Employment Hero Code of Conduct

Employment Hero Pty Ltd, and our affiliates (Employment Hero, EH, we, or us) exist to make employment easier, fairer, and more accessible. We build software and services that help businesses employ people compliantly and confidently, and help employees better understand and manage their working lives. We operate in line with our values – we are bold and ambitious; we invent; we are one team; we serve; and we own it, because how we behave matters just as much as what we build. This Code of Conduct (Code) is our overarching ethical framework and sets out the standards we expect from everyone who works for, with or represents Employment Hero. 

Who this Code applies to: 

This Code applies to everyone acting on behalf of Employment Hero, referred to collectively as “you”: 

• Directors, officers, employees and contractors of Employment Hero (collectively Heroes); and
• Consultants, suppliers, Employment Hero partners, and any other person or entity representing or acting on behalf of Employment Hero (collectively, Business Partners). 

How to use this Code:

This Code serves as an overarching framework for our ethical standards. It is designed to be your first point of reference:

• For Business Partners: This Code is your primary guide and defines the standards you must uphold in your dealings with us. Business Partners are also expected to extend these principles to their own suppliers and subcontractors where reasonably practicable.
• For Heroes: This Code provides a snapshot of the obligations detailed in our internal Global Policies. You should look to this Code first to understand our expectations before referring to specific policies for deeper operational guidance.

All persons covered by this Code are expected to understand and comply with its standards and to raise concerns about potential breaches via grc@employmenthero.com or the internal mechanisms referred to in the ‘Whistleblowing and Speaking Up’ section of this Code. Breaches of this Code may result in disciplinary action (including termination of employment or engagement), termination of commercial arrangements, civil liability or criminal penalties. Employment Hero reserves the right to verify compliance with this Code, including by requesting relevant documentation or conducting assessments.

Employment Hero may update this Code from time to time, and the most current version will be made available on our website. Heroes and Business Partners are responsible for ensuring that their activities remain in alignment with the standards set out in this Code as updated from time to time. 

Our Shared Standards

The following Shared Standards apply to all Heroes and Business Partners and reflect the baseline expectations for anyone who works for, with, or represents Employment Hero.

Compliance with Laws

As a global business, Employment Hero is subject to a wide range of laws and regulatory requirements, including those relating to governance, compliance, employment, privacy, financial reporting, anti-corruption, and competition. Where local laws or regulations differ from this Code or EH policies, you must comply with applicable laws and seek guidance before following local customs or practices that may conflict with EH standards.

Professional and Ethical Conduct 

You must act honestly, fairly and in good faith in all dealings connected with Employment Hero. Conduct that is misleading, deceptive, fraudulent or otherwise unethical is not tolerated. You must not engage in conduct that could damage Employment Hero’s reputation, compromise the integrity of our operations, or undermine trust in our business, customers, partners or colleagues. 

Anti-Bribery and Anti-Corruption 

Employment Hero maintains a zero-tolerance approach to bribery and corruption. You must not offer, promise, authorise, give or accept any bribe, facilitation payment, kickback or other improper benefit intended to influence a business decision. You must comply with all applicable anti-bribery and anti-corruption laws. Heroes must also comply with our internal Anti-Bribery and Anti-Corruption Policy.

Competition and Fair Dealing 

We compete vigorously but fairly. You must not engage in anti-competitive conduct such as price fixing, market allocation, bid rigging, misuse of market power, or the inappropriate exchange of competitively sensitive information. If you interact with competitors, you must ensure discussions remain lawful and appropriate.

Respect, Inclusion and Equal Opportunity

Employment Hero is committed to maintaining a safe, inclusive and respectful environment free from unlawful discrimination, harassment, bullying and victimisation. Employment decisions must be based on merit, capability, and legitimate business considerations. We do not tolerate discrimination or harassment on any ground protected by applicable law. All individuals must treat others with dignity and respect.

Heroes are expected to comply with our EEO and Discrimination Policy and Harassment and Bullying Policy. Business Partners are expected to uphold comparable standards within their own operations and when interacting with Employment Hero personnel.

Human Rights and Modern Slavery

Employment Hero is committed to respecting internationally recognised human rights and to preventing modern slavery, human trafficking, forced labour, child labour and other forms of exploitation in our operations and supply chains. We maintain a zero-tolerance approach to these practices and report annually on our modern slavery risks and mitigation measures in our Modern Slavery Statement.

Heroes must comply with our Modern Slavery Policy, remain alert to modern slavery risks within Employment Hero’s operations and supply chains, support reasonable due diligence measures, and promptly raise concerns about suspected unethical or unlawful labour practices.

