion, disability, gender identity,

Act
How we
with dignity, courtesy and respect including formal performance
sexual orientation or other personal
• Abusive, insulting or offensive language, management, is this okay?
do the right thing, be fair and be honest characteristic), even if the other person
or comments (including on social media)
doesn’t seem to mind and even if it is not
work hard to connect with others and of a racist, sexist, homophobic or
intended to offend
understand their everyday challenges transphobic nature, or towards people
with a disability • Conduct or harassment of a demeaning
Yes, Ahmed’s actions are
reasonable for the purpose 5
c are genuinely and passionately about

Business
How we do
and unwelcome nature based on of addressing unsatisfactory
creating an environment where everyone • Deliberately and unreasonably excluding performance.
someone’s sex, or characteristics
belongs someone
associated with their sex
listen, learn and respond appropriately to • Spreading misinformation or rumours
• Conduct or harassment of a demeaning
the views and concerns of others
• Aggressive and intimidating conduct and unwelcome nature based on 6
consider how everything we say and do someone’s gender or gender identity

Expectations
Leadership
• Practical jokes or initiations
might impact others.
• Mimicking someone’s accent or habits

• Sharing inappropriate images, videos

or memes

• Spreading misinformation or rumours, 7

isolating a team member or being

& Help
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Questions,
persistently unpleasant or rude
 12

Our Code of Conduct

Code of Conduct
Wooloworths Group
Identifying Inappropriate Behaviour
1

Welcome
3. Sexual Harassment Some types of sexual harassment may also be
offences under criminal law, for example sexual
Sexual harassment of team members,
customers, suppliers or others is not
assault or indecent exposure. Such behaviour, if
suspected, may be reported to the police.
2
acceptable. Sexual harassment is any uninvited,

of Our Team
Being a Part
unwelcome sexual advance, unwelcome
request for sexual favours or other unwelcome
conduct, or unreciprocated behaviour of a What would you do in this scenario? What would you do in
sexual nature that a reasonable person would this scenario?

3
Adam knows Samara through work, and they have recently become connected on
anticipate may humiliate, offend, embarrass or
Facebook. Adam has approached Samara at work and has sent Samara private Peter has recently affirmed his
intimidate another person.
messages via Facebook on a number of occasions asking Samara out. Despite gender at work, and has changed

Workplace
Respectful
Samara politely declining on more than one occasion, Adam has continued to send his name and pronouns to reflect
This includes (but is not limited to) the following
Samara private messages outside of work hours asking her out on a date. Is this his affirmed gender identity (he/
conduct, which may occur during or outside of
okay? him). Susan works with Peter and
work hours:
repeatedly refuses to address

Requesting, sending or showing sexual or No - although Adam is messaging Samara outside of work hours, they
him using the correct name and
pronouns. Instead, she refers to
4

Act
How we
offensive pictures or messages (including are connected through work, and this is sexual harassment as Adam is
Peter by his dead name (previous
by phone or on social media) persistently asking Samara on a date despite her declining.
name) and the pronouns she/her.
This causes Peter distress.
Unwelcome comments or questions about Is this okay?
a person’s appearance, sexual activities or
private life (whether in person or via social
What would you do in this scenario? 5
media or technology)

Business
How we do
No, Susan’s actions display
Mitchell and Mary have worked together for some time. They get along really well harassment on the grounds of
Unwelcome physical contact, such as and always joke around. They are friends on Snapchat and share funny pictures and gender identity. Peter has the right
shoulder massages or invading someone’s videos with each other. Recently, Mitchell has been sending Mary a lot of sexually to be addressed by the name and
personal space explicit memes and jokes. These make Mary uncomfortable, and she does not pronouns that correspond with his

Persistently asking someone on a date or

respond to them. Mitchell thinks it is funny and continues sending these, even when
he receives no response. Is this okay?
gender identity. Additionally, Peter 6
is also entitled to access the toilet,

Expectations
Leadership
to socialise outside of work, after previous locker and change room facilities
refusals corresponding to his gender
No, it is not okay. Even if Mitchell does not intend
to offend Mary, and thinks that what he is doing identity.
Offensive or demeaning comments or jokes
is funny, his conduct is inappropriate and may be
of a sexual nature (even if the intention is not
to offend or humiliate)
considered sexual harassment. Even though Mary has
not told Mitchell directly to stop, his behaviour is not 7

& Help
Speak up
Questions,
acceptable.
Staring or leering at another person
 13

Our Code of Conduct

Code of Conduct
Wooloworths Group
Identifying Inappropriate Behaviour
1

Welcome
What would you do in this
4. Racism scenario?

Woolworths Group is committed to a workplace Not all racism is obvious. When held as part Glenn is a store manager, and while What would you do in this scenario?
that is free from racism. Any form of racism of someone’s internal belief system, racism working he notices a family enter
Ben hears Kate say “I always check the
2
the store. The family is dark skinned
towards team members, customers, suppliers may not be revealed until it becomes apparent

of Our Team
Being a Part
and are carrying backpacks. He bags of people of different cultures,
or others will not be tolerated or accepted. through an individual’s actions or attitude. you can’t trust them”. Is this okay?
says to Mark, a team member with
Racism takes many forms and can happen
darker skin, “can you follow that
anywhere. It includes prejudice, discrimination, Racism is more than just words, beliefs
family around and make sure they
hatred, or antagonism directed towards and actions. It can also be reflected in systems
don’t steal?”. Is this okay? No, this is racism. Kate should not
someone due to the colour of their skin, their
ethnicity or national origin, as well as the belief
and institutions, and include all the barriers
that prevent people from enjoying dignity treat anyone less favourably because 3
of their racial or ethnic group.

Workplace
Respectful
that one’s own race is superior. and equality because of their race.
No. Glenn is showing prejudice towards,
and discrimination against, people based
While racism can be associated with acts of No team member or customer should ever
on his perception regarding their race.
abuse and aggression, racism doesn’t always experience racism at Woolworths, whether
He is racially profiling and stereotyping,

4
involve violent or intimidating behaviour. it’s in one of our stores, one of our distribution
which is not acceptable behaviour, and a
Often it can be making jokes, racially profiling, centres or one of our support offices. We breach of the Code of Conduct.

Act
How we
stereotyping others, negative comments about reject all forms of racism and are committed to
different ethnic groups, calling others racist eliminating racism for our team and customers.
names or verbally abusing them. It can also
include bullying, harassing or excluding people
from groups or activities because of where they
come from.
What would you do in this scenario? 5

Business
How we do
Sarah is working in service when a customer wearing a hijab (scarf) comes to her
A key part of this commitment is eliminating
checkout. After the customer leaves Sarah says to another team member, “it is so
racism in all of its forms and challenging the hot today why would you wear a scarf on your head.” Is this okay?
attitudes that lead to it. This is also an important
step in creating an inclusive workplace that
embraces and promotes diversity, as we are a No, this is a culturally insensitive comment even if Sarah thinks it is a joke
6

Expectations
Leadership
diverse team that reflects the communities we it is not acceptable.
serve across Australia, New Zealand and Asia.

