Australia

Employment & The Law

We work hard to ensure that InterWorks is a fair and supportive place for everyone who works here, as well as for those seeking to join our ranks. Quite frankly, we believe that inclusion, fairness and diversity make us a stronger and more vibrant organization.

We are constantly striving to excel in this regard, and we need your help to keep InterWorks a welcome and equitable place for years to come. Read through our policies below, then reach out to HR@interworks.au for questions or to learn more about additional efforts.

Code of Ethics

Simply put: We will conduct our business honestly and ethically. We will constantly improve the quality of our services, products and operations and will create a reputation for honesty, fairness, respect, responsibility, integrity, trust and sound business judgment.

No illegal or unethical conduct on the part of officers, directors, employees or affiliates is in the company’s best interest. InterWorks will not compromise its principles for short-term advantage. The ethical performance of this company is the sum of the ethics of the people who work here. Thus, we are all expected to adhere to high standards of personal integrity.

Conflicts of Interest

All employees should avoid any situation which involves or may involve a conflict between their personal interest and the interest of InterWorks. A conflict of interest occurs when your personal interests (financial, family, or otherwise) could improperly influence, or appear to influence, your decisions or actions at work. This includes situations where you might gain personally from a decision made on behalf of the company. As in all other facets of our duties, dealing with customers, suppliers, contractors, competitors or any person doing or seeking to do business with us are to act in the best interest of the company.

If a situation arises which may involve a conflict of interest, you should make a prompt and full disclosure in writing to your manager. We must be careful to avoid representing InterWorks in any transaction where any outside business affiliation or relationship is at play. Alternatively, we should avoid using our InterWorks contacts to advance private business or personal interests at the expense of the company, its clients or affiliates.

Bribes and Kickbacks

InterWorks has zero tolerance for bribery and corruption. No bribes, kickbacks or other similar payment or consideration should be given to any person or organization in order to attract or influence business activity. Gifts, favors and payments may be given to others at InterWorks’ expense, if they meet all of the following criteria:

Payments, commissions or other compensation to or for the benefit of employees of customers (or their family members or associates) not required by written contract are contrary to this policy. Any payment for goods or services must be proportionate and supported by a receipt. If you are offered or asked to make any payment that could be considered a bribe or facilitation payment, you must refuse and report it immediately to your manager or HR. Breaches of this policy may result in disciplinary action, up to and including dismissal for gross misconduct.

Receiving Gifts

Similarly, none of us should ever seek or accept any gifts, favours, entertainment or payments from any person or business that does or seeks to do business with or is a competitor of InterWorks. It is never permissible to accept a gift in cash or cash equivalent such as stocks or other forms of marketable securities of any amount. Finally, managers should not accept gifts from those under their supervision of more than limited value.

You may accept for yourself, and members of your family, common courtesies usually associated with customary business practices. All gifts and hospitality must be recorded and declared – let HR@ know what you got and from whom.

Reporting Concerns

If you believe or suspect that a breach of this policy has occurred or may occur, or if you are offered a bribe or asked to make one, report it immediately under our whistleblowing policy. You will not be treated unfavorably for raising a concern in good faith.

Fraud

The act or intent to cheat, steal, deceive or lie is both unethical and, in most cases, criminal. Fraud in every form, (e.g., submitting false expense reports; forging or altering financial documents or certifications; misappropriating assets or misusing company property; making any untrue financial or non-financial entry on records or statements) is prohibited.

Insider Trading

Australia and state laws make it illegal for anyone to trade in a company’s securities while in possession of material, nonpublic information relating to that company, known as “insider information”. This includes financial results, mergers, acquisitions, major contracts, or regulatory actions that have not been made public.

Because of the work we do, it is possible that you may come to possess “insider information” about a client, partner, or other business in the course of your employment. Such information is subject to the terms of your Employee Confidentiality Agreement and may not be disclosed. You may not share (“tip”) insider information with anyone, even if you do not trade yourself. You may not trade, including by placing a purchase or sell order, or recommend that another person trade, in any securities (including making initial elections, changes in elections or reallocation of funds relating to retirement plan accounts) when you have knowledge of material, nonpublic information concerning such securities. This applies to shares, bonds, options, and any related financial instruments.

