One Air New Zealand Doing what's right - OUR CODE OF CONDUCT - Air New Zealand website
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OUR CODE OF CONDUCT One Air New Zealand Doing what’s right LAST UPDATED: JANUARY 2020
A message
from Greg
We are a proud and iconic New Zealand
business sharing the best of our country
with the world. Every one of us plays a role
in shaping the Air New Zealand experience
for our customers each day.
Our Code of Conduct reflects the way we do things around
here and serves as a guide to how we should behave and
the daily decisions we make. Part of this means thinking,
acting and working as One Air New Zealand so we’re
consistent right across the airline.
Let’s all take pride in working for this uniquely Kiwi
organisation and together commit to doing what’s
right. Be honest, act with integrity, transparency and
mutual respect.
Please take the time to understand our Code of Conduct,
apply the principles to the work you do every day and
speak up if you have concerns about any behaviour
you feel is in breach of this Code.
Ngā mihi,
Greg Foran
Chief Executive Officer
BACK TO CONTENTS
Contents
A Message From Greg 0
About our Code of Conduct 1
What is it? 2
The Code Applies to All of us 2
Comply with the Law 2
Refer to the Code and Ask Questions 3
Make a Commitment 3
Speak Up 4
Our Business Principles 7
Operate Safely, Responsibly and Reliably 11
Safety 12
Avoiding Alcohol and Other Drugs 14
Crisis, Emergency and Business Disruption Management 15
Airline Security 17
Environment Sustainability 18
Sponsorship, Grants and Donations 18
Act with Integrity, Honesty and Transparency 21
Be Free of Conflicts of Interest 22
Using our Digital Communication Systems 24
Exchanging Gifts and Entertainment 25
Using Business Resources 28
Travelling for Business 29
Speaking on Behalf of Air New Zealand 31
Using Social Media 32
Protect our People, Property and Information 35
Financial Integrity 36
Committing to Contracts and Expenditure 37
Accurate and Complete Information, Records,
Reporting and Accounting 38
Protecting Privacy and Confidentiality 39
Information Security 40
Protecting and Respecting our Property 44
Treat People Fairly and with Respect 47
Diversity and Inclusion 48
Merit-based Recruitment and Selection 49
Preventing Bullying and Harassment 50
Ethical Business Practices of Suppliers 51
Comply with the Law 53
Anti-money Laundering 54
Ensuring Continuous Disclosure 55
Eliminating Bribery, Corruption and Improper Payments 56
Avoiding Insider Trading 57
Competing Fairly 58
Administration of the Code 60
Living our Code 61
© Air New Zealand 2016 AIR NEW ZEALAND CODE OF CONDUCT
ABOUT OUR
CODE OF CONDUCT
BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 1
ABOUT OUR CODE OF CONDUCT
What is it? The Code applies to all of us Refer to the Code Make a commitment
The Code of Conduct (‘Code’) sets out what we expect The Code applies to all Air New Zealanders globally –
and ask questions As Air New Zealanders, we are all expected to live our
Leadership Behaviours and ‘do what’s right’ in our daily
from every person working for and with Air New Zealand, including our executives, employees, contract workers or work and actions:
regardless of location, and confirms our commitments agents who provide services on our behalf, subsidiaries, Please read the Code and refer to it often. It’s your
to our people, our business partners and stakeholders. and directors. guidebook for doing what’s right. To supplement the • Act safely, ethically and responsibly – taking pride
general guidance of the Code, Air New Zealand has in your actions and decisions.
The Code brings together all of our policy principles, We expect our suppliers and business partners to uphold more specific policies and standards that apply • Comply with the principles in this Code and fulfill
and provides a working guide for employees to do the right equally high standards, and abide by our Supplier Code globally, geographically or to certain divisions, your legal and regulatory obligations.
thing when making decisions in our daily activities. of Conduct. functions or departments.
• Hold your colleagues accountable for
It is absolutely essential that all Air New Zealanders read, Take the time to understand the policies that are referred behaving ethically and following this Code
understand and live by this Code. to throughout the Code and how they apply to you in your and legal requirements.
While the Code provides guidance on standards of integrity
and business conduct, it doesn’t attempt to address every
Comply with the law role. You are encouraged, and expected, to seek additional
help whenever you have questions or aren’t sure about
• Speak up if you see behaviours which are unsafe,
unethical or in breach of our Code.
situation that we might encounter. Refer to the Business the right course of action. Managers, Human Resources
Principles to guide your behaviour and decisions, keeping Our Code reinforces our commitment to both the letter and and our Risk & Compliance team are available to help you
in mind our Brand Values and Leadership Behaviours which spirit of our legal requirements and our policies, standards if you need them. Our leaders have additional responsibilities
underpin all of our actions. and business principles. under the Code:
The airline industry is highly regulated by local government • Enforce the Code consistently for all your employees.
and the governments of other countries where we do
• Where there is a conflict between our ethics and
business. Without exception, Air New Zealand observes and
business objectives, our ethics must always come first.
complies with all applicable laws, rules and regulations.
• Support appropriate business conduct and ethics
However, our Code cannot cover all laws, regulations and compliance activities.
other legal requirements in all countries we operate in.
Always be familiar with the relevant laws and regulations • Make sure appropriate controls are in place in your
that apply where you work. If there is a difference between team.
a local legal requirement and our Code, apply the most • Never cover up or ignore any business conduct or
stringent standard. If in any doubt, contact your manager ethical problem; address the matter immediately and
or our Legal team. seek guidance if necessary.
• Encourage your team members to ask questions and
raise any conduct or ethical concerns by:
– Encouraging them to speak up
– Dealing with concerns when they are raised
– Making sure that no one who speaks up is treated
We need all Air New Zealanders unfairly as a result
to read, understand and live
by this Code.
BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 3
ABOUT OUR CODE OF CONDUCT
Speak Up If you are faced with a difficult issue,
ask yourself:
Q. I am concerned that my colleagues Q. What if I report something
will find out if I raise a concern. suspicious that turns out not
Will it be kept confidential? be a breach of compliance?
Don’t ignore behaviour that is unacceptable, even
small things, because we believe small actions can
A. Yes, Air New Zealand will not A. As long as your report was made
make a big difference. Is it legal and ethical? tolerate retaliation against anyone in good faith because of a genuine
We encourage everyone to raise concerns about who raises, in good faith, a genuine concern, no action will be taken
potentially unethical or illegal conduct, while assuring concern. We will keep what you against you.
confidentiality and protection against retaliation or any Is it consistent with our tell us private throughout the
investigation process, subject to our
form of harassment. Our Just Culture policy and
procedures support a fair and confidential process. Business Principles and legal obligations. Your issue will be
kept confidential regardless of which Q. I have a concern about the
If you see behaviour at work that you feel may breach this Leadership Behaviours? method you use to report it. actions of a colleague.
How should I report this?
Code or seems illegal or unethical – like bribery, theft or
fraud, price fixing or a breach of data privacy – you must
A. The most important thing is that
report it, even if you only suspect it.
Does it comply with Q. I am a contractor working with
Air New Zealand and I have a
you report your concern. It doesn’t
matter which route you choose. If
You must also report abuse of our systems, processes or
policies. This could be bullying or harassment, potential our policies? concern to report. Can I use the you feel comfortable talking to your
Speak Up reporting line? manager, do that. Your manager is
conflicts of interest, or danger to the health and safety
there to support you and can help
of employees or customers.
A. Yes, the Speak Up line is for you choose the correct course of
Can I explain it to family, employees and contract workers, action. Alternatively, you can contact
There are three ways to speak up: your HR Business Partner or use the
Report it to your manager
friends or colleagues? as well as suppliers and
business partners. Speak Up line.
We know it’s not always easy to raise your concerns.
We value open and honest communications, so you’re
encouraged to discuss any issues or potential issues Will I be comfortable if
with your manager.
Report it to your Human Resources team
it appears in the media?
If it’s not appropriate, or if you are not comfortable
discussing the issue with your manager, you should
discuss it with your HR Business Partner. Every business If the answer to any of these is NO, don’t do it.
area has one or more HR Business Partners – ask your
manager if you don’t know who yours is. If you are still unsure, seek help by talking to
Report it confidentially using the Speak Up line your manager, HR Business Partner or the Risk
You may want to report your concern to someone who is & Compliance team.
independent from the situation. Search Speak Up on the
intranet to find the phone numbers, or form to make
a report online. The standard you walk past is
Air New Zealand has a non-retaliation policy when a the standard you accept.
genuine concern has been reported. This means that no
action will be taken against you if you report concerns in
Lt. Gen. David Morrison, Australian Army Chief
good faith, even if proven not to result in a breach.
For safety-related incidents or issues, continue to use
our safety reporting process as a first priority.
POLICIES COVERED:
JUST CULTURE AND REPORTING POLICY
RISK MANAGEMENT POLICY
BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 5
OUR
BUSINESS PRINCIPLES
BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 7
OUR BUSINESS PRINCIPLES
Our Business Our Business Principles are the foundation
of how we do business everywhere we operate,
Principles
and reflect the commitments we make to our
people, our business partners and stakeholders.
These are at the heart of our Code of Conduct.
Operate safely, responsibly and reliably Act with integrity, honesty and transparency Protect our people, property and information Treat people fairly and with respect
• We will protect the health, wellbeing, safety and security • We will avoid any activity or contracts that may lead • We will base our investment decisions and business • We will treat people fairly, with dignity and will pursue
of our customers, employees and the communities in to, or suggest, a conflict of interest between personal relationships on economic criteria from objective and equality of opportunity and inclusion for all employees
which we operate. activities and Air New Zealand. complete due diligence information. through our employment policies and practices.
• We will not tolerate anyone being affected by alcohol or • We will build trust through integrity, transparency, • We will not commit to expenditure without We value diversity of people and thought.
other drugs in the workplace. honesty and objectivity in our business dealings appropriate authorisation. • We will recruit, select and develop our people on
• We will operate our business with discipline and excellence and relationships. • We will only spend company money where there is merit – irrespective of age, race, colour, origin, gender,
to ensure sustainability, resilience and effectiveness. • We will use business resources in the best interest a legitimate business need and where the cost is worth religious beliefs, disability, family or marital status, sexual
of Air New Zealand and not for personal gain. the benefit. orientation or other prohibited grounds.
• We will protect and safeguard the natural environment,
minimising our use of finite resources and the release of • We will communicate honestly, responsibly and • We will take into account social, ethical and • We will not accept any form of discrimination,
harmful emissions to the environment. transparently with all stakeholders within the bounds environmental considerations in our procurement harassment or bullying.
• We will invest in society and communities ensuring of commercial confidentiality. and supply chain decisions. • We will perform at our best, demonstrating
effective use of our resources and in line with our mission. • We will secure and safeguard our confidential and professionalism, living our values and operating with
sensitive information from improper disclosure to acute customer focus at all times. We will proactively
prevent harm to Air New Zealand, our stakeholders, address under-performance.
employees or customers who have trusted us with • We will work in good faith, within the appropriate legal
their information. framework, with trade unions and other bodies that our
• We will protect and safeguard our brand, property, people collectively choose to represent them.
intellectual property and financial assets. • We trust each other to deliver on our commitments and
• We will respect people’s legal rights to privacy and the obligations, and value collaboration as the best means of
confidentiality of personal information. working together to achieve superior outcomes.
• We will empower our people to enhance their personal
potential by offering satisfying and challenging work
and career opportunities, investing in development and
Comply with the Law
personal growth.
