Code of Conduct
Overview
1.1 Standards of Behaviour
Employees of SBS are expected to abide by the terms and conditions of employment set by SBS.
For most employees this includes any obligations set out in the SBS Enterprise Agreement, SBS Award,
SBS Codes of Practice, SBS Interim Protocol for New and Social Media Use and various programming
and policy documents and Editorial Guidelines.
SBS employees are expected to observe the requirements set out in this Code of Conduct. Refer to
section 3 of this Code of Conduct (Breaches of the Code of Conduct).
1.2 SBS Charter, Purpose and Values
1.2.1 SBS Charter
The principal Charter function of SBS is to:
provide multilingual and multicultural radio and television services that inform, educate and entertain
all Australians, and, in doing so, reflect Australia’s multicultural society.
The full text of the Charter is available in the SBS Act on the SBS Intranet (and in SBS’s
Corporate Plan
2013 - 2016).
As a public broadcaster, SBS is accountable to the Australian people through the federal parliament of
Australia. This accountability means that SBS must:
maintain the highest standards of integrity, impartiality and service; and
be focussed on producing exceptional quality radio, television and online services for all Australians;
and
ensure all SBS services are delivered in an extremely cost effective and professional manner.
1.2.2 SBS Purpose & Vision
SBS’s Purpose outlines how we put our Charter into effect.
SBS’s Purpose encapsulates the challenge set for us by the SBS Charter. Our Purpose is:
To inspire all Australians to explore and appreciate our multicultural world and contribute to an
inclusive society.
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SBS’s Vision is a statement of our aspirations. Our Vision is:
To make a vital difference through our distinctive role in Australia’s media landscape.
1.2.3 SBS Values
SBS’s Values underpin our success as an organisation. They inform our behaviours and actions, guiding
our decisions about what we do and how we do it and how we engage with each other, both internally
and externally.
Our Values are:
Creativity. This means:
Our content is thought provoking, bold and adventurous; we thrive on distinctive storytelling; and
We are continuously innovating and driven in everything we do.
Respect. This means:
We act with integrity, honesty and accountability; and
We are passionate and considerate in the way we interact with our audiences and each other.
Diversity. This means:
Embracing multiculturalism is at our core; and
The unique nature of people and cultures is a source of inspiration and we harness our
differences to improve performance.
Collaboration. This means:
We interact with transparency and openness with all stakeholders, internally and externally; and
Together we can make a difference.
1.3 SBS Corporate Plan
The SBS Corporate Plan outlines:
the strategic priorities of SBS; and
the goals of SBS for the 3 year period from July 2013 to June 2016;
the strategies SBS will implement to achieve its goals; and
the performance measures SBS will use to measure success in achieving its goals and strategies.
The Corporate Plan also sets out the parameters for all planning activities at SBS.
Please refer to
Corporate Plan 2013-2016 for details of SBS’s strategic direction and goals. The
Corporate Plan can be found on the SBS Intranet under Strategy & Communications.
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1.4 Assumptions
This Code of Conduct assumes that employees of SBS will observe and uphold relevant Federal and
State laws and policy. Compliance with these laws is a fundamental requirement of employment at SBS.
2. Code of Conduct
2.1 SBS Charter, Purpose and Values
All employees of SBS must, in the course of their employment, uphold and promote the Charter, Purpose
and Values of SBS.
2.2 General Behaviour
It is expected that SBS employees will:
(a) treat other SBS employees and members of the community with honesty, respect, and fairness,
courtesy and sensitivity;
(b) adopt a professional approach when dealing with other SBS employees and members of the
community. A professional approach includes using appropriate levels of:
skill;
care;
diligence;
impartiality; and
conscientiousness;
(c) comply with any lawful and reasonable direction given by another SBS employee who has authority to
give it; and
(d) maintain high standards of work performance.
2.3 Upholding SBS’s Reputation
SBS employees must not engage in any act, including using new or social media in a personal or SBS
capacity, which may compromise the reputation and integrity of SBS.
This includes:
(a) Not taking advantage of their employment with SBS in a way that may compromise the reputation and
integrity of SBS; and
(b) Being careful not to engage in activities in their private life that could adversely affect the reputation
and integrity of SBS.
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The obligations of SBS employees regarding the use of social media are set out in SBS’s Social Media
Protocol, which is available on the HR Intranet. All employees should familiarise themselves with their
responsibilities and obligations under the Protocol.
2.4 Conflict of Interest
“Conflict of interest” can be defined as:
“an employee having a direct or indirect involvement or interest in any matter or dealing with an
external individual or organisation, and from which the employee could receive personal reward,
remuneration or any other type of advantage as a result of the relationship of their position and that
particular matter or dealing”. (Section 25 SBS Accounting Manual)
SBS employees must avoid any direct or potential conflict of interest that could compromise SBS, and/or
disclose any current or potential conflict of interest to their Cost Centre Manager or Division Head.
