Scope
Central Coast Leagues’ Club Ltd (“CCLC” or “the Club”) Members and Guests Code of Conduct is designed to ensure that all visitors to the club are respectful of all others including staff. These guidelines, listed below, but not limited to allow members, guests and staff to enjoy their time and work in a safe, respectful, cohesive and welcoming environment. It is the responsibility of all members and guests to uphold these expectations, and to respectfully address any concerns or conflicts that may arise. By working together to maintain a respectful and courteous environment, the club can be a welcoming and inclusive space for all.

Guidelines
1. Dress code
Members and guests are expected to dress appropriately and in accordance with the dress code policy of the club. Clothing that is offensive, or promotes violence, racism, or other forms of discrimination is not allowed. Managers will have discretion and the final say on the dress code.

2. Respectful behaviour
All members and guests are expected to behave in a respectful and courteous manner towards each other and the club’s staff.

3. Harassment and Bullying
Bullying and harassment is prohibited on club premises, and all members and guests are expected to refrain from engaging in this behaviour. Bullying and harassment can take many forms, such as verbal, physical or online abuse, intimidating behavior, or exclusion, and can have serious negative effects on the victims.

4. Prohibition of sexual harassment
Sexual harassment is prohibited; Members and guests will be held responsible for any sexual harassment towards others including staff and are required to cease these behaviors immediately upon their awareness. Sexual harassment can include any situations where someone feels uncomfortable by a sexual misconduct directly or indirectly. Prohibiting sexual harassment is an important measure to ensure a safe and respectful environment for all members, guests and staff. Sexual harassment can take many forms, including unwanted sexual advances, comments or gestures, and can occur in various settings such as the workplace, social events, or online platforms. It can have serious consequences for perpetrators and victims including externally from the club.

5. Responsible drinking
Members and guests who consume alcohol are expected to do so in a responsible manner. This includes not becoming intoxicated and not causing any disturbances. Consumption of alcohol is not an excuse to breach any section of the Members Code of Conduct. The club may refuse service to any member or guest who appears to be intoxicated. The Club is an active member of the Brisbane Water Liquor Accord in partnership with other licensed venues, local businesses, local council, police and government departments to develop practical solutions to address alcohol-related issues, anti-social behaviour and violence in the local area.

6. Compliance with club policies
Members and guests are expected to comply with all club policies, including those related to smoking, gambling, minors in premises and the use of club facilities.

7. Prohibition of illegal activity
Members and guests are prohibited from engaging in any form of illegal activity while on club premises. This includes the use or possession of illegal drugs. Any member or guest found to be engaging in illegal activity will be reported to the police.

8. Use of club facilities
Members and guests are expected to use club facilities in a responsible manner. This includes not causing damage to club property, not disrupting the enjoyment of other members and guests, and following all safety guidelines.

Reporting procedures
Report non-compliance matters to the manager on duty, the CEO or to the club’s HR department HR@cclc.com.au. By reporting non-compliance, the club can take the necessary steps to investigate the incident, take appropriate action, and prevent it from happening again.

Consequences for non-compliance
Where conduct is considered unbecoming of a member or prejudicial to the interests of the Club, disciplinary action will be taken in accordance with section 9.2, 9.3, 9.4 and section 10 of the Clubs Constitution. Members and guests who do not comply with the club’s code of conduct, or the club policies, may be asked to leave the premises. Members of the Club may face suspension or revocation of their membership. In serious cases, the police may be called. The consequences for non-compliance are in place to maintain the club’s standards and ensure the well-being of its members, guests and staff.

Central Coast Leagues Club is committed to and actively practices Responsible Service of Alcohol (RSA). Our service staff have been trained in responsible practices which aim to minimise negative social impact of alcohol consumption and ensure alcohol is enjoyed in a responsible manner at Central Coast Leagues Club.

Minors, or under 18’s, are permitted to enter and remain in the Club in line with the following conditions. Minors must:

• remain in the company and immediate presence of a responsible adult, such as a parent or guardian or another person who is standing in as a parent;
• under NO circumstance possess, consume or attempt to purchase any form of alcoholic beverage;
• adhere to Club signage regarding restricted areas; and
• leave the Club when the Member does and no later than 22:00.

Minors are not permitted to enter or remain in bar areas of the Club unless they are accompanied by a responsible adult and must not approach bars, use or operate gaming machines on Club premises.

Upon a responsible adult entering the Club with a Minor, it is clearly understood and acknowledged both will comply with the foregoing conditions of entry at all times which underpins the Clubs strict policy on minors and the absolute restriction on the service, supply and consumption of alcohol to minors.

It is also understood that if any of these conditions are not adhered to, Club staff reserve the right to ask the Minor and the responsible adult to leave the premises immediately and will contact Police to report the incident.  