& Help
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Questions,
 14

Our Code of Conduct

Code of Conduct
Wooloworths Group
Identifying Inappropriate Behaviour
5. Victimisation 7. Unlawful Discrimination

Victimisation means treating someone Discrimination of team members, customers,

What would you do in this scenario?
1
negatively because they have made, or have suppliers or others is not acceptable.

Welcome
been involved in, a complaint. At Woolworths Discrimination means treating someone less Sumit supervises Nada and Tom. Sumit offers
Group, we encourage our team members favourably because of a protected attribute. additional shifts to Tom instead of Nada
to speak up when a situation isn’t right, and This includes (but is not limited to) limiting because Nada has a child, and Sumit thinks she
victimisation is never acceptable. access to training or other benefits, not
promoting someone, or ending someone’s
might not be able to work outside school hours.
Is this okay?
2
It is also unacceptable to disadvantage

of Our Team
Being a Part
employment.
someone because they have raised concerns or
asked questions in relation to their employment, Examples of protected attributes, which
No, this is discrimination. Sumit cannot treat Nada less
such as their duties or pay, or because they cannot be a reason for treating someone less
favourably because she has a child. Sumit should not
plan to take, or are taking, leave or using other favourably, include (but are not limited to): assume that Nada cannot work the additional shifts.
entitlements.
• Marital or relationship status, pregnancy,
He should provide her with the same opportunities, 3
and let her decide whether or not she can do a

Workplace
Respectful
6. Violence breastfeeding, parental status or carer or particular shift.
family responsibilities
Violence towards team members, customers,
• Sexual orientation, gender, gender
suppliers or others is not acceptable. Violence
identity, intersex status or gender
and aggression is any incident where a person
is threatened, attacked or physically assaulted in
expression What would you do in this What would you do in this 4
• Race, colour, descent, nationality, national scenario? scenario?

Act
How we
circumstances within or outside the workplace.
Work-related violence and aggression covers origin, ethnicity or religious belief
Sudesh raised a complaint regarding John is a team member who has
many actions and behaviours that create a risk • Disability the way food is handled in the Deli. just finished his shift for the day.
to physical and mental (psychological) health • Age Shortly after raising the complaint, While John is walking to his car, he

5
and safety. Sudesh finds that he is no longer bumps into a customer he knows
contacted to pick up extra hours, and outside of work who frequently
This can include (but is not limited to): Not all unwelcome behaviour or interpersonal his manager gives him short answers shops at the store. John and

Business
How we do
issues will constitute one of the forms of rather than engaging in conversation the customer get into a verbal
Punching, pushing, fighting, spitting, hitting, unacceptable behaviour discussed above. with him. Is this okay? altercation, which starts to get
shoving, tripping or other physical violence Sometimes, two or more team members very heated and John proceeds to
just do not get on, or are having difficulty threaten the customer. Is this okay?
Threats of violence to team members,
customers and partners as well as any
working together. For more information on No, Sudesh should not be treated 6
difficult working relationships, as well as the negatively because he has raised

Expectations
Leadership
of their family or friends unwelcome behaviour discussed above, concerns, and the conduct he is No. Although John knows the customer
please also refer to the Respectful experiencing may be victimisation. outside of work and has just finished
Abusive behaviour, including insults his shift for the day, John is in a public
Workplace Policy.
and name-calling location while still wearing his work

7
clothing. This behaviour towards team
Intimidating behaviour that creates a fear members, customers, suppliers, or
of violence, such as stalking or threatening others is not acceptable.

& Help
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to cause physical harm
Our Code of Conduct

How we Act
 16

Code of Conduct
Wooloworths Group
Our Safety,
Health and 1
Wellbeing

Welcome
2

of Our Team
Being a Part
We care deeply about the safety, health
and wellbeing of our teams, customers and
contractors. We are all responsible for working
together to make sure that anyone who works
or shops with us goes home safely. 3

Workplace
Respectful
To achieve this, you must:

• Immediately stop any job or task that you

believe is unsafe

• Always address hazards as you become aware

4

Act
How we
of them

• Only use equipment that you are trained and

authorised to use Mental (psychological) health and safety is as
important to us as physical health and safety.
• Wear Personal Protective Equipment (PPE) We care deeply about this, and want people
to know that it’s okay not to feel okay, and it’s
5
required for the task

Business
How we do
absolutely okay to ask for help. If you’re not If you are in doubt about any health and safety
• Follow any safety and health processes okay, please see the Questions & Help section at issues, please speak to your team leader for
including rules, policies or procedures the end of this document to find out more about assistance. Please refer to:
the support available to you.
• Report incidents and injuries immediately
Remember that no task is so urgent, and no
Safety and Health Policy 6

Expectations
Leadership
• Not undertake duties when you have
service is so important, that you cannot take the
consumed or are under the influence of illicit
time to do it safely.
drugs or alcohol in the workplace (as defined Drug and Alcohol Policy
in the Drug and Alcohol Policy).

& Help
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 17

Our Code of Conduct

Code of Conduct
Wooloworths Group
Our Safety, Health and Wellbeing
1

Welcome
What would you do in this scenario? What would you do in this scenario? What would you do in this scenario? 2

of Our Team
Being a Part
Sophie is a new team member in a store, Barry is a team member who works in one of our Tom works in Customer Service, he loves his job and
and is asked by another team member to Distribution Centres. Whilst operating a forklift, Barry has always does the right thing. Tom sees a customer who
move some products using a pallet jack. an accident and collides into his colleague, Brenda, who he is familiar with and suspects that this customer has
Sophie has not been trained on this, but is operating another forklift. Neither Barry nor Brenda are been stealing stock. Tom follows the customer around
she wants to help out and make a good hurt from the accident, and only have 5 minutes of their the store. When the customer attempts to leave Tom
impression. What should she do? shift remaining. Barry and Brenda want to finish their shift
on time so they agree not to report the accident. Have
asks to perform a bag check and when the customer
refuses he prevents him from leaving by holding on to
3

Workplace
Respectful
Barry and Brenda done the right thing? him. Has Tom done the right thing?
Sophie should let the other team member
know that she has not been trained on, or
authorised to use the pallet jack, but she can
ask if there is anything else she can do to No, Barry and Brenda have not done the right thing. No, Tom should stay calm and clear of the customer.
help instead. Although no one was hurt, they must follow the
required safety process at the Distribution Centre
He should never touch the customer. Safety is the
most important thing and if a customer refuses 4