It is impossible to formulate an exhaustive set of guidelines regarding what constitutes conflict of interest.
Therefore, in determining whether a conflict of interest has arisen or could potentially arise, Managers
and/or employees must consider:
the capacity of the employee to influence the dealings SBS may have with a third party; and
the level of personal benefit to the employee or third party that may result from exercising that
influence; and
the extent to which the other interests/ employment may conflict with their responsibilities and
obligations as an employee of SBS.
Conflict of interest may result from:
outside employment;
involvement with political parties and groups;
associations with community groups;
financial interest (direct or indirect) in a supplier or SBS contractor;
involvement with organisations or companies in competition with SBS; and
holding of company or other directorships.
Some examples of conflict of interest include:
Working for or at any other media organisation or other competitor of SBS (e.g. Language Services
provider);
Using or misusing any SBS resources for personal, employment or other interests;
Having a personal interest in a business that provides services to SBS;
Running for Government office.
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An employee must notify their Cost Centre Manager or Division Head in writing if any of the above
situations apply to them. In many cases, only the employee concerned will be aware of the potential
conflict. Therefore, it is the employee’s responsibility to notify their Cost Centre Manager or Division
Head of any other situation that may result in conflict of interest.
In respect of disclosure, SBS does not require information on any membership in organisations such as
political parties and community groups except where there is a reasonable belief that such membership
could give rise to a conflict of interest.
Section 25 of the SBS Accounting Manual outlines procedures that are to be taken to disclose any direct
or potential conflicts of interest. SBS expects employees to comply with those guidelines.
Section 4 of the SBS Editorial Guidelines outlines additional guidelines on Conflict of Interest for program
makers and content producers. SBS expects program makers and content producers to comply with
those guidelines.
2.5 Harassment, Bullying and Discrimination
SBS’s Elimination of Workplace Harassment policy outlines SBS’s commitment to providing a workplace
that is free from harassment, bullying and discrimination. The policy outlines obligations and expectations
of employees, supervisors and managers in the prevention and elimination of workplace harassment,
bullying and discrimination.
No harassment, bullying and/or discrimination will be tolerated, including the use of social media in
connection with a person’s employment at SBS to make inappropriate, threatening or offensive comments
about another employee. In addition to being unlawful, such behaviour is a breach of this Code of
Conduct.
2.6 Gifts and Benefits
SBS employees must not improperly use their position, status, power or authority to gain a benefit or
advantage for themselves or others. SBS employees therefore must not accept or give gifts and/or
benefits except where it is the custom and practice of a particular culture or organisation with which SBS
is dealing. If an employee does accept a gift and/or benefit they must ensure that it is accepted on behalf
of SBS, and inform their manager.
Section 26 of the SBS Accounting Manual outlines SBS’s policy and procedures relating to gifts and
benefits. SBS expects all employees to comply with this section. A copy of the Accounting Manual is
available on the SBS intranet (“Finance” site).
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2.7 Information, Facilities and Resources
SBS employees must use SBS information, facilities and equipment in an efficient, careful and honest
manner.
SBS owns all intellectual property in any material developed and/or made by employees in the
performance of their duties or in the course of their employment with SBS.
“Material” includes but is not limited to copyright, specific knowledge, documentation, files, processes,
technologies, databases, programs, recordings, films, musical compositions, software, trade secrets, etc.
SBS employees may not:
use SBS’s information, property, services or facilities; or
use material created in the course of their employment
improperly and/or for their own or any other person’s or organisation’s private benefit or gain. This
obligation continues during and after employment with SBS.
SBS employees must be mindful of the public interest and report any misuse of information, facilities or
resources to management.
SBS’s Computer, Email and Internet Usage Policy outlines acceptable use of information technology
resources including computers, email and internet. SBS expects employees to comply with this policy.
SBS will not tolerate any breach of this policy. A copy of the Computer, Email and Internet Usage Policy
is available on the SBS intranet (“People & Culture” site).
2.8 Privacy and Confidentiality
SBS employees have the duty to maintain the confidentiality, integrity and security of confidential
information for which they are responsible.
The
Privacy Act 1988 (“the Privacy Act”) governs the collection, storage and security, access and
correction, use and disclosure of personal information. The Privacy Act sets out the Information Privacy
Principles (IPPs) that govern the way SBS is to manage personal information. SBS employees are
subject to certain obligations, under the IPPs and SBS’s Privacy Policy, in relation to “personal
information” obtained during the course of their employment at SBS.
The Privacy Act defines “personal information” as:
“…information or an opinion, whether true or not, and whether recorded in a material form or not,
about an individual whose identity is apparent, or can reasonably be ascertained, from the information
or opinion.”