• We will reward and recognise our people for work which
contributes to our mission to supercharge New Zealand’s
• We will comply with all applicable domestic and
success, and for demonstrating the right behaviours that
international laws and regulations, appropriate standards
reflect our values.
and principles, including all competition, anti-trust and
anti-money laundering laws. • We will respect people’s lives outside of work, balancing
life activities, and valuing their contribution to society.
• We will not tolerate any form of bribery, including
improper offers of payments or gifts to or • We will not tolerate child labour and are committed to the
from employees. elimination of all forms of forced and compulsory labour.
BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 9
OPERATE SAFELY,
RESPONSIBLY
AND RELIABLY
BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 11
OPERATE SAFELY, RESPONSIBLY AND RELIABLY
Safety Q. Should I report an incident even if it We will protect the health, wellbeing,
didn’t result in an accident or injury?
safety and security of our customers,
Safety at Air New Zealand is a top priority. A. Yes. Report any incident no matter employees and the communities in
We are committed to achieving a Zero Harm work how small. Tell your manager
environment and instilling a culture of safety and straightaway so we can take action to which we operate.
prevent similar incidents happening
continuous improvement. We expect everyone in the future.
at Air New Zealand to behave in a safe and
responsible manner at all times.
Q. If I report a safety issue, will I
get in trouble if I’m the one who
What this means for you: made the error?
• You are responsible for your own safety and wellbeing,
A. No, as long as it wasn’t done
and the safety of your colleagues and our customers. recklessly or with malicious intent.
• Only undertake work if you are medically fit for duty, We are all human and sometimes
sufficiently rested and alert to carry it out. we genuinely make mistakes or
errors. We encourage everyone to
• Comply with applicable safety laws and follow the safety report any safety-related incident or
procedures and requirements specific to your area. situation without fear of retaliation or
• Never compromise on safety or knowingly create punishment. Being open and honest
situations where the safety and wellbeing of any person about safety issues is important
is put at risk. Intervene where you see unsafe practices to our Just Culture philosophy and
helps us prevent any future
or non-compliance with procedures.
safety risks.
• Prevention is critical – identify and report any hazards.
• Report events immediately where safety and wellbeing
have been compromised, including any near miss,
Q. I see colleagues talking on their
incident, accident, injury, illness, unsafe or
mobile phones while driving all the
unhealthy condition.
time. Is this ok?
• If injured, ensure you do all you can in your recovery and
rehabilitation for a safe and timely return to work. A. No. Nobody should use a handheld
• Always drive safely, responsibly and legally when mobile device while driving any
vehicle used for work purposes,
operating company vehicles or on company premises.
including vehicles such as baggage
Never use handheld mobile devices while driving.
trolleys and forklifts. trolleys
• Where your attention to safety is critical, limit using and forklifts.
mobile devices in the workplace.
POLICIES COVERED:
PEOPLE HEALTH SAFETY AND WELLBEING POLICY
AIRLINE SAFETY POLICY
ACCEPTABLE USE OF BUSINESS RESOURCES POLICY AND SUPPORTING STANDARDS
BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 13OPERATE SAFELY, RESPONSIBLY AND RELIABLY
We will not tolerate anyone We will operate our business
being affected by alcohol or with discipline and excellence to
other drugs in the workplace. ensure sustainability, resilience
and effectiveness.
Avoiding Alcohol Q. What if I’m on call after hours and at
weekends? Does this mean that I am
Crisis, Emergency and
and Other Drugs unable to consume alcohol for that
period of time?
Business Disruption
Alcohol and other drugs must never affect A. Being on call to respond to work
Management
us in our work. Our safety, and that of our related situations is typically
considered to be ‘on duty’ or an Crisis, emergency and business disruption
colleagues and customers, depend on it.
extension of your duties. Therefore, management is important to protect our people
Therefore, you must maintain a zero blood if you are rostered or paid to be on and reduce any damage or loss. Effective
alcohol level and be drug free while working. call, you must remain alcohol and
drug free. In cases where you are crisis, emergency and business disruption
This includes being free from the negative
called on for work when you’re not planning ensures we’re committed to health and
effects of legal drugs, such as prescription expecting it, safety must always safety, minimising damage and impact to the
medication. Any possession, use, sale or come first – so let the caller know
if you’re not alcohol or drug free so
Company, and keeping our operations going
distribution of illegal substances at work will
they can find an alternative person. after any disaster. We must retain a high level of
be treated very seriously. Air New Zealand
preparedness to respond to any type of business
provides support to those affected by
interruption in any location where we might have
problems with alcohol or other drugs. Q. I have been invited to a corporate
function held after hours. Am I people, property or assets.
allowed to have a drink there?
What this means for you: A. Any time you are representing What this means for you:
• Never work, under any circumstances, while affected Air New Zealand at a function, keep
by alcohol or any other drug that impairs judgement,
in mind that your behaviour will • Know your individual responsibilities and follow crisis,
reflect on the Company’s reputation. emergency and business disruptions procedures,
performance or behaviour – be drug free and maintain
Alcohol consumption in social including knowing local emergency contact details.
a zero blood alcohol level. settings and at corporate functions
• Never drive a vehicle used for business purposes during after hours is acceptable, provided • Assist in developing and implementing local crisis,
that all formal business has emergency and business disruption plans for your
work hours or on work duties if you aren’t drug and
been completed, alcohol is used business area as requested.
alcohol free.
responsibly, and you are not on call • Continually assess risks and any financial, reputational
• Don’t use, sell, distribute or be in possession of alcohol or or otherwise expected to return to and other non-financial threats that may impact your
other drugs while working or while on our premises. work. If driving afterwards, ensure
business area.
• Discuss with the Medical team prescription medication or you are within legal limits.
other legal drugs which may impair your ability to work.
• Test and practice your crisis, emergency and
business disruption procedures to improve response
• Don’t store or consume alcohol on our premises unless it’s Q. What about drinking while preparedness.
authorised (e.g. sponsored and supervised functions on I’m on Duty Travel?
our premises).