Act
How we
(which includes immediately stopping the work, to cooperate or becomes abusive, then allow the
isolating the area and immediately reporting the customer to leave. This includes where the products
incident to the relevant team leader). are taken without payment. Under no circumstances
are team members to leave the store to pursue
someone.
What would you do in this scenario?
5
Ayesha notices her team member, Mark,

Business
How we do
isn’t acting like his usual self lately. He has
What would you do in this scenario?
been getting angry and upset, and has
been turning up late to his shifts. As Mark’s
John has a big load to get through. He moves a pallet What would you do in this scenario?
Line Manager, Ayesha is concerned for his
of stock to the front of the store. To make sure he gets
wellbeing. What should Ayesha do?
through his work faster, he rides the pallet jack back
through the store. Has John done the right thing?
Kam goes to the pub next door for her lunch break.
While having lunch, Kam has two beers and then
6

Expectations
Leadership
Ayesha should ask Mark if he is okay, and returns to finish her day. Has Kam done the right thing?
have a conversation about how he is feeling.
Ayesha should try to understand whether No, John should never ride on a pallet jack, no
Mark’s work might be impacting his mental matter how important the work is. John should No, while Kam may not be over the legal limit it is not

7
wellbeing, and if so, Ayesha might tell Mark remember that no task is so urgent and no service appropriate for her to undertake duties when she has
about some of the support options available is so important that you cannot take the time to consumed alcohol as this could pose a safety risk to her, her
if needed. team mates or customers.

& Help
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do it safely.
 18

Code of Conduct
Wooloworths Group
Understanding 1
your Team

Welcome
Benefits 2

of Our Team
Being a Part
3

Workplace
Respectful
Woolworths Group puts our customers
and our teams first. That’s why we provide
exclusive offers under our Team Benefits
program.

As part of this program, we offer eligible 4

team members a discount card, referred

Act
How we
to as the Everyday Rewards Plus Card in
Australia, and the WOW People Discount
Card in New Zealand. It can be used
To make sure that our team members
across a number of Woolworths Group
businesses in Australia and New Zealand
receive the greatest benefit from the
program, we regularly monitor usage
5
and selected partners.

Business
How we do
to check it is in line with our policies.
This program is exclusive to our team Everyday Rewards Plus Card Policy Misuse of this benefit, including by
members and should not be misused or sharing it with friends, extended
shared more broadly. To find out more family or customers, could result
about the discount card, including correct Do’s and Don’t in disciplinary action or a loss of 6
and acceptable ways to use it, see the: the benefit.

Expectations
Leadership
T&Cs Asia

& Help
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 19

Code of Conduct
Wooloworths Group
1

Welcome
2
How To Use
We always treat others with respect We protect our confidential information

of Our Team
Being a Part
Whenever interacting with, or talking about, Information you come across at work can What would you do in

and Behave team members, customers or others connected

with work, or when discussing Woolworths
sometimes be sensitive or confidential, so it’s
important that you never share this on social
this scenario?

Across Social
Sarah hears from another
Group on social media – whether at work or not media. (The exception is the appropriate sharing team member that Woolworths
– you must: for work purposes on internal-only forums
3
will be stocking an innovative

Media • Always treat everyone with dignity,

such as private work Google Currents pages
or Workplace for NZ). Similarly you must never
new product in the lead up to
Christmas, but the product has

Workplace
Respectful
courtesy and respect, even if they have
‘like’ or re-share other people’s posts containing not been officially announced
made negative, inflammatory or untrue externally. She posts on LinkedIn
Woolworths Group’s confidential information.
comments about you or Woolworths that she is excited to work for a
We all need to make sure we use social media Group company that supports product
Confidential information is internal information
safely and effectively, and always do the right
thing online. • Never make insulting, demeaning, that is not readily available to the public. innovation, but does not mention
the specifics of the product. Is
4
threatening, sexual or discriminatory This might include information about team

Act
How we
this okay?
It’s important to remember that content shared comments to or about someone (even members, customers, strategy, business plans,
on websites can exist online indefinitely, as well if the other person is not mentioned by internal events, profit information, sales results
as being shared and seen by a much larger or upcoming promotions. For more information Yes, Sarah has not revealed any
name)
about confidential information, see page 27. confidential information, so this
audience than might be intended. Below are our
expectations for using social media. • Never send sexual or offensive pictures
or videos
is okay.
5

Business
How we do
• Never disclose personal information
about other team members or customers What would you do in this scenario?

• Never post or share anything about Tom hears that the Company will be dropping prices on a
team members, customers or other
people connected with the Group that
range of products on Saturday. He posts on Facebook that
people should hold off on buying until then. Is this okay?
6

Expectations
Leadership
is inconsistent with our Respectful
Workplace Policy
No. Tom has revealed confidential information. Even if he was trying to
help customers, this was not the right way to do that. In addition to being
seen by Tom’s Facebook friends, this information could also potentially
be picked up by the media and/or competitors and this may have a 7

& Help
Speak up
Questions,
negative impact on sales and the Company’s competitive advantage.
 20

Code of Conduct
Wooloworths Group
How To Use and Behave Across Social
Media 1

Welcome
We are advocates for Woolworths Group and We check before posting
our businesses
Before posting anything related to work— What would you do in this scenario?
Using social media to promote our Group including sharing photos and videos taken at
Pietro serves a difficult customer who is challenging Pietro about
2
and businesses is encouraged. However, you work, in one of our workplace locations, or of

of Our Team
Being a Part
the price of an item. When Pietro goes on his lunch break, he
shouldn’t talk negatively about Woolworths people wearing our uniform, logos or a name posts about the incident on his Facebook profile. Is this okay?
Group, or share, comment on or ‘like’ anything badge—reread your post and ask yourself:
that might damage the Group’s reputation,
• How might your post impact Woolworths
brand or commercial interests, including posts
Group if it becomes widely viewed? No. Before posting anything on social media that relates to work, Pietro
that are incorrect or misleading.
• Would you want your team leader or team should reflect on how the post might impact Woolworths Group, how 3
members to see it? the customer would feel if they saw the post, and whether Pietro would

Workplace
Respectful
It’s important to remember that if you list your
want his team leader to see the post. If Pietro has any concerns about the
workplace on social media, people will see you • Are you revealing any confidential incident, he should raise them with his team leader.
as a face of our business—even when you are information?
not working or talking about work. Accordingly, • How would a customer feel if they read
any views you share, or comments you make
associated with Woolworths Group should be
the post? 4

Act
How we
consistent with the views of the Group. If you are unsure whether the content is
What would you do in this scenario?
appropriate and consistent with the principles
If you want to raise a concern about Woolworths outlined above, you should ask someone else Kate is on TikTok while working in the fresh produce department and decides to post
Group, or anything related to the Group, you to review it before you post. You can talk to your a funny video of her juggling some apples. The video gets a lot of likes so Kate starts
should speak to your team leader or contact team leader, the business’ Social Media team
5
regularly posting videos of her juggling different fruits and vegetables. The videos are really
People Advisory, BIG W Employee Services, or the Group External Communications (Media) popular and Kate says she is promoting the fresh produce at Woolworths. Is this okay?
Team Services for NZ team members, or Speak team for guidance.

