Business Code of Conduct

Our Company

Starshine Marketing and its associated companies are committed to excellence and innovation, in developing and marketing our brands and associated products. Our Business Code of Conduct reflects on how, as a company, we wish to conduct ourselves and how our business partners conduct themselves to ensure the highest level of integrity and compliance.

In working with, or associated with Starshine Marketing you are expected to act and conduct yourself in the manner consistent with our key values and company rules and this Code.

1. Purpose Of The Code

Our company Code of Conduct (this Code) has been written in accordance with the spirit and values that we wish to adhere to and maintain at all times.

  1. Each Director and Team Member is to read this Code – to ensure that you understand and acknowledge its relevance to the core of our business.
  2. Support this Code at all times whilst you are an employee, contactor or Business Partner.
  3. Apply this Code in your everyday business activities and dealings in the best interests of the company, our customers and associated business partners.
  4. Understand as a Director, Team Member, Contractor or Business Partner you will be continually assessed to ensure that our policies and procedures are being adhered to and that legal, corporate and government compliances are being maintained.
  5. All Directors, Team Members, Contractors and Business Partners will be advised of any additions or updates to this Code.

2. Who The Code Applies To

  • Company Directors
  • Executive Managers
  • Permanent Team Members
  • Part-Time Team Members
  • Casual Team Members
  • Contractors or Consultants
  • Third Party Suppliers
  • Wholesalers or Retail Business Partners
  • Associated Business Partner

3. Our Company Values

Our Company values represent who we are as a company and must be respected and adhered to. It reflects how we conduct ourselves in business, dealing with our customers, how our brands are represented and who we associate ourselves with in relation to Third Party Suppliers and Wholesalers or our products.

Our core values are:

  • - Honesty
  • - Integrity
  • - Accountability
  • - Customer and Service Focused
  • - Transparency

In working at, or with, Starshine Marketing you are expected to adhere to this Code and be consistent in your everyday business dealings.

  • At all times maintain and exceed customer expectations.
  • Act within the work environment to uphold the principles of equal opportunity, and create and maintain a workplace free of discrimination, harassment and bullying.
  • All of our business dealings are to be conducted ethically across all areas of our business and meet all legal and compliance requirements.
  • And that our financial, business and retail dealings do not any anytime conflict with our company principles and the law.

4. Your Responsibilities

At all times when representing our company and our brand in your work or work related situations or events you will:

  • Act in accordance with the company’s work ethics, brand values, and this Code.
  • Understand within your work area the relevant Starshine Marketing policies and procedures and compliance and laws associated with your role and your relevant job description.
  • Fulfil your contract of employment or company contracts as stated.
  • Where you may think a breach of the company code has taken place report this to your Line Manager and Starshine Marketing Human Resources Manager. Where it is an outside Third Party, any breach is to be brought to the attention of the Company Directors.
  • Within your Team area maintain and keep the Company Code of Conduct accessible for all staff/team members to access.
  • Ensure when dealing with Third Parties they are aware of this Code and what is required as a business partner associated with Starshine Marketing.

5. A Safe And Equal Workplace

Starshine Marketing values an equal and fair workplace and is committed to upholding these values – within our own Team Members, Suppliers, Wholesales and our Customers.

You are committed to:

  • Treating everyone that you interact with during your course of your employment or association with our company with respect.
  • Working within the law and its compliances.
  • Do not harass or discriminate against people in the provision of our goods or services – including recruitment, training, remuneration and other associated human resource matters.
  • Report any breach of any human resource regulations to the Human Resources Manager or senior executive.

6. Retail and Wholesale Fair Trading

Starshine Marketing and its associated companies, is committed to fair trading and to maintain compliance at all times.