To ensure alignment with global ESG standards and human rights legislation,Business Partners must:

• Compliance: Comply with all applicable modern slavery, labour, and employment laws in the jurisdictions where you operate.
• Forced & Child Labour: Strictly prohibit the use of forced, bonded, indentured, or involuntary prison labour, and ensure no child labour is used in any part of your business or subcontracting chain.
• Wages and Conditions: Provide a safe and hygienic work environment and compensate workers in compliance with all applicable local wage laws (including minimum wage, overtime, and mandated benefits).
• Respect & Dignity: Ensure a workplace free from inhumane treatment, including sexual harassment, corporal punishment, or physical/mental coercion.
• Freedom of Association: Respect workers’ lawful rights to free association and collective bargaining.
• Due Diligence & Transparency: Conduct reasonable due diligence within your own supply chains and provide information reasonably requested by Employment Hero to verify compliance.

Information Security and Acceptable Use

Protecting Employment Hero’s systems, platforms and data is fundamental to maintaining the trust of our customers, Business Partners and Heroes. All Heroes and Business Partners must take reasonable steps to safeguard Employment Hero’s information assets against unauthorised access, misuse, interference, loss or disclosure. 

Employment Hero maintains a comprehensive Information Security Management System (ISMS) supported by formal security policies and procedures, details of which are available in our Security Trust Centre. Our security framework is independently certified against recognised industry standards, including ISO/IEC 27001, ISO/IEC 27017 and ISO/IEC 27018, and is subject to independent SOC 2 assurance reporting. 

Heroes must use EH systems responsibly and only for authorised purposes, comply with access controls and internal security requirements, protect credentials and sensitive information, and promptly report suspected security incidents or vulnerabilities in accordance with applicable policies. 

Business Partners who access EH systems or process EH data must:

• Implement appropriate technical and organisational security controls;
• Comply with contractual security and data protection obligations; and
• Cooperate with reasonable security assessments, due diligence and audit requests.

Data Protection and Privacy

Employment Hero is committed to protecting personal information and handling it lawfully, transparently and securely in accordance with applicable privacy and data protection laws. Information about our approach to privacy is set out in our publicly available Privacy Policy, Applicant Privacy Policy, Cookie Policy, Data Processing Addendum and List of Subprocessors. 

Heroes must only collect, access, use or disclose personal information for authorised business purposes, protect it from unauthorised access or misuse, and promptly report suspected data breaches or privacy incidents in accordance with internal procedures and policies. Business Partners who process personal information on behalf of Employment Hero must comply with applicable data protection laws, act only in accordance with contractual instructions, implement appropriate safeguards, and notify Employment Hero of any actual or suspected data breaches without undue delay.

Confidentiality Obligations

In the course of working with Employment Hero, you may have access to confidential or commercially sensitive information. In addition to any contractual confidentiality obligations, you must:

• Protect confidential information from unauthorised access, use or disclosure;
• Use confidential information only for authorised business purposes; and
• Continue to comply with confidentiality obligations after your employment or engagement ends.

Financial Integrity and Record Keeping

Employment Hero complies with applicable accounting, financial reporting and regulatory requirements in all jurisdictions in which we operate. All business records, whether financial and non-financial, must be accurate, complete and fairly reflect the underlying transactions and activities. False, misleading or incomplete records, or the circumvention of internal controls or approval requirements, are strictly prohibited. All transactions must be properly authorised and recorded in accordance with applicable laws and internal controls. Records must be retained and disposed of in line with legal and internal requirements. Business Partners are expected to maintain accurate books and records relating to their dealings with Employment Hero and to comply with applicable legal and contractual obligations.

Work Health and Safety

Employment Hero is committed to providing a safe, healthy and respectful working environment. All Heroes and Business Partners must take reasonable care for their own health and safety and that of others, comply with applicable work health and safety laws, and promptly report hazards or incidents. Heroes must comply with the Work Health and Safety Policy and the Alcohol and Drugs Policy, follow all safety procedures relevant to their role, and ensure they are fit for work and not impaired while performing duties. Business Partners must maintain safe and lawful working conditions within their operations and ensure their personnel are fit for work when performing services for Employment Hero. 

Environmental Sustainability

While Employment Hero operates primarily as a technology platform, we acknowledge that our activities have environmental impacts. We are committed to:

• Using resources efficiently and responsibly;
• Reducing waste and promoting responsible consumption practices;
• Considering environmental impacts in procurement and vendor selection decisions where reasonably practicable;
• Encouraging sustainable practices within our workplaces, including remote and hybrid work arrangements;
• Supporting responsible environmental practices across our supply chain where reasonably practicable; and
• Complying with all applicable environmental laws and regulatory requirements.

Heroes are expected to act in a manner that supports responsible environmental practices in their day-to-day activities and decision-making and to raise concerns about practices that may pose environmental or regulatory risk via the internal mechanisms referred to in the ‘Whistleblowing and Speaking Up’ section of this Code. Business Partners are expected to operate in compliance with applicable environmental laws and to maintain responsible environmental practices within their own operations and supply chains.