• Debrief following an event to ensure lessons are learned
and actioned.
• Report in confidence any concerns you have about your A. Any time you are travelling for work,
use good judgement. Ensure that
own use, or a colleague’s use, of alcohol or other drugs to
any consumption of alcohol before,
our Medical team for support and advice.
during or after travelling will enable
• You may be required to undergo alcohol and other drug you to comply with the policy when
testing for safety sensitive roles and where there is cause. you are next expected to work.
Familiarise yourself with local
drug and alcohol laws, cultures
and customs when travelling for
POLICIES COVERED:
business purposes. POLICIES COVERED:
ALCOHOL AND OTHER DRUGS POLICY CRISIS, EMERGENCY AND BUSINESS RESILIENCE POLICY
BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 15OPERATE SAFELY, RESPONSIBLY AND RELIABLY
Q. I’ve seen people ‘tailgate’ me
through the security doors without
swiping their card. What should I do
in these situations?
A. Tailgating through security access
doors is not permitted – you must
swipe through. Next time this occurs,
Airline Security politely ask the tailgater to swipe
their own card, and ensure you’re not
followed through the security door.
Global security remains volatile and we must
take our safety and security seriously. We are
all responsible for having a high level of security Q. I’ve noticed visitors walking around
the office unescorted without a
awareness and consistently applying appropriate
security ID or visitors badge on. Is
security measures to protect our customers, that ok?
employees, assets, premises and property in
our care. A. No. People must be authorised to
be taken into secure areas – i.e. any
area that requires a password or
swipe entry. All visitors must register
What this means for you: at reception, wear a security badge
• Always wear your security ID in secure areas so it is visible to enter a secure work area and be
to others – make sure it’s current, accurate and valid for the escorted by an Air New Zealander at
all times. If you see someone without
area in which you work (restricted vs non restricted).
a visible ID, first phone Security to
• Immediately report to our Security team any actual or report the breach, then approach
perceived security risks, weaknesses, threats, or unusual the person and politely question who
or suspicious activity or behaviour. they are here to see, and escort them
to the main reception area to wait for
• Vigilantly adhere to safety and security protocol, standards their contact.
and practices at all times, and follow requirements specific
to your area.
• Never bring unauthorised individuals into secure areas Q. Part of my uniform went missing
without the appropriate security checks and authorisation. from my hotel room on my last Tour
Always escort your visitors while they are on the premises of Duty. Is that a big deal?
– never leave them alone in secure areas.
A. Yes. Uniforms should be treated as an
• Report any loss of property straight away, including
item of security. You must report any
security ID cards, Air New Zealand uniforms or branded
theft or loss of a company uniform to
work wear, to local police and our Security team. police and our Security team. There
• Store equipment and other property securely to prevent is a very real possibility that lost or
unauthorised use or theft. stolen uniform items could be used to
do harm by posing as an employee to
• Read travel advisories and security tips before travelling get into secure areas.
overseas for business.
Refer to the Information Security section for protecting and
securing data and information. Q. Should I report a small incident,
even if it didn’t result in major
security breach?
A. Yes, report it to the Security team.
Without knowledge of security
incidents or events - including
potential threats - we are not able
to fully assess risk. What you might
think is an isolated incident may in
POLICIES COVERED: fact be one piece of a larger puzzle.
SECURITY POLICY
BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 17OPERATE SAFELY, RESPONSIBLY AND RELIABLY
Q. I serve on the board of directors Q. My team wants to raise money
of a non-profit organisation that for a local charity. Are there any
supports environmental initiatives. restrictions on who to donate to?
Can I guarantee the board that
We will invest in society Air New Zealand will donate to A. No, there are no restrictions on giving
and communities ensuring the organisation? personal donations. These should be
done in your own time and with your
effective use of our resources A. No. You must make clear that your own resources.
participation on its board is in
and in line with our mission. your individual capacity and that
it is unlikely that you will be able
to secure any donation from Air
New Zealand. If the organisation
has historically received donations
Environment Sponsorship, Grants or has a formal relationship with
us, approval for the directorship
Sustainability and Donations is required in advance of you
accepting a board position.
We are committed to preserving and protecting As New Zealand’s national carrier, we are
New Zealand’s natural environment for the committed to using our resources to enrich
future. We take responsibility for operating in an our communities, protect the environment
environmentally sustainable way, minimising and promote New Zealand. We support
Air New Zealand’s impact on the environment legitimate and worthy causes aligned to our
and improving our energy performance. purpose, mission and values, including those
based on humanitarian needs. Through
proper governance of grants, sponsorships
What this means for you: and donations, we protect Air New Zealand’s
• Comply with applicable environmental laws reputation with all stakeholders.
and regulations.
• Report any non-compliance with environmental
laws and regulations to your Property and What this means for you:
Facilities Manager.
• Ensure all sponsorships or donations are
• Do your bit to reduce, recycle, reuse and be energy appropriately authorised.
efficient in your work environment.
• Ensure that your participation in personal fundraising
• Support using and procuring sustainable energy- activity is not construed by the public as being endorsed
efficient design, products and services to help by, or on behalf of Air New Zealand.
improve our energy performance.
• Never request sponsorships or use company money to
• Educate, support and encourage others (including make charitable donations to close deals, seek favours
suppliers and customers) to take responsibility for from decision makers, support illegal activity or for
efficient energy practices in their workplaces personal gain.
and communities.
• Raise questions about any potential conflict of interest
• Support company environmental or appearance issues that may arise from charitable
sustainability initiatives. donations or sponsorships.
• Never use company money to make donations to political
parties, campaigns or candidates.
We will protect and safeguard
the natural environment,
minimising our use of finite
resources and the release
of harmful emissions to the
environment.
We’re proud to partner with the Department of
POLICIES COVERED: POLICIES COVERED: Conservation bringing some of New Zealand’s
SUSTAINABILITY POLICY SPONSORSHIPS AND DONATIONS POLICY rarest birds back to their natural homes.
BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 19ACT WITH
INTEGRITY,
HONESTY AND
TRANSPARENCY
BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 21ACT WITH INTEGRITY, HONESTY AND TRANSPARENCY
Q. I work part-time in my family’s Q. A close friend is applying for a job at
business. Do I need to disclose Air New Zealand. Is this ok?
an interest?
A. Absolutely. We encourage you to
A. Yes, even if the business is not recommend Air New Zealand as a
related to Air New Zealand, you great place to work. However, you
must disclose it, as it may become need to ensure that you are not
a conflict if it affects your health, involved in the recruitment process
job performance or the quality of and that the job your close friend is
your work. applying for does not report to you
Be Free of Conflicts (either directly or indirectly).
of Interest
We must all be free from actual, perceived What this means for you: Here are some examples of when you might face a conflict of interest.
or potential conflicts of interest. A conflict • Act in Air New Zealand’s best interest and make
of interest can happen if an employee’s objective decisions. Friends, relatives and co-worker relationships Outside activities or investments
personal, social, financial or political activities • Discuss conflict of interest concerns with your Business relationships with relatives, spouses, partners/ You may have a personal interest in one of Air New
interfere (or could be seen to interfere) with manager, disclose all conflicts and report them on significant others or close friends can lead to a conflict Zealand’s existing or potential competitors, suppliers
their judgement in work-related decisions. the Conflicts of Interest Register. of interest. We don’t prohibit family members or friends or customers, which might affect or compromise our
Whenever possible, conflicts of interest • Remove yourself from business decisions or processes from being employed by the Company, or close personal business, or your ability to perform your job. These
should be avoided. If they arise, always where you have a personal interest. relationships between co-workers. However, a relative or situations can create an actual or perceived conflict
close personal friend cannot have any business dealings of interest if they involve you:
disclose them immediately. Even the • Never get involved in hiring, supervising, managing,
with you, anyone who reports to you (direct report), or
appearance of a conflict of interest can promoting, rewarding, or advancing any relative, close • Having a second job
anyone working in your business unit (indirect report).
be harmful and needs to be addressed. friend or partner. • Serving as a director or consultant, or providing
Similarly, intimate relationships of any duration between co-
• Never affect or influence the terms and conditions workers can, depending on the work roles, create an actual professional services
of a contract for service, or for employment, of any or apparent conflict of interest. • Having material financial interests in a competitor,
employee, contractor or supplier who is a relative, supplier or customer, or
Q. Do conflicts of interest include If you are faced with the possibility of a business or personal
close friend or partner.
people I have close personal relationship conflict of interest, you should disclose it to • Taking part in civic or public duties.
relationships with as well as • Avoid working or consulting for, or providing your manager, so the potential conflict can be managed.
actual relatives? professional services to, anyone external that you As a general rule, you may work, or consult, for other
deal with as part of your job for Air New Zealand. We must all exercise care when providing travel services organisations while employed at Air New Zealand as
A. Yes. Any close relationship, no to relatives, friends or co-workers. Providing preferential long as you inform your manager and gain appropriate
matter how current, that may create
• Never use business resources for personal political
treatment to them is not allowed – this includes approvals from the Legal team before accepting the
an actual or perceived conflict activity, make political donations in Air New Zealand’s
unauthorised deviations from established rules for pricing, work. Outside activities should not interfere or conflict
of interest is included. We can’t name, or give the impression that the Company
issuing, exchanging or refunding tickets, inappropriate with your job responsibilities – for example, scheduled
list every activity or relationship. endorses any candidate, campaign or political issue.
upgrades, improperly withholding seats from inventory hours, overtime when required, or job performance.
However, a conflict of interest • Never provide sensitive or confidential information to or blocking space and ignoring boarding priorities. This includes selling goods or services for personal
includes any activity that could a competitor or third party, including friends or profit during work time or using your employment
interfere with your objectivity to
relatives – see the Competition Law section. at Air New Zealand as an endorsement for
Air New Zealand.
See our Subsidiary Directorships Policy and Industry personal business.
Associations Policy for information on the invitations We will avoid any activity or Knowingly maintaining substantial financial interests
Q. My colleague’s son just joined our for directorships within the Air New Zealand Group or
team. Is this allowed? for Group representation on industry association contracts that may lead to, or or investments in a competitor, customer or supplier
without disclosing them is not allowed.
A. Unless local policy prohibits it,
boards/committees. suggest, a conflict of interest
relatives can work in the same between personal activities
team, department or business unit. Political or civic involvement
The only rule is that no relative and Air New Zealand. If you are involved in civic or political activities, it must
can ever be in a position to either
hire, supervise, affect the terms be on your own time, and with your own resources. You
and conditions of employment should never use Air New Zealand resources such as time,
or influence the management of property, material, cash, equipment or branding for political
another relative. donations or activities.
POLICIES COVERED:
CONFLICT OF INTEREST POLICY
SUBSIDIARY DIRECTORSHIPS POLICY
BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 23ACT WITH INTEGRITY, HONESTY AND TRANSPARENCY
Exchanging Gifts
and Entertainment
We support reasonable and proportionate giving We will build trust through
and receiving of gifts and entertainment as part of
a normal business relationship or cultural practice. integrity, transparency,
They’re permitted as long as they’re ethical, honesty and objectivity in
Using our Digital Q. I use a range of internet and social
related to Air New Zealand business, infrequent,
low in value, legal and customary in a business
our business dealings
Communication Systems
media sites for my job. Why are
some sites blocked? relationship. We prohibit the giving or receiving of
and relationships.
significant gifts or significant benefits (including
A. We encourage the use of the
For many of us, the use of the Company’s intranet, hospitality, discounts and other benefits not
internet for research, training and
internet, phone and email systems is critical to our collaborating in the context of your available to all employees).
