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Sustainability Performance Report 2012 11
Governance andmanagement
Code of conduct
AGL’s Code of Conduct (the Code) sets out a number of overarching
principles of ethical behaviour aligned with AGL’s core values. The
Code applies to directors, employees and contractors working on
behalf of AGL.
The Code is administered by the AGL Ethics Panel. The Ethics Panel
comprises: Company Secretary, Group Head of People and Culture,
Head of Legal, Head of Group Audit, and an independent person with
expertise in managing employee grievances. The responsibilities of
the Ethics Panel include putting in place procedures for distribution
of, and compliance with, the Code; investigation and reporting of any
alleged breaches of the Code; and recommending to the Board any
changes required to support the effectiveness of the Code.
The payment of membership fees and subscriptions to political
parties is addressed in the Code, and the political networking
forums in which AGL participates are outlined in the Stakeholder
engagement section of this report.
AGL’s Code of Conduct is available at
Health, safety and environmental management
AGL’s health, safety and environmental management system is based
on the recognised standards AS/NZS/ISO 14001 (Environmental
Management Systems) and AS/NZS 4801 (Occupational Health
and Safety Systems). Life Guard sets the corporate standards and
requirements for health, safety and environmental management for
all aspects of AGL’s business. Life Guard committees monitor and
drive performance improvement and compliance with Life Guard.
AGL’s Health, Safety and Environment Policy is available at
Market disclosure
The Market Disclosure Policy outlines how AGL manages continuous
disclosure obligations and communication with capital markets.
An internal Market Disclosure Committee is responsible for
ensuring that all AGL announcements are timely, contain clearly
written, material information, and are objective and factual, to
allow investors to assess the consequences of information on their
investment decisions.
AGL’s Market Disclosure Policy is available at
AGL’s Privacy Statement and companion internal document, the
Privacy Policy, outline AGL’s responsibilities and commitments in
relation to the privacy of customers, shareholders, employees and
other stakeholders. The Statement is consistent with the National
Privacy Principles, as documented in the
Privacy Act 1988
AGL’s Privacy Statement is available at
Legislative compliance
AGL is committed to embedding compliance risk management
practices within the broader risk management and governance
frameworks, and integrating it into all business processes and
operations to drive consistent, effective and accountable decision
making. The Compliance Policy and Plan covers legislative
requirements, management responsibilities, training, reporting
on compliance and provision for internal audit. AGL’s approach to
compliance is consistent with the Australian Standard on Compliance
Programs (AS 3806-2006).
AGL’s Compliance Policy is available at
Public policy advocacy
AGL aims to provide stakeholders with access to the right
information so that the effects of energy market and climate
change policy on both AGL’s business and AGL’s customers are
fully understood. AGL participates in the development of public
policy by providing submissions, consulting with government,
participating in government networking events and by speaking
at government inquiries.
AGL also works with a number of energy industry associations to
provide common industry and business positions to governments
on energy market and greenhouse policy issues. However, there
are occasions where AGL’s position differs from the association to
which it belongs. Where possible, AGL informs stakeholders of this
difference of opinion to avoid confusion. Refer to the Stakeholder
Engagement section of this report for further information.
Copies of AGL’s submissions are publicly available on relevant
government department websites. Selected submissions are
also published on AGL’s corporate blog at
Key issues for which AGL plays a policy advocacy role are
listed below.
Price risk
Price risks exist for energy retailers where regulated prices do not
reflect current energy costs. AGL actively participates in regulatory
price reviews when they arise.
Energy regulation
AGL recognises that an efficient market and regulatory
framework assists in ensuring that the industry and its customers
are not exposed to inappropriate costs and risks. To facilitate
the development of a consistent framework for Australia’s
energy markets, AGL has made a number of submissions to
energy regulators.
Climate change
In FY2012, AGL contributed to a number of public policy discussions.
AGL continues to advocate the adoption of a broad-based emissions
trading scheme in Australia.