Business
How we do
Up. Social media is not an appropriate forum for
this. We limit our use during work hours
No, Kate has made the videos in the store and while in her uniform. Even if Kate believes
she is promoting Woolworths, she has not obtained the appropriate permissions and
We are honest and transparent Generally, social media should only be used

If you are talking about Woolworths Group or

during breaks—unless it is being used for work
purposes (for example, finding a recipe or social
could be breaching food safety and handling processes in the way she is handling the
food. Kate should ask someone else to review the videos before she posts them. She 6

Expectations
Leadership
should talk to her team leader, the business’ Social Media team or the Group External
related topics, or even retail in general, you media promotion for a customer). Use of social Communications (Media) team for guidance.
should make it clear that you work for the Group, media during work hours should not impact
but the views you are expressing are your own your ability to do your job.
and not those of the Group. Team members can

7
only comment on behalf of Woolworths Group, Please also refer to the
or use logos and branding, with approval from
one of our Social Media teams.

& Help
Speak up
Questions,
Social Media Policy and Guidelines
 21

Code of Conduct
Wooloworths Group
1

Welcome
2
Opportunities
That’s why we encourage all our team members If the media approach you, please refer Public submissions
to behave in a way that continues to build our them to the Woolworths Group External

of Our Team
Being a Part
good reputation. A good reputation is hard to Communications (Media) team at media@ As a large business which interacts with

with Media earn, but can be easily damaged. woolworths.com.au (in Australia or Asia),
or call (02) 8885 1033 (in Australia) or media@
all levels of government, Woolworths
Group is often invited to contribute to

and External To ensure that you do not inadvertently risk

Woolworths Group’s reputation, it is important
countdown.co.nz (in New Zealand). government inquiries, consultations,
planning processes and reviews. Our
3
Stakeholders
that you: Participation in political activities Government Submissions Guidelines,
which apply to all Woolworths Group

Workplace
Respectful
• Do not provide information to the media Woolworths Group respects the rights of team business units and controlled subsidiaries,
or talk to the media if they approach you, members to participate in the political process, are in place to ensure all submissions on
unless your role authorises you to do so. If but we also need to avoid any potential conflicts behalf of Woolworths Group are managed
Woolworths Group is a well-known business in the media does approach you, refer them of interest, or situations that could damage in a consistent and coherent way, with the
Australia and New Zealand; the media, industry
associations, community groups, regulators and
to the contact details of the Woolworths
Group External Communications (Media)
our reputation. appropriate executive governance. 4

Act
How we
politicians understandably pay close attention team listed on this page That means: If you have any questions or concerns,
to what we do. contact the Head of Government
• Do not provide information to politicians • You must comply with all relevant laws
As a representative of Woolworths Group, Relations and Industry Affairs, via
or government officials, unless approved regarding lobbying, gifts or benefits to
everything you do at work, and the decisions governmentrelations@woolworths.com.
by the Government Relations team government officials or government
you make can have a direct impact on the
• Do not reference Woolworths Group
employees
au or media@countdown.co.nz.
5
Group’s reputation. We always want that impact

Business
How we do
negatively in any online social medium or • Any donation to a political party made by Please also refer to the Political Donations
to be positive.
public forum or on behalf of Woolworths Group must Policy, and the
be consistent with the Group’s Political
We strive to have a positive relationship with
Donations Policy, which includes obtaining Fraud, Anti-Bribery and Corruption Policy
everyone we interact and work with, so it’s
important that all enquiries from customers,
approval from our Government Relations
team.
6
partners, the media and all other external and where relevant, the

Expectations
Leadership
groups and organisations are dealt with quickly It’s important that any person who considers
and appropriately. running for elected office does not inadvertently Woolworths Group Government
create a conflict of interest or impact Submission Guidelines
Woolworths Group’s reputation, and that the
process occurs purely in an individual capacity. 7
If you are thinking of running for elected office,

& Help
Speak up
Questions,
you should notify your team leader and the
Woolworths Government Relations team.
Our Code of Conduct

How we do
Business
 23

Our Code of Conduct

Code of Conduct
Wooloworths Group
How we do Business
1

Welcome
One of our important core values is that we Taking care of Woolworths Group property the workplace and ensure its removal is
always do the right thing. documented
We are all responsible for the property that
That means you should: belongs to Woolworths Group. We need to Use property and business tools for their What would you do in 2
make sure we use items properly and take care intended business use and not for personal this scenario?

of Our Team
Being a Part
Carry out your duties in good faith, always of any property we come into contact with. use unless authorised
When Tracy finishes her shift, she
following relevant laws, policies and
marks down a roast chicken that
procedures In your role, you may be given access to things Use property and business tools
has just been cooked so that she
that belong to the Group, such as: appropriately and responsibly including
can buy it at a cheaper price. The
Respect the human rights of your team,
customers, and all those you interact with in • Cash
with appropriate care and ensuring they are
returned in good working condition
store will be closing in an hour, so
the chicken possibly won’t be sold
3
the course of performing your role • Equipment

Workplace
Respectful
anyway. Is this okay?
• Products and merchandise Return property, including hard and soft
Complete the training applicable to your role, copies of documents, when you stop
and raise anything that you don’t understand • Computers, mobile phones, tablets and No. It’s not right for Tracy to mark
passwords working with Woolworths Group
down a product so that she or another
with your team leader
• Motor vehicles If you believe that theft or damage to
team member can buy it more
cheaply. If Tracy is not sure whether
4
Avoid engaging in behaviour—or ignoring • Buildings and sites Woolworths Group property is happening

Act
How we
the chicken is needed or will be sold,
behaviour by others—which breaches this in your workplace, you should report it
• Confidential information she should speak to her team leader.
Code of Conduct, any of our policies, or the immediately to your team leader or a loss
• Intellectual property
law prevention representative. Theft or damage to
You should always handle stock, equipment and property is a criminal offence.
Promptly raise issues (or suspected
breaches) with your team leader
other Woolworths Group property with care,
To protect our customers, team members and What would you do in
5
and remember to:

Business
How we do
sites, Closed Circuit Television (CCTV) video this scenario?
You should treat customers fairly and with Ensure every sale is processed through the surveillance equipment operates at our sites.
respect, as relevant to your role. For example: Phil has been given samples of
point of sale in the correct way CCTV cameras are clearly visible, and are not new nappies from a supply partner.
• Listen to and value customer feedback installed in bathroom areas, change rooms or When he doesn’t think the nappies

• Address customer concerns regarding

Assume that damaged or expired stock is
wanted and valuable to Woolworths Group
locker rooms. will be needed any more, he gives 6
them to his brother who has a baby.