jobs. Air New Zealand invests in strengthening our job. Some sites are not appropriate Q. I’ve been sent a high value gift by
for the workplace, don’t have We need to ensure we are never influenced, a supplier and don’t want to cause
digital workforce and provides access to a range
appropriate levels of security or are or seen to be influenced, by gifts or entertainment offence by returning it. What should
of IT resources to connect and collaborate as one used predominately for personal I do?
or other inducements during a tender process
Air New Zealand. These systems and resources, use. In these cases, the sites have
been blocked. If you run into issues, or when signing a new deal. These actions can A. Notify your manager and seek
such as Wi-Fi, are intended to be used for business
contact the IT Service Desk for create conflicts of interest, or raise questions guidance from the Legal team. Ideally,
purposes. As a user of these resources, you have information and assistance. you should politely refuse and return
about our judgement.
access to valuable information, sensitive data the gift. If this is not possible, then the
and internal and external networks that must be item should be donated to charity.
protected and used responsibly. Q. I recently noticed that a colleague
in my department spends a lot of What this means for you:
work time on the internet and social • Seek approval and record gifts, hospitality and entertainment Q. I work at checkin. A regular customer
networking sites, despite a backlog on the Gifts Register if valued at NZ$250 or more.
What this means for you: offered me a tip as thanks for taking
of incomplete projects. Is this ok?
• Avoid giving or accepting anything of inappropriate value. care of a reconnection on his last
• Use digital communication systems and other IT trip. He then asked me to upgrade
resources in a responsible, ethical and legal manner. • Avoid giving or accepting any gifts or entertainment during him to business class outside of
A. No. Personal use of company a tender process that would be perceived as preferential
Don’t use them for any illegal, unethical, or objectionable appropriate guidelines. What should
resources (including Internet and
activities such as gambling, pornography or other treatment or providing an unfair advantage. I have done in this situation?
email) should be limited and never
inappropriate subject matter. interfere with job responsibilities. • Think about the context of the gifts, entertainment or
A. The best course of action is to
• Don’t use company computers and equipment for outside His or her use of social networking hospitality – imagine how it might look to someone outside of
thank the customer for their
businesses, personal gain or personal activities. sites is likely to be excessive and Air New Zealand. thoughtfulness and politely decline
could even lead to damaging
• You are personally accountable and liable for all activities computer viruses. You should • Never accept any cash or cash equivalent, even as a tip for accepting the tip, ensuring that you
great service. operate within established rules
associated with your user accounts and company report the issue to your manager.
regarding upgrades.
equipment. • Never give or accept gifts from competitors or public officials.
• Incidental personal use of IT resources (email, internet, • Never ask for gifts, entertainment or any other inducements.
social media) at work is acceptable as long as it: Q. A colleague in my team manages the
• Discuss any concerns with your manager.
– doesn’t affect your, or others’ job performance or relationship with a wholesale travel
productivity, and agency on behalf of Air New Zealand.
‘Gifts and entertainment’ include anything of value offered to or Last week, I heard the agency offered
– doesn’t interfere with operations or system received by you or a member of your family. ‘Gifts’ include cash my colleague a significant discount
performance (e.g. sending large personal files) or and non-cash items. ‘Entertainment’ is where you accompany for personal travel that isn’t available
consume significant time or resources, and a third party to an event. Entertainment should be treated as a to other employees. Is this allowed?
– doesn’t create risk to Air New Zealand as a result of gift if the party who made the offer does not plan on attending.
your personal use, and ‘Inducements’ are gifts, entertainment, services or benefits for
the purpose of securing business or favourable terms outside A. No. By offering this discount to your
– doesn’t violate other company policies.
of the normal process. colleague, which is not available to all
employees at Air New Zealand, the
Review the Bribery and Improper Payments section for agency created a conflict of interest
additional guidance on inducements. between official company business
and your colleague’s personal gain.
POLICIES COVERED: POLICIES COVERED:
ACCEPTABLE USE OF BUSINESS RESOURCES POLICY GIFTS AND ENTERTAINMENT POLICY
BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 25We need all Air New Zealanders to read, understand and live by this Code. BACK TO CONTENTS
ACT WITH INTEGRITY, HONESTY AND TRANSPARENCY
We will use business
resources in the best
interest of Air New Zealand
and not for personal gain.
Using Business Resources Q. I’ve seen colleagues checking out
flight details and seat assignments
Travelling for Business
of celebrities who fly on Air New
Resources are provided to you to perform Zealand. Is this allowed? At times, employees need to travel for work. As an
the requirements of your job. We must all use airline, we must balance the needs of commercial
A. Definitely not. Unless these
business resources responsibly and only for customers with our business travel requirements.
individuals are directly booking or
business purposes. All business resources have altering a customer’s travel plans, When planning your trip, use your judgement to
an economic value, so use them effectively. employees are not allowed to access find the right balance between business need,
confidential information out of
environmental impact, financial cost and your
personal interest. We should always
Common business resources include: protect the identity, privacy and health and safety. Q. My travel costs into the office
• IT resources and computer equipment safety of our customers. are expensive. Can I claim some
of it back?
including access to electronic information,
networks, software, internet, systems and What this means for you:
Q. I sometimes use my company A. No. Normal travel to and from
equipment such as desktops, laptops, phones, laptop to respond to personal • Only travel on business when there is a genuine need, work can’t be claimed as a travel
and mobile devices emails, do my personal online where travel is authorised and pre-approved. Manager expense – this cost is considered
banking and for other personal approval is required for domestic or intra-regional your responsibility and not a
• Business-related travel activities at home? Is this ok?
business travel; international travel requires additional business expense.
• Budgets, expenditure and company credit cards A. Our preference is that you use
GM approval (or Chief approval for GMs).
• Office furniture, equipment and supplies business resources for business- • Use the defined procedures to book travel (e.g. through Q. I travel regularly for business.
related work. In principle, business Tandem Travel for International travel and your local Can I access the Koru Lounges
• Branded material and official company images resources provided to you for work travel arranger for domestic or regional travel) – never when I’m travelling so I can work
and content are not intended to be a replacement book your own business travel, including flights, more productively?
for personal resources, however accommodation and rental cars.