We are committed to:

  • Dealing and treating our customers with respect at all times.
  • At no time is a Team Member to give or offer their personal contact details. All customers are to be directed to Company telephone and contact details.
  • Promoting and selling our brands and products in an honest and trustworthy manner.
  • Following all required safety procedures and product information procedures. And when required carry out product recalls from retail as set out by the company in line with local laws.
  • Ensuring that are no time are our products sold to minors, the intellectually impaired or those consumer who may not understand what it is that they are being presented with.
  • Ensuring that our retail outlets and retail partners market and price our brands and products in accordance with the relevant laws of those markets we trade in.
  • Ensuring our customers are not harassed bullied or forced into buying a product that they do not wish to purchase by our company or business partners sales teams.
  • Ensuring that our customer’s right to return or refund the value of the product is maintained under the consumer laws in the markets that we trade in.
  • Ensuring that those companies who wholesale or sell our brands and products outside of Starshine Marketing’s retail outlets do so in accordance with this code. Those companies that do not abide by this code will be terminated as our business partners.

7. Dealing With Our Competitors

  • At no time will we try to disrupt or deal unfairly with our competitors or restrict their trading.
  • At no time will we enter into any pricing discussions or agreements with our competitors.
  • At no time will we try to restrict the market through bad business practices against competitors.

8. Confidential and Proprietary Information

Integral to Starshine Marketing’s business success is our protection of confidential company information, as well as non-public information entrusted to us by employees, customers and other business partners.

  • Confidential and proprietary information includes such things as pricing and financial data, customer names/addresses or non-public information about other companies, including current or potential supplier and vendors. Stakeholders must not disclose confidential and non-public information without a valid business purpose and proper authorisation from Starshine Marketing.
  • Stakeholders acknowledge that disclosure of confidential information may cause irreparable harm to Starshine Marketing.

9. Use of Company Resources

  • Company resources, including time, material, equipment and information, are provided for company business use. Nonetheless, occasional personal use is permissible as long as it does not affect job performance or cause a disruption to the workplace.
  • Stakeholders and those who represent Starshine Marketing and who have access to the Company’s resources must behave responsibly and use good judgment to protect the Company’s resources. Managers are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use.
  • Generally, Stakeholders must not use company equipment such as computers, copiers and fax machines for a purpose unless it is a Starshine Marketing purpose except as authorised by the Company from time to time.
  • Stakeholders must not solicit contributions nor distribute non-work related materials during work hours.
  • All resources accessible by Stakeholders are owned by the Company. In order to protect the interests of Starshine Marketing and Stakeholders, Starshine Marketing reserves the right to access, monitor, and review or delete all data and information contained on a Stakeholder’s Company-issued computer or electronic device.
  • The Company reserves the right to monitor all internet activity using company resources.
  • The Company will not tolerate the use of company resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate.

10. Conflict of Interest

The Company expects that Stakeholders will perform their duties conscientiously, honestly, and in accordance with the best interests of the Company. Stakeholders must not use their positions or the knowledge gained as a result of their positions for private or personal advantage. Stakeholders must not conduct themselves in a manner that conflicts with their duty to serve the Company’s best interest.

  • Conflict of interest will arise (for example) when a Stakeholder is involved in a business decision of the Company and at the same time, the Stakeholder may benefit from that business decision personally or allow someone he or she knows to benefit from the decision. For example, awarding a contract of supply to a friend or family member.
  • Regardless of the circumstances, if Stakeholders sense that a course of action they have pursued, or are presently pursuing, or are contemplating pursuing may involve them in a conflict of interest with the Company, they should immediately communicate all the facts to their supervisor.

11. Representing the Company

The value of the Company’s reputation and good will (name) must be protected and upheld whenever Stakeholders represent the Company. This extends to speaking on business matters in a public setting or posting any information on the Internet – including through social media applications and websites.