Political Engagement and Government Interaction

Employment Hero is an apolitical organisation. We do not make political donations or contributions to political parties, candidates or elected officials. Where we engage with governments, regulators or industry bodies, we do so transparently, constructively and in compliance with applicable laws, and solely in relation to matters affecting our business, industry or customers.

Heroes may participate in political activities in a personal capacity, provided such activities do not conflict with their obligations to Employment Hero, do not use company resources, and do not imply endorsement by Employment Hero.

Additional Requirements for Heroes

Nothing in this section limits Employment Hero’s rights under employment contracts, contractor agreements, or applicable workplace laws.

External Communications and Public Representation

Heroes represent Employment Hero in their interactions with customers, partners, communities, regulators, governments and the broader public. All external communications must be professional, accurate and consistent with Employment Hero’s values. Heroes must not make unauthorised public statements on behalf of Employment Hero, including to the media, regulators or through social media platforms. Requests for official statements must be referred to the appropriate authorised representative and regulatory inquiries must be escalated appropriately. Heroes must not disclose confidential, commercially sensitive or personal information and comply with the Social Media Policy.

Intellectual Property 

All intellectual property created by a Hero in the course of their employment or engagement, or using Employment Hero resources, that relates to Employment Hero’s business, products or services, belongs to Employment Hero unless otherwise agreed in writing. Heroes must comply with the Copyright and Intellectual Property Policy.

Use of Artificial Intelligence and Machine Learning

Employment Hero supports innovation and the responsible use of artificial intelligence (AI) and machine learning (ML) technologies to improve efficiency, creativity and service delivery. However, these tools must be used thoughtfully, ethically and in a manner consistent with our legal and regulatory obligations.

We ensure transparency in how we deploy our AI-powered products and features through our AI Services Statement. This statement is a detailed transparency resource, providing specifics about the AI features and products we offer and assuring customers of how we responsibly deploy them. Our commitment to Responsible AI is further outlined on our dedicated web page, which is designed to inform the world about how we embrace AI in an innovative yet responsible manner, detailing the values and principles we apply.

Heroes must ensure that the use of AI or ML tools, including generative AI platforms, automated decision systems, data analytics tools and code-generation systems, does not create legal, security, privacy, discrimination or reputational risk. In particular, Heroes must:

• Not input confidential, commercially sensitive, personal or customer data into unauthorised or publicly available AI systems;
• Ensure any AI tool used in the course of employment has been approved or assessed in accordance with internal governance and risk processes;
• Apply appropriate human oversight and professional judgment to AI-generated outputs and not rely solely on automated outputs for material decisions;
• Take reasonable steps to verify the accuracy, completeness and appropriateness of AI-generated content, including code, advice, communications or analytical outputs;
• Ensure AI tools are not used in a way that could result in unlawful discrimination, bias or unfair treatment, particularly in employment-related or customer-facing decisions;
• Respect intellectual property rights and ensure that AI-generated materials do not infringe third-party rights;
• Where AI tools are used in product development, engineering, or system design, comply with the Software Development Life Cycle (SDLC) Policy; 
• Not use AI tools in a manner that circumvents established controls, misrepresents authorship, or creates misleading outputs presented as verified fact;
• Comply with the Data Protection Policy, Employee Privacy Policy, and Data Classification and Handling Policy when handling personal or sensitive information; and
• Immediately report suspected AI-related security incidents, data exposures or unintended disclosures in accordance with the Information Security Incident Response Plan and Data Breach Policy.

Conflict of Interest

Heroes must avoid situations where personal interests conflict, or appear to conflict, with their obligations to Employment Hero. Conflicts must be managed in accordance with internal governance requirements and, where relevant, the Anti-Bribery and Corruption Policy.

Gifts, Entertainment and Hospitality

Heroes must exercise sound judgment when offering or accepting gifts, entertainment or hospitality. Benefits must not improperly influence, or appear to influence, business decisions. Heroes must not solicit gifts or accept bribes, kickbacks or improper benefits. Heroes must comply with the Anti-Bribery and Corruption Policy and any internal approval requirements.

Donations and Sponsorships

Charitable donations and sponsorships made on behalf of Employment Hero must align with our values and be appropriately authorised. Employment Hero supports community initiatives, including through the Hero Foundation, in a transparent and responsible manner. Heroes must not commit Employment Hero to any donation or sponsorship without proper approval in accordance with internal delegation requirements.

Whistleblowing and Speaking Up

Employment Hero encourages Heroes to speak up about suspected misconduct, unlawful behaviour or breaches of this Code. Reports may be made via grc@employmenthero.com in accordance with the Whistleblower Policy, Grievance Handling Policy, or other applicable reporting mechanisms. Employment Hero does not tolerate retaliation against any Hero who raises a concern in good faith or participates in an investigation.