Employment & Workforce Conduct Policy

Status: v1.0
Tier: Tier 1 – Core Corporate & Platform Policy
Owner: Governance and Compliance Function
Approval Authority: Board of Directors
Effective Date: 5 January 2026
Next Review: 12 months from approval

1. Purpose

This policy defines the standards of conduct expected of Global Talent Pathway’s workforce and representatives.

Its purpose is to:

  • ensure lawful, ethical, and professional conduct,

  • protect candidates, workers, employers, and partners,

  • support trust in Global Talent Pathway’s platforms and services,

  • provide a clear basis for accountability and enforcement.

2. Scope

This policy applies to:

  • employees (permanent, fixed-term, casual),

  • contractors, consultants, and secondees,

  • officers, Board members, and Advisory Board members (where relevant to conduct),

  • agents and representatives acting on behalf of Global Talent Pathway.

This policy applies across all jurisdictions and operating contexts.

3. Policy Statement

Global Talent Pathway expects all personnel to:

  • act with integrity, professionalism, and respect,

  • comply with applicable laws and internal policies,

  • avoid conduct that could harm individuals or the organisation.

This policy sets minimum conduct standards. It does not replace contractual obligations or legal duties.

4. General Conduct Standards

Personnel must:

  • act honestly and in good faith,

  • treat others with dignity and respect,

  • perform duties competently and responsibly,

  • follow lawful and reasonable directions,

  • not misuse position, authority, or access.

Unacceptable conduct includes behaviour that is abusive, discriminatory, harassing, coercive, or otherwise inappropriate.

5. Candidate and Worker Interactions

Personnel interacting with candidates or workers must:

  • provide accurate and non-misleading information,

  • avoid pressuring individuals to accept opportunities,

  • respect individuals’ autonomy and decision-making,

  • not solicit or accept recruitment fees from workers,

  • not retain personal documents or exert undue influence.

Conduct that exploits vulnerability or power imbalance is prohibited.

6. Employer and Supplier Interactions

Personnel must:

  • engage employers and suppliers fairly and transparently,

  • not provide preferential treatment without proper authorisation,

  • avoid conflicts of interest,

  • not solicit or accept improper benefits.

7. Use of Systems and Data

Personnel must:

  • use Global Talent Pathway systems only for authorised purposes,

  • protect personal, sensitive, and confidential information,

  • comply with the Privacy Policy, Information Security Policy, and Records Management & Retention Policy,

  • not access, disclose, or alter information without authority.

Misuse of systems or data is serious misconduct.

8. Conflicts of Interest

Personnel must:

  • disclose actual, potential, or perceived conflicts of interest,

  • comply with the Conflict of Interest Policy,

  • not participate in decisions where conflicts are unmanaged.

9. Gifts, Benefits and Hospitality

Personnel must:

  • comply with the Fraud, Bribery & Corruption Policy,

  • not offer or accept gifts or benefits that could influence decisions,

  • declare gifts where required.

10. Compliance with Law and Policy

Personnel must:

  • comply with all applicable laws,

  • comply with Global Talent Pathway policies,

  • cooperate with audits, investigations, and compliance processes.

11. Reporting Concerns

Personnel must report:

  • suspected misconduct,

  • breaches of this policy,

  • harm or risk to individuals,

  • legal or regulatory issues,

through the Complaints & Disclosures Gateway.

Whistleblower protections apply where relevant.

12. Disciplinary Action

Breaches of this policy may result in:

  • counselling or corrective action,

  • disciplinary measures,

  • termination of employment or engagement,

  • referral to authorities where required by law.

Disciplinary action is proportionate to severity and risk.

13. No Retaliation

Retaliation against individuals who raise concerns in good faith is prohibited and may result in serious consequences.

14. Recordkeeping

Conduct issues and disciplinary actions are:

  • documented appropriately,

  • access-restricted,

  • retained in accordance with the Records Management & Retention Policy.

15. Relationship to Other Policies

This policy operates alongside:

  • Ethical Recruitment & Fair Work Policy,

  • Modern Slavery & Human Trafficking Policy,

  • Fraud, Bribery & Corruption Policy,

  • Conflict of Interest Policy,

  • Privacy and Information Security Policies,

  • Complaints & Disclosures Gateway.

In the event of inconsistency, Tier 1 policies prevail.

16. Review

This policy will be reviewed annually or earlier if required by operational or legal change.