The Warehouse Group Limited (TWG) is committed to the highest degree of integrity and honestly in the conduct of its business affairs. 

The highest possible standards of ethical and business conduct are required of TWG team members and directors in the performance of their responsibilities and duties. It is the responsibility of every team member and director to encourage other team members and directors to ask questions, seek guidance, report suspected violations, or express their concerns regarding compliance with this standard of conduct. 

You must conduct the Company’s business affairs with the highest personal integrity. In every business transaction and negotiation, you are expected to respect the rights of competitors, customers, suppliers and other team members. You must comply with any laws governing price fixing and other trade practices.

1. You are responsible for conducting yourself in a manner that upholds TWG's standards, values and policies.
   
2. You are accountable for TWG’s business conduct, must obey the laws which apply to the business, and must live up to the standards and values expressed in this policy. Your actions will be reviewed under this policy, applicable TWG policies and the laws of the relevant country that you are based in or the laws of New Zealand.
   
3. If you do not act in accordance with this policy and applicable policies and laws, you may be subject to disciplinary action. TWG cannot and will not compromise compliance with this policy or applicable policies or other laws to meet financial plans or maximize profits.
   
4. In addition to company disciplinary actions, violations of many provisions of this Code are against the law and may subject a violator and/or TWG to severe penalties, fines or other consequences.
   
5. You have a responsibility to promptly notify immediate Managers or Department Heads of any violations of this policy whether by suppliers or other team members. You will not be subject to reprisals for reporting, in good faith; actions you feel violate this policy. We further expect you to fully cooperate in any investigation of an alleged violation or other business conduct.
   
6. Where TWG reasonably believes that any team member or director has been involved in any criminal conduct, TWG will co-operate fully with any police or other governmental agency investigation and the criminal proceeding of any charges laid.
   

1.  Purchase without prejudice for the overall benefit of TWG.
   
2. Conduct business in a highly ethical manner; be honest, courteous and professional in our business affairs.
   
3. Strive to obtain the maximum value for each dollar of expenditure.
   
4. Purchasing requirements should routinely be subjected to competitive evaluation.
   
5. Conflicts of interest with the business of TWG must be avoided.
   
6. Conduct business with potential and current suppliers in an atmosphere of good faith, devoid of intentional misrepresentation.
   
7. Demand honesty in sale representation whether offered thorough the medium of verbal or written statement, an advertisement or sample of product.
   
8. Maintain confidentially regarding quotations, price or other confidential information involving TWG’s suppliers and competitor dealings.
   
9. Gifts or rewards from supplier or potential suppliers must be given to the manager for redistribution regardless of the type of gift or its value. All gifts or rewards are regarded as TWG’s property and must be reported to your Manager and entered on the Gift Register. There may be occasions where TWG solicits certain items from other persons or organizations in support of special company-sponsored events. In these circumstances, solicitations may only be made in furtherance of the event and for no other reason. All solicitations must be coordinated with the person or persons designated by senior management to be responsible for coordinating the special events.
   
10. Supplier sponsored trips are generally discouraged. Where such trips are requested, they require departmental manager prior approval in writing.
    
11. Buyers must not take for themselves, or divert to another person or company, a business or financial opportunity which they know, or could reasonably anticipate, TWG would have an interest in pursuing.
    
12. Buying team members are expected to comply with both the letter and spirit of this policy.
    
13. When making sourcing decisions buyers must remain mindful of the Social Policy Section of TWG’s Terms of Trade (Section 6) concerning a supplier’s obligation to comply with the laws and standards of the countries in which the suppliers are doing business, including the labour and employment laws of those countries and any applicable New Zealand laws.   Buyers must as a minimum refer suppliers to these Terms of Trade so as to ensure suppliers are aware of them.  Buyer’s sourcing decisions must show clear preference for those suppliers who are accredited (Accredited Suppliers), or working towards accreditation (Probationary Suppliers) as to their compliance with said Social Policy.  In the case of a decision to shift business from a known Accredited or Probationary Supplier, buyers must require that the prospective new supplier undergo The Warehouse Supplier Factory CSR Assessment prior to the placement of any purchase order.  Details of existing Accredited and Probationary suppliers are available from the compliance manager based in The Warehouse Corporate Affairs Department or from the Warehouse Direct Sourcing Office.
    
14. Dependent Suppliers. Buyers, when working with suppliers who, by virtue of the majority share of business they have with TWG, are vulnerable to sudden changes or discontinuity or cessation of business with the TWG, must subject any decision to cease or dramatically reduce purchasing, to review and approval by their Merchandise Manager and a representative from Corporate Affairs.
    

1. You are required to conduct yourself in a manner and with such ethics and integrity so as to avoid a conflict of interest, either real or apparent.
   
2. A conflict of interest is any circumstance where an individual's personal interest interferes or even appears to interfere with the interests of TWG. You have a duty to avoid financial, business or other relationships that might be opposed to the interests of TWG or might cause a conflict with the performance of their duties.
   
3. A conflict can arise when you take actions or have interests that may make it difficult to perform your work for TWG objectively and effectively. Conflicts also may arise when you or a member of your family, receives improper personal benefits as a result of your position in TWG.
   
4. Some of the areas where a conflict could arise include:
   

1. Giving or accepting gifts that equal more than the amount that would be considered customary courtesies may be deemed a bribe. Bribes are strictly prohibited by law and are against TWG policy. A bribe can expose you to criminal penalties. Company payments (regardless of amount), or gifts or entertainment of any value to officials and other personnel of any governmental of Council agency or department are not permitted. cf. 9 above.
   
2. If confronted with a demand for a payment, gift, entertainment or the like, you must inform your Manager and Department Head.