Corporate Social Responsibility & Ethical Stance Policy

1. Scope

This CSR Policy applies to Hurley Australasia Pty Ltd (Hurley) and its subsidiaries, employees, partners and suppliers.

2. Policy Statement

This CSR Policy will govern Hurley decisions and actions pursuant to its commitment to act responsibly and ethically in all aspects of its operations. Hurley perceives the implementation of the CSR Policy as strengthening the core principles of its business. Hurley appreciates that a failure to comply with policy guidelines may lead to reputational damage.

3. Purpose

The purpose of this CSR Policy is to emphasise the corporate social responsibility principles and practices to which Hurley aspires. Adherence to the CSR Policy will assist Hurley achieve the highest level of responsible business practice and sustainability and result in a positive overall impact on society. This CSR Policy will be reviewed and updated (if necessary) at least every five years in response to advances in knowledge about corporate social responsibility and the implementation of it.

4. Principles

a. Accountability and Transparency

Hurley will be accountable and transparent by endeavouring to:

- ensure that it does not risk the health and safety of its employees and the wider community;
- ensure that the lives of local and indigenous people are not harmed;
- promote diversity and inclusion;
- maintain a safe working environment through best practice in health and safety management in all areas of its business;
- produce an environment whereby all are encouraged to work to and realise their full potential through the offering of learning and developing opportunities;
- seek out and accept customer feedback, respect customer processes and support vulnerable customers;
- ensure that its programs and policies promote the increased representation of diverse groups of people, including people of varied cultural backgrounds, religions, ages, genders, sexual orientations, abilities and disabilities; and
- encourage employee confidence in discussing any problem(s) connected with their work ensuring that they will receive a fair, impartial and confidential review of the issue.

b. Legality

Hurley will uphold its principle of legality by endeavouring to:

- adhere to its internal policies;
- ensure that all of its business operations are genuine; and
- maintain honest and transparent partnerships and collaborations.

c. Business Ethics & Integrity

Hurley will uphold its principle of business ethics & integrity by endeavouring to:

- conduct business operations with integrity and respect to human rights;
- encourage safe and fair dealings, respect toward the consumer and anti-bribery and anti-corruption practices;
- conduct its business in accordance with the laws and regulations of the countries in which its business is located; and
- refuse to accept any bribes, kickbacks or similar payments.

d. Human Rights

Hurley will support and uphold human rights principles by endeavouring to:

- affirm its dedication to protecting human rights;
- commit to being an equal opportunity employer who adheres to all fair labour practices;
- ensure that its activities do not directly or indirectly violate human rights in any country; and
- prohibit child labour or any form of forced labour, including prison labour, indentured labour, bonded labour, military labour, slave labour, or any form of human trafficking in its operations or those of its suppliers.

e. Stakeholders

Hurley will ensure interdependence and collegiality with stakeholders by endeavouring to:

- promote understanding about the direct and indirect impact(s) of its operations, both internally and externally to its business, and strive to advance its management of direct and indirect impacts;
- engage with, and form relationships with stakeholders by providing them with a range of opportunities by which to express their interests and concerns;
- form relationships with stakeholders through the supply chain that share Hurley’s desire to positively impact on society and the environment; and
- equip its employees with the skills and knowledge to perform their tasks, invest in training and development, and produce a safe working environment that supports health and wellbeing.

f. Proactiveness

Hurley will ensure that it is proactive by endeavouring to:

- encourage its employees to volunteer through programs organised internally or externally;
- protect the environment (save and except when it interferes with Hurley’s legal obligations). Such relevant activities may include recycling, conserving energy and using environmentally friendly technologies;
- reduce emissions and waste;
- respond to community concerns with integrity, honesty and respect;
- support non-profit organisations and/or movements to advance cultural and economic development of communities, both locally and globally;
- conduct occasional audits of contract factories through the use of a hired and experienced outside third party to focus on employee working conditions, working environment, human rights, worker age documentation, wage issues, working hours, safety and discrimination;
- maintain updated records to ensure the integrity of its proactive process;
- ensure products are packaged and delivered in a sustainable manner.

5. Policy Management

Hurley will implement a systematic approach to corporate social responsibility, ethical stance and maintain sustainable management to affect a continuous improvement in performance.