Expectations
Leadership
products that are faulty, unfit or and should be accounted for and disposed Is this okay?
mislabelled of in the appropriate way
No. Samples are provided for a
• Make sure our marketing, promotional Never take any stock, money or property, no
business purpose. Phil should check
information, product packaging and matter how small or inexpensive
7
with his team leader before taking
labelling is legal, clear, truthful and always them home, or using them for any
carefully checked Where appropriate, seek permission
other purpose.

& Help
Speak up
Questions,
from a team leader to take property from
 24

Our Code of Conduct

Code of Conduct
Wooloworths Group
How we do Business
1

Welcome
Navigating gifts and entertainment

We’re committed to being honest, unbiased, This is how you are expected to respond if you
and always behave with integrity every day. are offered entertainment: What would you do in 2
To maintain a level playing field for all of our this scenario?

of Our Team
Being a Part
partners, our policy is to not accept gifts, and to If it relates to a professional development
Prakash is moving a tray of perishables from a freezer. Another
only accept entertainment in accordance with or professional awards event, it can be
team member asks him to help out in Deli for fifteen minutes as
the Gifts and Entertainment Policy. accepted but needs to be logged in the Gift
it’s busy. To save time, the team member asks Prakash to leave
and Entertainment Register, and signed off the perishables in the corridor while he helps out. Prakash tells
Examples of gifts include: physical products,
cash, gratuities, supplier-paid trips, and
by the relevant General Manager the team member that he needs to put the perishables back in
the freezer before helping in Deli. Is this right?
3
If it relates to a sporting or entertainment

Workplace
Respectful
any other personal favours. Examples of
entertainment include: meals, and tickets to event (e.g. a concert), it can be accepted
sport or entertainment events. if the value does not exceed AU$150 per Yes. If Prakash had not put the perishables back into the freezer (or in
person in Australia or NZ$150 per person in the case they were going into) before helping in Deli, the perishables

4
If you are offered a gift—unless it is part New Zealand. You will need to log it in the would have spoiled and been a stock loss. This may have created a food
of a Woolworths Group approved promotion, Gift and Entertainment Register. safety risk, which Prakash was able to avoid.

Act
How we
and you have received prior direction that
it is approved for you to accept it—you are If the value exceeds AU/NZ$150 per
expected to: person, and you would like to accept the
entertainment, you should pay the value
What would you do in
• decline the gift; or greater than $150, notify your manager
• if declining the gift is not possible, or is
and log the entertainment in the Gift and
this scenario?
5
Entertainment Register (exceptions apply for A sales rep gives Sam a $25 gift card to celebrate a

Business
How we do
inappropriate, the gift can be accepted,
partner award dinners – see the Gifts and successful promotion. What should Sam do?
but should be logged in the Gift and
Entertainment Policy)
Entertainment Register and used for
charity or raffle prizes. Please also refer to the Because a voucher or gift card is
classed as a gift, Sam should thank 6
Gifts and Entertainment Policy the sales rep but politely decline

Expectations
Leadership
the gift, explaining that Woolworths
Group policy is to not accept gifts.

Fraud, Anti-Bribery and Corruption Policy

& Help
Speak up
Questions,
 25

Our Code of Conduct

Code of Conduct
Wooloworths Group
Navigating Conflicts of Interest
1

Welcome
We are all expected to act in the best interests remuneration and other Woolworths Group What would you do in this scenario? What would you do in this
of Woolworths Group. This means that we benefits to which you are entitled), or to benefit scenario?
must avoid conflicts between our own interests
and the Group’s interests wherever possible.
any other business or person. Arjun works in the Procurement
team, and Arjun’s sibling, Sonali, just Sally wants to hire her boyfriend,
2
Conflicts of interest can include any personal If you have an actual, potential or perceived

of Our Team
Being a Part
secured a role with a major supply Nick, to work on a project. Nick is
interests, relationships or activities that may conflict of interest: partner. Currently, Arjun does not an expert in this particular work,
influence you (or be seen to influence you) to act have to liaise with the partner, but and Sally has received advice from
in a way that is not in the Group’s best interests. • Avoid putting yourself in a position where Arjun may need to in future as part the Performance and Reward team
you are choosing between what is in the of his role. Arjun is pretty sure this on the market rate for the role. Is it
If you think you might have a potential conflict of Group’s best interests and what is in your
interest (or that someone else might perceive interest (or the interest of someone you
won’t present a conflict. Should Arjun
disclose this?
okay for Sally to hire Nick?
3
one), you must disclose that interest to your are connected with)

Workplace
Respectful
team leader. You will also need to make a
• Woolworth’s Group may also make Although Arjun doesn’t think that Although the choice is legitimate,
conflict of interest declaration. See the Conflict
changes, or take additional steps that their sibling’s new job is a current and Sally is trying to do the right
of Interest Policy for more information on how
we consider necessary to protect team conflict, it is a potential conflict, thing for Woolworths Group, Sally
to complete the conflict of interest declaration.
members, those they are connected with,
Here are some examples of conflicts of interest:
and the Group from the potential conflict.
and Arjun should therefore disclose
the potential conflict to their team
hiring Nick might look like a conflict
of interest. It’s fine for Sally to put 4

Act
How we
leader. Arjun must then complete Nick’s name forward for the role,
You should seek help from your team leader
• Your sibling holds a sales role with a a conflict of interest declaration. but Sally should let the Talent
with this, and ensure any conflict of interest
supply partner with whom you may end Even if Arjun never ends up liaising Acquisition team do a proper
is captured in SuccessFactors, or using the
up negotiating a contract with the major supply partner, Arjun search to make sure Nick is the
form linked within the Conflict of Interest Policy.
should disclose the conflict just in best person for the job. Sally should
Please also refer to the:
• You have a material financial interest in a
business which is seeking to do business
case. also seek approval from her team
leader and seek the advice of her
5
with Woolworths Group

Business
How we do
People Partner. If Nick is found to
Conflict of Interest Policy
• Your spouse holds a senior position with a be the best person for the job and
major competitor What would you do in this scenario? is hired, he shouldn’t report to Sally
and Sally shouldn’t be involved in
• You work for Woolworths Group in a role Jenny is the Customer Service Manager at the Store and future decisions for him regarding
where you have access to confidential or her daughter, Kelly, wants a job at Woolworths. Jenny hires promotions, pay and ongoing 6
market sensitive information and have a her daughter as a part time team member in the customer performance management.