The Club is committed to providing safe, socially responsible and supportive environment where the potential harm associated with gambling is minimised. Central Coast Leagues Club is a member of ClubSAFE; a program providing expert services to mitigate problem gambling.

Central Coast Leagues Club is committed to providing you with the highest levels of customer service. This includes protecting your privacy and keeping you informed of our privacy policy.

Central Coast Leagues Club (“CCLC” or “The Club”) is committed to fostering a culture in which honesty, integrity and business ethics are a regular part of the workplace. The Club established this policy toencourage the reporting of any matters which may be considered unethical, illegal or an act of serious wrongdoing.

The Club provides protections and measures so that those persons who make a report may do so confidentially and without fear of intimidation, disadvantage, or reprisal.

This Policy provides a framework which helps to identify instances of wrongdoing and provide guidanceon how to raise a concern about suspected or actual unethical or unlawful behaviour.

Scope
This policy applies to all Central Coast Leagues Club Directors, employees, contractors, consultants, and subsidiary companies.

Content
Qualifying for Protection
The Corporations Act 2001 (Cth) and other legislation provides special protections to people that disclose wrongdoing related to an organisation such as a club (whistle-blowers). These protectionsprevent the organisation from subjecting the whistle-blower to detriment, such as by dismissing, harassing, or damaging the reputation of the whistle-blower.

These legislative protections will apply to a person disclosing wrongdoing if three criteria are satisfied:

• the person making the disclosure is an eligible whistle-blower and
• the whistle-blower suspects that the information being disclosed concerns wrongdoing in relation to the Club (a disclosable matter) and
• the information is disclosed to a prescribed person or body (a prescribed recipient).

The Policy describes two other avenues to qualify for protection, besides satisfying the three criteria above.

Please see the Club’s Grievance Procedure on how personal workplace or other matters that are not covered by this policy may be dealt with.

Eligible whistle-blowers
A person is an eligible whistle-blower if they are a current or former employee or director of the Club.

A current or former volunteer staff member is also an eligible whistle-blower. The following people are also eligible whistle-blowers:

• a supplier to the Club, as well as the supplier’s staff (including volunteer staff)
• a relative or dependent of a current or former director, employee, volunteer staff member or supplier (including a dependent of the supplier’s staff). A relative or dependent includes a spouse, parent, brother, sister, grandparent, or grandchild.
• Disclosable matters

This policy applies to the disclosure of information which a person has reasonable grounds to suspect concerns misconduct, or an improper state of affairs or circumstances in relation to the Club.

This may include:

• breaching Commonwealth, State or Territory legislation, or local authority by-laws
• fraud or corruption
• illegal activities or conduct (including theft, illicit drug sale/use, violence, threatened violence, or criminal damage against the Club’s assets or property)
• discrimination, vilification, sexual harassment, harassment, bullying and victimisation
• unsafe work-practices.

As noted above, a disclosure is a disclosable matter if the person making the disclosure “has reasonable grounds to suspect” wrongdoing.

Therefore, if a person discloses information about possible wrongdoing, and the allegation is ultimately found to be incorrect (i.e., the Club did not in fact engage in wrongdoing), the disclosure may still qualify for protection if the person had “reasonable grounds to suspect” that the information concerned wrongdoing. However, a person who maliciously or vexatiously makes disclosures or makes disclosures which they know are false is unlikely to qualify for protection.

Disclosure relating to tax
Disclosures about tax wrongdoing are treated differently to other disclosures. For instance, the prescribed recipients are different depending on whether the disclosable matter relates to tax.

Tax disclosures refer to wrongdoing in relation to federal tax matters, such as tax avoidance orother breaches of tax legislation. Federal tax includes income tax (also known as corporate tax), capital gains tax (CGT), Goods and Services Tax (GST) and Fringe Benefits Tax (FBT).

Taxes that are regulated by state legislation must be treated as a non-tax matter for the purposesof whistle-blower rules. Taxes regulated by state legislation include gaming tax, payroll tax and land tax.

For example, if an employee wishes to make a whistle-blower disclosure because they suspect that a Club is deliberately underpaying payroll tax or gaming tax, the employee should make thedisclosure to a prescribed recipient for non-tax matters (described below) and not a prescribed recipient for tax matters.

Alternatively, if an employee wishes to make a whistle-blower disclosure because they suspect thata Club is deliberately underpaying corporate tax, the employee should make the disclosure to a prescribed recipient for tax matters.

Federal tax-related disclosures must satisfy an additional ground to be a disclosable matter (in addition to the description above), being that the person considers that the information may assist the recipient to perform their duties in relation to taxation.