• Company-provided vehicles and car parks. incidental and occasional use of IT A. Access to our Koru Club Lounges is
resources is acceptable where the • Use preferred suppliers to help minimise the for members only. If you personally
cost and risk to Air New Zealand cost of travel. have a membership, then you can
is negligible. We ask that you use • Only claim business expenses that are necessary use the Koru Lounge whenever
What this means for you: common sense and good judgement. you travel (we offer a discount to
and reasonable for your business travel. Use a
• Use business resources and assets for company employees who purchase Koru Club
company credit card for travel-related expenses
memberships). Some roles require
business – this includes money, equipment, materials, whenever possible.
Q. Can I use my company credit card business travel so regularly that the
information and time.
to pay for personal items, especially • Ensure you are medically fit for your planned travel and Company purchases a Koru Club
• Only use resources that you are authorised to use and if I’m short on cash? I would pay it review safety protocols and security advisories for your membership on their behalf. In these
complete all necessary authorisations. back to the Company, of course. destination – discuss any concerns with our Safety and cases, where there is capacity, staff
Security teams. may access the Lounge.
• Only access or use authorised resources or information
where there is a legitimate business need and not for
A. No. Never use a company credit card,
• Personal travel is not be taken in conjunction with
personal interest or gain. business-related travel. Q. I’m travelling overseas for business
or any company funds, to pay for
• Use resources responsibly and cost effectively. personal items. • To reduce risk, executives, management groups or and would like to add on some annual
leave at my cost. Is this allowed?
• Don’t engage in personal activities during work hours other key individuals should avoid travelling together.
that interfere with you fulfilling your job responsibilities. • Maintain professionalism at all times – you are an A. No. Annual leave cannot be taken
Q. I have access to company tickets to
• Take all reasonable and necessary steps to protect ambassador for the airline. together with business travel.
a sporting event that are being used
company resources and assets, including the for marketing promotions. Can I give Air New Zealand honours any provision in employment However, there are times when it is
prevention of theft. them to a friend who works at a hotel agreements regarding duty travel, where it differs to policy. acceptable to add, for example, a
in exchange for a free hotel room for weekend to a planned business trip.
• Use business resources in line with our confidentiality Because of the potential conflict of
my personal use?
and privacy guidelines. interest, you must openly disclose
A. No. The tickets are considered your intent, gain approval from your
POLICIES COVERED: company property and cannot be Chief, and ensure that there is no
ACCEPTABLE USE OF BUSINESS RESOURCES POLICY AND SUPPLEMENTARY used for personal gain. POLICIES COVERED: financial impact to Air New Zealand.
STANDARDS DUTY TRAVEL AND TRAVEL-RELATED EXPENSES POLICY
BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 29ACT WITH INTEGRITY, HONESTY AND TRANSPARENCY
We will communicate
honestly, responsibly and
with transparency with all
stakeholders within the bounds
of commercial confidentiality.
Q. A local reporter has contacted me
through a mutual friend to ask me
Speaking on Behalf
about this year’s Annual Report.
Can I comment?
of Air New Zealand
A. No. Only authorised spokespeople As a publicly-listed company, we are bound
for Air New Zealand can provide by strict rules to ensure that publicly released
comment to the media. You should information is appropriately disclosed and
put the reporter in touch with our
Corporate Communications team accurately reflects the Company’s position.
on the 24 hour media line: (+64) No one should make comments on behalf of
021 747 320. Leaks of company Air New Zealand unless they are an authorised
or confidential information to the
media will be treated very seriously. spokesperson or have prior approval from
Corporate Communications. This includes when
contributing to professional journals or presenting
Q. I’ve been invited to speak at a at industry association conferences.
professional conference in my
area of expertise. Do I need
permission to speak on behalf
of Air New Zealand? What this means for you:
A. Yes. You need to gain approval • Only make comments on behalf of Air New Zealand if you
from your GM before speaking are authorised to do so. This includes passing on to third
at conferences. If you plan on parties information intended for internal use only.
using Air New Zealand material, • Direct any media enquiries or requests to the Corporate
Corporate Communications Communications team.
must review your content to
protect against disclosing • Never disclose commercial or strategic information
confidential, sensitive or about the Company, our employees or our
proprietary information customers without permission, even after you leave
Air New Zealand.
• Return any unsolicited confidential information you
receive to the sender or ensure it’s deleted.
• Gain approval from your GM and have your content
reviewed by our Corporate Communications team
before contributing to professional journals or
speaking engagements.
POLICIES COVERED:
MEDIA COMMUNICATIONS POLICY
BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 31ACT WITH INTEGRITY, HONESTY AND TRANSPARENCY
Q. Am I allowed to say where I work
on my social network profile?
A. Yes. You can disclose on your
‘About’ page or bio that you are an
Air New Zealander, which part of the
Using Social Media What this means for you: organisation you represent and what
your responsibilities are. You may
• You are personally responsible and liable for anything want to include a link to the
you post online, whether speaking personally or in an Air New Zealand website.
We recognise the importance and benefit of
official capacity for Air New Zealand.
communicating through social media. We want
to empower all our employees to be good
• Separate your personal social media sites and accounts
from work-related ones. Avoid using Air New Zealand Q. I have an issue with my manager
ambassadors for our brand, but be mindful of sites to distribute personal communications, and never and said so recently in my Facebook
what you post online as it could have unintended page. Was this wrong?
use official company images on personal social media.
consequences. • Clearly show when posts or comments are your own A. Yes. You should discuss any issues or
views, and not that of Air New Zealand’s, when you talk concerns you have about your job or
Follow these general guidelines when using about work related matters. work environment with your manager
social media – both inside and outside of using the normal processes, rather
• Don’t disclose information about others, misuse
the Company: than posting to social media sites.
personal data or post photos without their knowledge
and permission.