Expectations
Leadership
second job with a competitor service department. Jenny does not tell her manager but
everyone in the store knows that Kelly is Jenny’s daughter.
• You are in a close personal relationship
Is this okay?
with another team member whose job
or career you have influence over (for While it may be known that Kelly is Jenny’s daughter, Jenny should still notify her
example, someone who reports to you) manager, and complete the Conflict of Interest declaration in SuccessFactors or
the Form. It may be more appropriate for Kelly to work in another department where
7
You must not use your position with Woolworths

& Help
Speak up
Questions,
Jenny is not her direct manager.
Group to obtain any personal benefit (other than
 26

Code of Conduct
Wooloworths Group
Using
Information 1
Technology

Welcome
All team members have a role to play in
protecting Woolworths Group’s information,
2

of Our Team
Being a Part
including customer information. We must also
act to protect all technology and information
systems within the Group.

To keep our systems safe:

• Team members are provided with unique

3

Workplace
Respectful
accounts with passwords, which should not
be shared with others.
• Information sent, received or stored on
Woolworths Group systems (including email,
chat, internet and intranet) may be monitored. 4

Act
How we
• If you receive a suspicious email, do not
respond or click on any links, instead forward
the email to hoax@woolworths.com.au, What would you do in this scenario?
or hoax@woolworths.co.nz or hoax@
What would you do in this scenario? Sabina is really frustrated with a change to business
countdown.co.nz for NZ team members.
Jing receives an email from a well-known
operations, which means her roster has to change. 5
• Always use systems (including, email, chat She posts about how frustrated she is, and makes

Business
How we do
and Workjam) in a manner consistent with this organisation saying that she has won a free
bad comments about her Store Manager and Group
holiday, which she must claim within 24 hours
Code of Conduct. Communications on these Manager in a Workjam chat (Workplace chat NZ)
by clicking on a link. What should Jing do?
systems are monitored and recorded and any which is visible to the whole store. Others start to
breaches may be investigated. comment raising similar complaints. Is this okay?
• Report suspected security incidents to the Emails such as the one Jing received 6

Expectations
Leadership
Incident Management Centre immediately are often used by scammers to trick
on 1800 008 584 (Australia) or 0800 501 801 the recipient into submitting their No. Workjam should always be used in a way that
(New Zealand). A security incident is any event personal or financial information, and treats everyone with dignity, courtesy and respect.
that may indicate that Woolworths’ systems are commonly referred to as Phishing Sabina’s conduct is a misuse of the IT service, and
or data have been compromised. emails. Jing should not click on the a breach of the Code of Conduct. There are more

• Familiarise yourself with, and always act in

link and should forward the email to appropriate ways for Sabina to raise her concerns, 7
hoax@woolworths.com.au or hoax@ such as speaking directly to her Store Manager

& Help
Speak up
Questions,
accordance with the Acceptable Use
woolworths.co.nz for investigation. and Group Manager.
of Information Systems Policy.
 27

Our Code of Conduct

Code of Conduct
Wooloworths Group
How to treat personal and confidential
information
To help us remain competitive, and to keep for your role. For example, if you find a lost Woolworths Group information
the information people trust us with safe,
team members should not share Woolworths
credit card, you must take appropriate steps to
keep the card secure, as well as the personal Information about Woolworths Group and our 1
Group information with any person who is information on it, as strict rules apply for dealing operations, strategies, finances, customers

Welcome
not authorised to see that information. This with credit card data. and team—or anything else that is not publicly
applies both during and after Woolworths Group known—must be kept confidential and not
employment. Please also refer to the:
disclosed to anyone outside Woolworths Group, What would you do in this
As part of your role you may be trusted with
Acceptable Use of Information
including friends and family, on social media, or
if speaking at events. If you are due to speak at
scenario? 2
documents and information that belong to

of Our Team
Being a Part
Systems Policy an event, be sure to let your team leader know Rohan has made a list of customer
Woolworths Group, our customers, team
members and partners. For more information what information you’ll be sharing. names and addresses for a
please refer to our: competition. When he goes to send
Partners this to his team leader, Sarah, he
What would you do in accidentally sends it to another
Woolworths Group Privacy Policy
Usually, when Woolworths Group receives
information from another party, such as
this scenario? Sarah who works at his former
company. What should he do?
3
a partner, we have agreed to keep that

Workplace
Respectful
Rachna’s sister works in marketing for
information confidential. This means you must: a competitor. Rachna and her sister
Countdown Privacy Policy Rohan should tell his team
sometimes talk about Woolworths Group
• Only use the information for the reason it leader and report any
ideas for upcoming promotions. Is this
was given to Woolworths Group and as unintentional disclosure,

4
okay?
agreed with our partner loss or theft of customers’
Internal Team Member Privacy Policy No. Rachna is giving away confidential or team members’ personal
• Not share it with people outside of

Act
How we
information. This is not okay, even if Rachna’s information (including but not
Woolworths Group without the owner’s sister promises not to tell anyone or use the limited to email address, phone
Personal information permission information at work. Rachna and her sister number, physical address and
• Keep the information in a secure and may also be breaching competition laws by date of birth) to the Incident
Under privacy laws, there are strict rules about discussing price and promotions. Management Centre (IMC)
safe location if the information is in hard
how we can collect personal information from
our customers, team members and others,
copy format, or restrict access to the immediately on 1800 008
584 (Australia) or 0800 501
5
information on a need-to-know basis with

Business
How we do
how we can use that information (including 801 (New Zealand). It may be
other team members if the information is
restrictions on sharing it with others), and possible to recover the email
in soft copy format What would you do in
what we need to do to protect the information. or steps can be taken to ask
Remember, someone’s personal information this scenario?
• Securely destroy, permanently delete, the recipient to delete the
generally can’t be shared without that person’s or de-identify personal information
consent. We all play a vital part in complying if the business purpose for which
Andrew, a Store Manager, has received a medical report from
a team member. Andrew then shares some of the medical
email. It may also be necessary
to undertake a review to 6
with these rules. the information was collected has

Expectations
Leadership
information in this report with the team member’s team leader determine whether the
been exhausted and there is no legal customers need to be notified.
Customers (who doesn’t need to know this information for business
requirement to retain the information
reasons). Is it okay that Andrew shared this information?
Woolworths Group places great importance • Treat all personal information in
on protecting our customers’ information. You accordance with privacy laws
7
No. Generally, medical information must be kept confidential (unless the team member
should only collect, use, retain, store or disclose
consents to the information being shared) and can only be used for the purpose it is
customer information in accordance with the
provided.