Prescribed recipients for non-tax matters
The following bodies and people are prescribed recipients. Therefore, disclosing information about wrongdoing will qualify the person for whistle-blower protections, as long as the other two criteria are met (the person is an eligible whistle-blower, and the information is a disclosable matter):

• a director or senior manager of the Club
• the Club’s internal or external auditor (or a member of the external audit team) andactuary.
• the Australian Securities and Investments Commission (ASIC) or the Australian Prudential Regulation Authority (APRA).
• Prescribed recipients for tax matters

The following bodies and people are prescribed recipients for disclosures related to federal taxes:

• Commissioner of Taxation
• an employee’s direct manager or supervisor
• the Club’s internal or external auditor (or a member of the external audit team)
• a registered tax agent or BAS agent who provides services to the Club
• a director or senior manager of the Club or
• any employee or director with tax-related

Other avenues to qualify for protection
Satisfying the three criteria above is one avenue for a prospective whistle-blower to qualify for protection. There are two other avenues to qualify, as they may relate to the Club:

1. the disclosure is made to a legal practitioner for the purpose of obtaining legal advice or legal representation in relation to the whistle-blower matter
2. the disclosure is an emergency disclosure, because it satisfies each of the below criteria (this avenue does not apply to a tax-related matter): or the person has previously made adisclosure qualifying for protection a reasonable period has since passed
   • there is a risk to public health or safety if the information is not acted onimmediately
   • the person notifies the Club in writing that they intend to make an emergency disclosure and
   • the disclosure is made to a State, Territory or Commonwealth member of Parliament or a journalist.

Protections Available to Whistle-blowers
If a person discloses information which qualifies for whistle-blower protection, the below legalprotections will apply. These protections will apply to internal whistle-blowers (such as employees, volunteer staff and directors) as well as external whistle-blowers (such as suppliers or relatives of club staff). Given these legislative protections, the Club is legally obligated to ensure these protections:

• identity protection (confidentiality)
• protection from detriment
• compensation and other remedies
• protection from legal

Confidentiality
The Club recognises that maintaining appropriate confidentiality is crucial in ensuring that prospective whistle-blowers come forward and make disclosures in an open and timely manner and without fear of reprisals being made against them.

It is illegal for the Club or any other person to identify a discloser or distribute information likely to lead to the discloser being identified.

In the following instances, the Club may lawfully disclose the identity of the whistle-blower:

• to ASIC, APRA or the Australian Federal Police
• to a legal practitioner (to obtain legal assistance)
• if the prospective whistle-blower

The Club or a person investigating the whistle-blower complaint may also disclose

information about the complaint, which could lead to the person’s identity being deciphered, if the person’s name is redacted and the investigator has taken all reasonable steps to prevent the whistle-blower’s identification.

Note: Whistle-blowers may complain to ASIC if their confidentiality has been breached. In appropriate cases, disclosure of the identity of the whistle-blower, or the allegation made by them, may be unavoidable, such as if court proceedings result from a disclosure pursuant to this policy.

Protection from detriment
The following types of detriment to a whistle-blower are unlawful:

• terminating the whistle-blower’s employment
• altering characteristics of the whistle-blower’s employment, such as their position or duties
• harassing or intimidating the whistle-blower
• damaging the whistle-blower’s reputation, property, or financial position
• injuring or harming the whistle-blower (including psychological harm).

The Club may take adverse action against a whistle-blower if the disclosure reveals that the whistle-blower engaged in misconduct.

If a disclosure qualifies for protection under the applicable legislation, the protection afforded to the discloser overrides any provision of their employment contract, including any confidentiality clause.

If the whistle-blower was involved in the conduct which was the subject of the disclosure, the fact that the whistle-blower has made the disclosure may be considered in determining the severity of the disciplinary measures, if any, that may eventually be taken against such whistle-blower.

Compensation and other remedies
A whistle-blower is entitled to seek compensation and other relief through the courts if:

• they suffer detriment due to making the disclosure
• the Club failed to prevent the

Protection from legal liability
A whistle-blower is protected from the following outcomes:

• legal action being commenced against the whistle-blower, such as for breach of confidentiality or any other obligations in their employment contract or elsewhere
• criminal prosecution, such as for unlawfully releasing information and
• administrative action, for example, a BAS agent cannot be sanctioned or disciplined under the accounting profession’s code of conduct due to making a whistle-blower

Supporting confidentiality
As noted earlier in this Policy, the Club is legally obligated to take steps to maintain a whistle- blower’s confidentiality. Where necessary, the Club will take the following actions to protect a whistle-blower’s confidentiality:

• redact the whistle-blower’s name, personal information and information which could lead to the identification of the whistle-blower, in any written material which describes the disclosure
• the whistle-blower will always be referred to in a gender-neutral context
• where possible, the Club will contact the whistle-blower to ascertain certain information which could cause another person to identify the whistle-blower (for example, there may be unique characteristics about how and when the whistle- blower discovered informationabout the wrongdoing, and if these characteristics are disclosed, it may cause another person to identify the whistle-blower)
• documents or information relating to the investigation will not be sent to a printer or email address that can be accessed by other staff.