Officers, directors and employees will refrain from gathering competitor intelligence by illegitimate means and refrain from acting on knowledge which has been gathered in such a manner. The officers, directors and employees of InterWorks will seek to avoid exaggerating or disparaging comparisons of the services and competence of their competitors.

Officers, directors and employees agree to disclose unethical, dishonest, fraudulent and illegal behavior, or the violation of company policies and procedures, directly to management. Any suspected insider trading or misuse of confidential information must be reported immediately. Violation of this policy can result in discipline, including possible termination. The degree of discipline relates in part to whether there was a voluntary disclosure of any ethical violation and whether or not the violator cooperated in any subsequent investigation. Remember that good ethics is good business.

Compliance

We are all individually responsible for compliance with these rules, standards and principles. In the area of ethics, legality and propriety, you have an obligation to the company that transcends normal reporting relationships. You should stay alert to possible violations of the code anywhere at InterWorks and are encouraged to report such violations promptly, including suspected or potential breaches.

Reports should be made to the employee’s supervisor, the appropriate HR, Sec Ops, or Legal department personnel, or elsewhere as the circumstance dictates. You will be expected to cooperate in an investigation of any violations reported. All cases of questionable activity involving this code of ethics or other potentially improper actions will be reviewed for appropriate action, discipline or corrective steps. Whenever possible, InterWorks will keep confidential those involved in reported violations until it has been determined that a violation has occurred.

You will be required to notify InterWorks within five days of a conviction of any criminal statute violation occurring while on the job. In addition, anyone convicted of a felony, whether related to these rules or not, should report that fact.

Appropriate disciplinary penalties for violations of this policy may include counseling, reprimands, warnings, suspensions (with or without pay), demotions, dismissals and restitution. Disciplinary action may also extend to a violator’s manager when InterWorks determines that the violation involved either the participation of the supervisor or reflected the supervisor’s lack of diligence in seeking compliance, including the failure to report the violation on a timely basis. Anyone who takes any action whatsoever in retaliation against an employee who has in good faith raised any question or concern about compliance with this code of ethics will be subject to serious sanctions, which may include dismissal.

Employees who have questions about this policy should contact our General Counsel for guidance without fear of retaliation. If you have reason to believe that an actual or potential violation of this policy is occurring or has occurred, you should contact our General Counsel immediately, again without fear of retaliation.

Disability and Reasonable Accommodation

We are committed to the fair and equal employment of individuals with disabilities under the Fair Work Act and Disability Discrimination Act. It is our policy to provide reasonable accommodation to qualified individuals with disabilities unless the accommodation would put an undue hardship on our company.

We want to make sure our team members with disabilities can do their jobs and enjoy all the perks of working here. If you’ve got a disability and need some help, just send a request over to HR@. Let them know what you need to really flow into your job, and if you can, share some info to back it up, in line with the legal requirements.

We’ll look into it, chat with you about it, and see what we can do to make things work better for you. If we need it, we might ask for some medical info about your disability and what can help, while maintaining your privacy and keeping this information confidential and on a need-to-know basis.

As stated in many ways throughout this handbook, we put a great deal of weight on how people treat each other here. To us, it’s all about respect. We won’t tolerate any bullying or discrimination because of a disability or because you asked for help. If this happens to you, we’ve got your back. If you ever see or experience any of this, check out our Complaint Procedure (keep reading) to report it.

Workplace Bullying, Discrimination and Harassment

We will always strive to create and maintain a work environment in which people are treated with dignity, decency and respect. The environment of this company should be characterized by mutual trust and the lack of intimidation, oppression and exploitation.