& Help
Speak up
Questions,
Group’s policies, and only where this is required
 28

Our Code of Conduct

Code of Conduct
Wooloworths Group
Record keeping 1
We’re committed to operating responsibly and parties including the government or

Welcome
in accordance with legislation and accounting regulators, is unacceptable
principles.
• No team member should deliberately
This means that: keep, or help another team member to What would you do in this scenario?
• We need to make sure our financial
keep, records that intentionally mislead or
hide the true nature of a transaction Wendy, a Store Manager, is approached by
2
records, people records and systems are

of Our Team
Being a Part
someone external who offers to clean the store
accurate and complete • All Woolworths Group funds, transactions
very cheaply if Wendy pays in cash and does not
and bank accounts must be reflected in
• All of our financial transactions and document the work. Is this okay?
Woolworths Group’s books/accounts. No
funds need to be recorded correctly and
‘off book’ transactions can be made
supported by proper documentation
No. Wendy should not agree to any arrangement where she is asked
(electronic or paper) so they can be
audited reliably and reported honestly
not to keep records or to pay ‘cash in hand’. Wendy should call 3
People Advisory, her team leader, and/or raise a Speak Up report.

Workplace
Respectful
• Falsifying Woolworths Group documents,
or any information given to external

Trading in Woolworths Group and other 4

Act
How we
What would you do in

companies’ shares this scenario?

Tim owns shares in Big Biscuits,

As a team member, you may become aware of trade (or encourage someone else to trade) are Specified Persons must also seek pre-trade which has a major contract with
confidential information that could affect the
Woolworths Group share price, or the share
in Woolworths Group shares or the shares of
another company. In addition to being a breach
clearance before trading in Woolworths Group
shares.
Woolworths Group. Tim hears from
a team member that Big Biscuits is
5

Business
How we do
price of another company. of our policies, this is against the law. about to lose its contract. Tim sells
These processes protect team members who his shares because he is worried
This confidential price-sensitive information is From time to time, team members may are Specified Persons from inadvertently trading that Big Biscuits’ share price will
known as Inside Information. Team members be advised not to trade in shares in other Woolworths Group shares when confidential, fall and that he will lose money.
should never trade in Woolworths Group shares companies due to confidential, price-sensitive price-sensitive information is known within the Is this okay?
or the shares of another company while in information being known through business Group. You will be notified by email if you are 6
possession of Inside Information about that dealings. As a general rule, buyers should not a Specified Person. A list of Specified Person

Expectations
Leadership
No. Tim’s decision to sell his
company. This prohibition applies to any form buy or sell shares in a partner they are dealing roles and a definition of Closely Related Parties Big Biscuits shares is based on
of trade including buying, selling or transferring with on Woolworths’ behalf. is available on the “Securities Trading” page on information that is not publicly
shares. the People Portal. known and might affect Big Biscuits’
Woolworths operates blackout periods where share price. He should not sell his
Team members must also not share the Inside
Information directly or indirectly with another
Specified Persons (and if applicable, their
Closely Related Parties) must not buy or sell
Please also refer to the Securities Trading
Policy page on the People Portal.
shares, and can seek further advice
from the Chief Legal Officer or
7

& Help
Speak up
Questions,
person who may use the Inside Information to Woolworths Group shares. Team members who Company Secretary.
 29

Code of Conduct
Wooloworths Group
Adhering to Food Safety
and Responsible Sourcing 1

Welcome
Food and product safety is paramount, and we Staying aware of sanctions
are all accountable for it. Where relevant to your
role, you should make sure that the products Governments impose restrictions on activities
What would you do in this scenario?
we supply are safe and meet regulatory
requirements, including safety warnings and
relating to certain countries, organisations, or
individuals called ‘sanctions’. Sanctions are Phan, a Category Manager, receives a response to a tender from a potential supplier.
2

of Our Team
Being a Part
labelling. If you become aware of an issue with a designed to bring a situation of international The potential supplier is quoting a price for the work that is significantly lower than other
product—either through a customer complaint concern to an end by influencing those suppliers, and lower than what Phan understands to be the market rate for the work the
responsible to limit the adverse impacts of a supplier will complete. Should Phan automatically award the work to the supplier, given
or a recall issue—you should make sure that
situation, or to penalise those responsible. they have the lowest price?
immediate action is taken to investigate and
prevent sale of recalled products.
Business activities that may be affected by
sanctions are supplier relationships, financial
3
It is important that, where relevant to your role, No, Phan should not automatically accept the lower price. While it is important that Phan

Workplace
Respectful
you make sure that you are aware of the policies transactions, talent acquisition, investor obtains the best value for money, he cannot act unethically and needs to be aware of the
and legislation that apply, and that you comply relations, and other areas dealing with external important role Woolworths plays in its supply chain. If Phan suspects that the price is too
with the Responsible Sourcing Policy and parties. low, he should work with the potential supplier to understand how they arrived at the quote
while still enabling workers to be paid appropriately. If in doubt, Phan should escalate
Standards.
We must always be aware of sanctions when
doing business. This is not only to comply with
the matter to his team leader, who may also contact the Group Human Rights team at
responsiblesourcing@woolworths.com.au.
4
This means, never asking or accepting bribes,

Act
How we
selecting suppliers that meet our minimum the law, but also to meet our customers’ and
expectations, and always acting ethically and community expectations. To find out more
responsibly. Please also refer to the: about sanctions and the tools available to you,
click here, read the Fraud, Anti-Bribery and
What would you do in this scenario?

Environmental Claims Policy

Corruption Policy, and if required raise a Speak
Up report if you believe anyone is breaching Tara, a Store Manager, is approached by a sales
5

Business
How we do
sanctions. rep, who offers to give her a bottle of wine if she
puts his products in an over-and-above display
in a prominent location. What should Tara do?
Food and Grocery Code of Conduct
What would you do in this scenario?

One of Rob’s partners calls to tell him that some products have been seized No payments should ever be made to make someone
6
Fraud, Anti-Bribery and Corruption Policy

Expectations
Leadership
by a foreign government, and that the government is demanding $10,000 to act in Woolworths Group’s favour, a team member’s
release the shipment. What should Rob do? Should he make the payment. favour or for the benefit of someone else (including
family or friends). Tara may give the sales rep the
Responsible Sourcing Policy & Standards over-and-above display if it will be justified by sales
No. Bribes or facilitation payments should never be
or in accordance with other relevant policy/process,
paid by a team member or by a third party. Rob should
immediately raise this with his team leader, his People
but Tara should not accept or be influenced by the
inducement of a bottle of wine.
7
Partner, or through Speak Up.