Preventing detriment
The Club will also take steps to prevent the whistle-blower from experiencing any detriment,including:

• move the whistle-blower to another team or position (with the whistle-blower’s consent)
• after a whistle-blower complaint is made, senior managers and directors privy to the complaint, may meet to assess the risk of detriment to the whistle-blower and actions to mitigate that risk
• if detriment has already occurred – intervening to protect the whistle-blower, such as by taking disciplinary action against a person responsible for the detriment.

Any reprisals against a whistle-blower are a serious breach of this policy and may result in disciplinary action, including dismissal. Where the Club becomes aware of any reprisals against a whistle-blower for complying with this policy or the legislation, the Club will take steps to either overturn, or deem void, the decision or action. This protection applies to anyone providing information related to an investigation pursuant to this policy.

Reporting
The Club has several channels for reporting wrongdoing. In the first instance, any person who has reasonable grounds to suspect that a breach of a law or other standard of behaviour has occurred, is encouraged to report that suspicion to their direct manager or the Chief Administrative Officer.

If this is considered inappropriate, the person should raise the concern with the Chief ExecutiveOfficer, by phone or email, or in writing. You may also raise the matter with any Director or senior manager of the Club.

If neither of these channels are considered appropriate, disclosures may be made to the Club’s auditor Fortunity Assurance:
thompson@fortunity.com.au
Erina Business Centre: 155 The Entrance Road Erina NSW 2250
(02) 4304-8888

Where an allegation of wrongdoing relates to the Club’s tax affairs, a person may qualify for protection by disclosing the allegation to other recipients the Commissioner of Taxation or a registered tax agent or BAS agent (this may be the Club’s accountant).

All disclosures should provide specific, adequate, and pertinent information with respect to, among other things, dates, places, persons, witnesses, amounts, and other relevant information, in order to allow a reasonable investigation to be conducted.

If the whistle-blower discloses his or her name, the person receiving the disclosure will acknowledge receipt of the disclosure and may initiate a follow-up meeting. However, if the disclosure is submitted on an anonymous basis, there will be no follow-up meeting regarding the disclosure and the Club will be unable to communicate with the whistle-blower if more information is required, or if the matter is to be referred to external parties for further investigation.

All disclosures received will be dealt with on a confidential basis.

Handling a disclosure
A person who receives a disclosure cannot circulate your identity to other staff without your consent. For instance, if you lodge a whistle-blower complaint to your direct manager, your manager will not circulate your identity to the Chief Executive Officer or any senior manager without your consent. Ifyou do not consent, your manager may circulate the complaint to the Chief Executive Officer or other senior managers in such a way that maintains your confidentiality.

After receiving a disclosure, the Club will assess whether:

• the disclosure qualifies for protection and
• a formal investigation is

In conducting this assessment, the Club may seek professional legal advice.

If a person makes a disclosure in good faith, and the Club subsequently concludes that the disclosure does not qualify for protection, the Club may choose to protect the discloser’s confidentiality, and protect the discloser from detriment, despite the absence of legislativeprotections.

Investigating a disclosure
Any investigation in relation to a disclosure will be conducted promptly and fairly, with due regard for the nature of the allegation and the rights of the persons involved in the investigation. Adisclosure will not be investigated by persons implicated in the wrongdoing.

The purpose of investigating the disclosure is to determine whether there is enough evidence to substantiate or refute the allegation. Accordingly, during the investigation, the Club may request additional information from a whistle-blower, to attain sufficient evidence to make this assessment.

Investigating a disclosure may also require the Club to seek outside assistance of a technical, financial or legal nature.

The Club will ensure that, provided the disclosure was not made anonymously, the whistle- bloweris kept informed of the outcomes of the investigation of his or her allegations, subject to the considerations of privacy of those against whom allegations are made.

The findings resulting from an investigation will be documented and circulated to the board and senior managers, in accordance with the Club’s obligation to maintain the whistle- blower’s confidentiality.

In addition to protecting the whistle-blower’s confidentiality, the Club may also choose not to

circulate the findings of the investigation to persons implicated in the wrongdoing.

Individuals Mentioned in a Disclosure
The Club will take steps to ensure the fair treatment of individuals mentioned in a disclosure, including where those individuals are implicated in wrongdoing.

The Club will adhere to the principles of natural justice in taking any disciplinary action against persons implicated by a whistle-blower disclosure. This means that the implicated person will be advised about the substance of the disclosure prior to any actions being taken.

The Club will also take reasonable steps to protect the confidentiality of persons implicated in a whistle-blower disclosure.

Availability of this policy
This policy will be made available by various means including the Staff Handbook, internal network access/intranet, and the Club’s website.