  • Stakeholders represent the Company. Accordingly, all Stakeholders acting on behalf of the Company, in any capacity, are to act professionally and with integrity at all times.
  • Stakeholders must perform their duties to the best of their ability with care, competence and efficiency and are to avoid situations where their actions, behaviours or conduct could reflect badly on the Company or impact negatively on them.
  • Stakeholders’ conduct after hours may also impact the Company and its good will and reputation. Stakeholders are reminded that their activity after hours will encroach and impact their Company activity during business hours.

12. Protecting and Enhancing Starshine Marketing’s Image, Profitability and Success

This means that Stakeholders and employees in particular must:

  1. Dress and appear clean, tidy and appropriate for the employee’s position and in accordance with health and safety requirements and any other Company policy related to personal presentation. And where indicated appear in the company brand uniforms;
  2. conduct themselves in a manner to uphold the reputation of the Company at every opportunity;
  3. Strive to ensure a high standard of work in everything employees do ensuring that work is carried out conscientiously, efficiently, economically and effectively;
  4. respect all other Stakeholders they come into contact with in the course of completing the Company’s duties; and
  5. not use their position for personal benefit independent from the business of Starshine Marketing or to benefit any other business or person.

13. Dealing With Outside People and Organisations

Employees must take care to separate their personal roles from their Company positions when communicating on matters not involving Company business.

Employees must not use Company identification, stationery, supplies, and equipment for personal, religious or political matters.

When communicating publicly on matters that involve Company business, employees must not presume to speak for the Company on any topic or bind the Company to any commitment, unless;

  1. They receive prior approval from the company;
  2. They are certain that the views they express are those of the company;
  3. They are sure that it is the company’s desire that such views be publicly disseminated.

When dealing with other Stakeholders or with third parties, including public officials, employees must take care not to compromise the integrity or damage the reputation of the Company, other Stakeholders or any third party.

14. Dealing With The Media

You are not permitted to engage in any communication with the media pertaining to the company. Any approach from any media outlet/source should be immediately directed to the Company Director.

The definition of the media constitutes the following:

  • Television/Electronic formats
  • Radio
  • All print media - including but not limited to newspapers, magazines, and trade media.
  • Social media - including but not limited to Facebook, Twitter and all other digital applications.

15. Uphold the Law and Policies

Starshine Marketing’s commitment to integrity begins with its commitment to comply with any laws that are applicable to its business operation.

  • Stakeholders must have an understanding of the Company policies and any laws, rules and regulations that apply to the Company’s business.
  • Stakeholders who are unsure of whether a contemplated action is permitted by law or Starshine Marketing policy, should seek guidance from their manager or supervisor.
  • Stakeholders are responsible for preventing violations of relevant laws and for speaking up if they identify possible violations.

16. Drugs and Alcohol

Except for prescription medicine, Starshine Marketing maintains a zero blood alcohol and drug free policy within its workplace. The Company has zero tolerance to breaches of this rule. This means that all Starshine Marketing Stakeholders must be free from alcohol and/or other drugs whilst:

  • At work or on duty;
  • On Starshine Marketing premises;
  • In Starshine Marketing uniform; and
  • Whilst representing Starshine Marketing in any capacity.

17. Gifts and Bribes

Stakeholders may be exposed from time to time to receiving gifts or be offered the opportunity to give gifts.

Gifts should never be offered or accepted by Stakeholders unless;

  • the Company is made aware of the gift; and
  • the Company approved of the gift.

Employees involved in a tendering process must refrain from actions which may give rise to an expectation of some favoured treatment from or by any tendering party.

Bribing, or attempting to bribe, a foreign public official (in or outside Australia) is a serious crime under Australian law with harsh maximum penalties (including imprisonment for individuals involved). The Company may also be liable for breaches by Employees.

Employees must ensure that they do not participate in any conduct which may directly or indirectly provide any benefit or advantage to a local or foreign public official where such benefit is not legitimately due or is intended to influence the local or foreign public official.

A gift in this Code means any present whether in cash or cash value which are not expected or forming part of the Stakeholders usual dealings with goods.


last updated version May 2016