& Help
Speak up
Questions,
 30

Code of Conduct
Wooloworths Group
Choosing your
Preferred Dress 1

Welcome
Dress and personal presentation are important
expectations of team members.

While what may be considered as the

Workplace has changed for some, we are all
2

of Our Team
Being a Part
expected to dress appropriately while at work
locations and when representing Woolworths
Group. This means wearing a professional and
appropriate style of clothing, consistent with
your role and location. Attire must never present
a safety issue and must be in line with this 3
Code of Conduct.

Workplace
Respectful
This includes:

• Wearing preferred clothing (in line with

applicable policies/guidelines for your location
and role) or professional business attire. It’s
4

Act
How we
always okay to wear cultural and religious
garments, and you may wear clothing that
best aligns to your gender identity. • Wearing respectful attire that demonstrates
• Wearing clothing that is safe in the relevant respect to others and is not offensive.
environment, and wearing appropriate
What would you do in
this scenario? 5
protective or safety clothing when required

Business
How we do
What would you do in
Ben wears thongs, shorts and
• Being clean, tidy and maintaining personal
this scenario? a singlet to work in one of our
hygiene and grooming
support offices. Is this okay?
• Wearing a name badge or identity card when Amar wears a turban to
on work premises represent his faith. Can he 6
wear it to work in a store?

Expectations
Leadership
• Wearing only Woolworths Group authorised No. Team members are
business logos, promotional garments expected to wear professional
or accessories, (e.g. caps, if you are in a business attire at our support
customer-facing role) Yes. It’s absolutely fine for offices, even on Fridays when
Amar to wear a turban at professional and business-
• Keeping jewellery to an acceptable business- work, irrespective of where he appropriate smart casual 7
level standard. Additional department-specific works. clothing can be worn.

& Help
Speak up
Questions,
requirements may also apply, (e.g. when
working in a fresh food department)
Our Code of Conduct

Expectations of
Our Leaders
 32

Code of Conduct
Wooloworths Group
Expectations
of Our Leaders 1

Welcome
2

of Our Team
Being a Part
3

Workplace
Respectful
4

Act
How we
Team Leaders, Managers and Supervisors • monitoring the workplace and intervening • making fair, transparent and consistent
(Leaders) have a responsibility to role model quickly and appropriately when behaviour decisions regarding any allegations of
and promote this Code of Conduct. that is contrary to this Code of Conduct is
observed or reported. A formal complaint
behaviour that is inconsistent with the Code
of Conduct.
5

Business
How we do
Leaders are also responsible for: does not need to be made before the
appropriate action is taken;
• making sure team members have a clear
understanding of the expectations and values • treating all complaints seriously and with
outlined in this Code of Conduct, and any
other relevant legislation and policy;
care, including taking action to deal with any
matters arising out of contraventions of this
6

Expectations
Leadership
Code of Conduct in a timely and reasonable
• discussing issues and clarifying expectations
manner; and
with team members;

& Help
Speak up
Questions,
Our Code of Conduct

Questions,
Speak Up and
Further Help
 34

Our Code of Conduct

Code of Conduct
Wooloworths Group
Questions, Speak Up and Further Help
1

Welcome
At Woolworths Group, we encourage Your enterprise agreement • Malaysia - 1800 81 0010
our team members to speak up when something
For more information about your entitlements • Philippines - 1800 1 322 0463
isn’t right.
and responsibilities go to the People Portal. • Thailand - 1800 012 655 2
Unwelcome behaviours and breaches of our

of Our Team
Being a Part
Policies and this Code of Conduct are not only People Advisory (Aus) / Team Services (NZ) Financial Wellbeing Program
unacceptable in our workplace. They may also be For more details on how to report please go to
For people matters, including understanding WoolworthsGroup.com.au/SpeakUp For information and support with finances
against the law. If you believe this is happening
your pay and benefits and resolving workplace or email GroupCompliance@woolworths. for team members in Australia and New
to you, or another team member—whether
issues:
by another team member, a team leader, a
customer, or anybody at work—there are
com.au Zealand, including interest-free loans.
3
• Australia - Call 1800 008 584, or use webchat

Workplace
Respectful
informal and formal ways to address this. In Australia
or a service request through the People Portal
• New Zealand - Call 0800 735 477 or by email Call 1300 975 418 or email
Options include speaking to the person in to team.services@countdown.co.nz support@goodmoney.com.au.
question, if you feel comfortable and safe doing • Asia - Please email
so, or raising in any of the following ways: asiapeopleservices@woolworths.com.au Sonder (Australia, Asia & New Zealand) In New Zealand
Call 0800 969 379 or email
4
Your team leader

Act
How we
Speak Up For 24/7 confidential guidance and support, fwp@goodshepherd.org.nz.
our partner Sonder provides our team
Your first point of call for any queries, advice Woolworths Group Team Member Speak Up is members with on-demand personal safety,
or support. an independent complaints handling service health and wellbeing support through access
hosted by an external company. To understand
People Partner
what type of concerns should be raised with
to counsellors, psychologists, emergency
management and nurses to address medical
5
Speak Up, consult our Team Member Speak

Business
How we do
For more sensitive or complex people concerns. From Australia, you can call the
queries or support, or in Asia for payroll Up policy. Sonder Support Centre on 1800 234 561.
and benefits issues. To provide access to your family, you can
Where you identify a serious matter that doesn’t
share the code “IAMHEREFAMILY” with any
seem right, for example a potential breach of
6
People Portal member of your immediate family. For more
the law or our policies, including suspected
information, visit the “I am here” page on the
For people policies, processes and guidance fraud or corruption, or need to raise an issue

Expectations
Leadership
People Portal. In New Zealand call 0800 447
material. Go to: anonymously. Call:
444 for the Sonder Support Centre. To provide
• Australia - 1800 334 319 access to your wider whānau, you can share
• Australia - wowpeople.woolworths.com.au
• New Zealand - 0800 393 76736 the code WWNZFAMILY. For
• New Zealand - https://sites.google.com/a/ more information, visit the Team This Code of Conduct may be changed
countdown.co.nz/countdown-people-portal/ • Bangladesh - 0800 0000 333
Benefits page on the People from time to time and does not form 7
• China (Hong Kong) - 800 969 643 portal. To download the Sonder part of any contract of employment or

& Help
Speak up
Questions,
• Asia - woolworthsasia.me/asiapeopleportal
app, scan the QR code. enterprise agreement. September 2022.
• India - 000 800 0501 474