Think before you post – Remember
• Be mindful of copyrights, trademarks and intellectual Q. On my last tour of duty, I took this
that whatever you share may be public property rights of others. Never post copyrighted great photo with a celebrity who was
for an indefinite period of time (even material without the appropriate permissions (including flying with us. Can I post it on social
published music, movies or video content). media?
if you attempt to delete it), and will be
associated with you, your profile, and • Honour any confidentiality and non-disclosure A. No. Even though taking and posting
Air New Zealand. requirements, even on personal sites. ‘selfies’ have become the norm, we
• Never post information about legal matters, including must protect our customer’s privacy
Be truthful, accurate, and respectful – corporate transactions or investigations. and safety as a priority. Avoid asking
customers for autographs, photos, or
Don’t make statements that are false, • For security reasons, never post details (including videos any favour that encroaches on their
misleading or unsubstantiated. Respect or photos) of any secure or restricted area, such as personal privacy. And never take
other people’s views, even if you disagree aircraft hangars or maintenance areas, runways, airline or post photos of our passengers,
passenger areas, interiors of aircrafts cabins, cockpits, or make comments about them
and always be polite and courteous. on social media, unless it is with
under carriage, landing gear and baggage holding areas.
permission and authorised by
Use good judgement and common Corporate Communications.
sense – Don’t post items that could
reflect negatively on Air New Zealand, You are personally responsible
Q. I saw a negative post on social
or are legally protected (e.g. confidential and liable for anything you media about Air New Zealand.
or private in nature). Avoid topics that Should I respond?
could be inflammatory, or inappropriate, post online, whether speaking
including personal work-related concerns personally or in an official A. No. As a general rule, avoid the
temptation to respond directly to
or issues. capacity for Air New Zealand. negative posts about the Company
on social media unless you respond
Do no harm – Don’t post material with approved messaging from
considered to be illegal, abusive, Corporate Communications. Keep
in mind that we have dedicated
discriminatory, defamatory or offensive. teams tasked with responding to
customer enquiries or complaints.
When in doubt, contact Corporate
POLICIES COVERED:
Communications.
SOCIAL MEDIA POLICY
BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 33PROTECT
OUR PEOPLE,
PROPERTYAND
INFORMATION
BACK TO CONTENTSPROTECT OUR PEOPLE, PROPERTY AND INFORMATION
Financial Integrity Q. I think my manager is claiming for
expenses that aren’t really business-
Committing to Contracts Q. Where do I find out the details of my
Delegated Financial Authority?
We expect all Air New Zealanders to be good
related. What should I do? and Expenditure
A. Refer to the Delegated Financial
stewards of company funds and spend responsibly. A. You should speak to your HR Authority Policy on Korunet.
manager about your concerns. Air New Zealand is committed to sustainable
Our financial and accounting controls ensure we
Alternatively, use the Speak Up procurement and supply chain decision-making.
apply sound financial principles in our business reporting line if you feel it’s
By managing our supply chain decisions centrally, Q. Can I put a preferred supplier
transactions. Clear policies and strict guidelines are more appropriate.
contract in place by myself?
we will minimise our impact on the physical
used in our financial planning, budgeting, monitoring
environment, deliver optimal financial outcomes,
and evaluation. We are all responsible for following A. No. All supplier contracts and
our policies and legal, financial and accounting We will only spend company and enhance our competitive advantage. We have agreements are managed centrally.
defined processes for interacting with suppliers, Contact Procurement for more
regulations. Our managers have an extra duty to money where there is a negotiating supply contracts and making information.
ensure that their teams manage expenditure within
legitimate business need purchasing decisions. Legally binding contracts,
budget and spend company money carefully.
(See Committing to Contracts and Expenditure and where the cost is worth with agreed terms and conditions, are required
Q. Why does Procurement need to
before we can commit our resources. Without
for more information). the benefit. We will base these agreements, we are open to financial,
approve suppliers before we can
order from them?
When assessing value for money, consider: quality, our investment decisions commercial, tax and legal risk.
service, reliability, sustainability, compliance with and business relationships The Delegated Financial Authority (DFA)
A. We have a set of criteria used for
approving suppliers that takes into
our finance and procurement policies and any terms
and conditions. Make sound investment decisions
on economic criteria from shows what level of authority you need before consideration cost, environmental
factors and purchasing power.
capable of being validated and based on objective objective and complete due committing Air New Zealand to a contract or This helps us meet our sustainability
expense. Everyone is expected to understand goals, mitigate risk of conflicting
and economic criteria. diligence information. how the DFA rules apply to their role. supplier commitments, provide
more cost-effective procurement
and ensure the quality of goods
What this means for you: and services.
What this means for you:
• Understand the financial management responsibilities,
policies and processes relevant to your role. • Only commit to a contract or incur expenses where you
• Understand when you can and when you can’t commit
are authorised and within your delegated limits. We will not commit to
company funds. • Use defined processes and approved suppliers when
expenditure without
sourcing and purchasing goods and services.
• Strive to find the best value when spending company money.
• Obtain DFA approval for every purchase, requisition or appropriate authorisation.
• Only spend company funds on legitimate business needs. order you make. We will take into account
• Keep expenditure within budget. •
• Ensure your decisions are sound, and based on
Ask Purchasing if you’re in doubt before ordering a
product or service.
social, ethical and
objective information. environmental considerations
• Run transparent tendering processes for suppliers in our procurement and
and business relationships.
• Report suspected misuse of company property or funds.
supply chain decisions.
POLICIES COVERED:
POLICIES COVERED: PROCUREMENT POLICY
FINANCE AND ACCOUNTING POLICIES DELEGATED FINANCIAL AUTHORITY POLICY
BACK TO CONTENTS AIR NEW ZEALAND CODE OF CONDUCT / 37You can also read