SBS employees are required to comply with the Privacy Act, IPPs and SBS’s Privacy Policy and ensure
that any “personal information” obtained by them during the course of their employment is not disclosed
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inappropriately and/or illegally, and that personal information is secured against loss and unauthorised
access, use, modification, disclosure or other misuse.
The
Freedom of Information Act 1982 provides a formal mechanism for the lawful disclosure of official
information and documents.
In addition to Privacy Act requirements, in the course of employment with SBS, employees may have
access to confidential and/or commercial-in-confidence information and/or material that must not be
disclosed inappropriately.
SBS’s Codes of Practice and Editorial Guidelines provide further guidelines on Privacy for program
makers and content producers.
See also 2.10 Public Comment.
2.9 Work Health and Safety (WHS)
SBS is committed to providing a workplace which is safe and without risk to health. Accordingly, SBS
views this commitment as an individual and collective responsibility of all employees.
SBS employees must not engage in any act, which risks the health and safety of themselves or others,
and must not interfere with any systems and/or equipment provided for the purposes of health and safety.
SBS employees are therefore expected to comply with SBS’s WHS policies and procedures.
2.10 Public Comment
SBS employees, as members of the community, have the right to make public comment and to enter into
public debate. However, there are some occasions where public comment by an SBS employee is
inappropriate.
“Public comment” includes views expressed in any forum or media, including social media, where it might
be expected that the comment will spread to the community at large.
SBS makes a distinction between public comment on “SBS matters” and “non SBS matters”.
2.10.1 SBS Matters
No SBS employee may make public comment about SBS matters without the authority of the Managing
Director or his or her delegate.
“SBS matters” include programming, editorial, employment and management policy and practices, and
any other matters relating to SBS’s operations.
2.10.2 Non-SBS Matters
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SBS is a publicly funded national broadcaster which must be, and be seen to be, objective and impartial.
There may be occasions when public comment on non-SBS matters by an employee acting as a private
individual could be detrimental to public perceptions of SBS’s independence, particularly when the
employee has a high public profile.
It is the responsibility of the employee to determine where there is the potential for such a situation to
arise and to ensure that their status as a private individual is clearly established before any public
comment is made. If the employee is in any doubt, they should seek advice from their manager.
2.11 Fraud
The term ‘fraud’ is used to describe illegal, unethical, improper or dishonest acts including, but not limited
to, deception, bribery, forgery, extortion, corruption, theft, conspiracy, embezzlement, misappropriation,
false representation, concealment of material facts and collusion. For practical purposes fraud may be
defined as the use of deception with the intention of obtaining an advantage, avoiding an obligation
and/or causing a loss to another party.
SBS, as a publicly funded broadcaster with responsibility for the appropriate use of taxpayer funds, will
not tolerate any acts of fraud perpetrated by an employee or contractor. SBS will refer any acts of fraud or
suspected fraud to the police and criminal or civil actions may be taken against employees or contractors
who participate in such unlawful acts.
SBS is not required to use a criminal conviction and/or prosecution of fraud as the basis for determining
whether an act is fraudulent and/or in breach of this Code of Conduct.
Any suspected case of fraud will be investigated by the relevant Manager/Supervisor and may be referred
to the SBS Board Audit and Risk committee by the Chief Financial Officer. Any internal investigation
should be conducted with reference to the SBS Internal Discussion, Counselling and Misconduct
Procedures and Section 22 of the SBS Accounting Manual.
Section 22 of the SBS Accounting Manual outlines the procedures for controlling fraud and cases of
suspected fraud. SBS expects employees to comply with this section.
3. Breaches of the Code of Conduct
3.1 What if the code is breached?
This code of conduct is provided so that standards of behaviour expected by SBS are clear to all
employees.
Breaches of this code are of serious concern to SBS. Accordingly, an employee who is found to have
breached any aspect of the Code of Conduct may be subject to disciplinary action in accordance with the
Informal Discussion, Counselling and Misconduct Procedures, up to and including termination of his/her
employment. A breach of the Code of Conduct may include an employee breaching any obligation set out
in the SBS Enterprise Agreement, SBS Award, SBS Codes of Practice, SBS Interim Protocol for New and
Social Media Use and various programming and policy documents and Editorial Guidelines.
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3.2 What if I suspect a breach of the Code of Conduct?
Employees who believe another person is breaching the Code of Conduct should discuss this with their
immediate supervisor and/or Cost Centre Manager.
Supervisors and/or managers who believe an employee is breaching the Code of Conduct should discuss
their concerns with People & Culture.
4. Further Information
If you are unsure of any aspect of the Code of Conduct you should discuss this with your immediate
Supervisor and/or Director.
Your People & Culture Business Partner is available to provide advice and assistance.
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