We are committed to providing a safe working environment for all at InterWorks and to complying with our legal obligations and duties, including our obligations to provide a safe working environment and to eliminate unlawful conduct. InterWorks recognizes that unacceptable workplace behaviour is a risk to our business and takes a risk-management approach to addressing workplace behaviour issues.

You should be able to work and learn in a safe yet stimulating atmosphere.

The accomplishment of this goal is essential to the mission of the company. Therefore, InterWorks will not tolerate bullying, unlawful discrimination, or harassment of any kind. Through enforcement of this policy and by the education of each of us, InterWorks will seek to prevent, correct and discipline behavior that violates this policy.

We require each employee to complete annual training through Udemy. You’ll complete this training in your first weeks, then you’ll receive notifications each year when it’s time to update.

Each of us, regardless of position, are covered by and are expected to comply with this policy and take steps to ensure that prohibited conduct does not occur. Appropriate disciplinary action will be taken against anyone who violates this policy. Based on the seriousness of the offense, disciplinary action may include verbal or written reprimand, suspension or termination of employment.

This policy applies to all InterWorks employees and to other workers at InterWorks, such as interns, work experience students and contractors. It applies in the workplace, while “at work” (e.g., when working remotely) and in other situations outside of the workplace where there is a connection to work (e.g., when attending an InterWorks event or when traveling for work). Third parties that come into contact with InterWorks employees and workers (such as visitors or clients) can also be expected to be treated consistently with this policy, and are expected to show such treatment to InterWorks people.

InterWorks, in compliance with all applicable federal, state and local anti-discrimination and harassment laws and regulations, enforces this policy in accordance with the following definitions and guidelines:

Discrimination

It is a violation of our policies and ethics to discriminate in the provision of employment opportunities, benefits or privileges; to create discriminatory work conditions; or to use discriminatory evaluative standards in employment if the basis of that discriminatory treatment is, in whole or in part, the person’s race, color, national origin, age, religion, disability status, gender, sexual orientation, gender identity, genetic information, marital status, or any other personal characteristic protected by applicable anti-discrimination laws.

Direct Discrimination is where a person is treated less favourably than someone in the same or similar circumstances because they have or are assumed to have a personal characteristic or attribute that is protected by law.

Examples of Direct Discrimination include:

Indirect Discrimination is where an unreasonable requirement, condition or practice is imposed that has or is likely to have the effect of disadvantaging people with a personal characteristic or attribute protected by law.

Examples of Indirect Discrimination include:

Discrimination of this kind may also be strictly prohibited by applicable law. This policy is intended to comply with the prohibitions stated in these anti-discrimination laws.

Discrimination in violation of this policy will be subject to disciplinary measures up to and including termination.

Bullying

For purposes of this policy, bullying is behaviour is where a person, or group of people, repeatedly behave unreasonably towards another worker or group of workers and that behaviour creates a risk to health and safety.

Examples of bullying include behaving aggressively towards others, teasing or playing practical jokes and excluding someone from work-related activities.

Workplace bullying does not include reasonable management action carried out in a reasonable way.

Harassment

Sexual Harassment

Sexual harassment is a form of harassment under the Fair Work Act and Sex Discrimination Act and is prohibited under InterWorks’ anti-harassment policy. Sexual harassment refers to unwelcome sexual conduct, or unwelcome sexual advances or requests for sexual favours, that a reasonable person would anticipate could offend, humiliate or intimidate the person harassed.

There can be different types of sexual harassment:

Sexual harassment may take different forms. The following examples of sexual harassment are intended to be guidelines and are not exclusive when determining whether there has been a violation of this policy:

Courteous, mutually respectful, pleasant, non-coercive interactions between all InterWorkers, that are appropriate in the workplace and acceptable to and welcomed by both parties are not considered to be harassment, including sexual harassment.

THIRD-PARTY HARASSMENT

We want to create a workplace which is free of harassment. This objective extends beyond acts of harassment by those working for us to harassment by third parties such as customers, visitors, clients, suppliers, partners, or others.

You are encouraged to report any third-party harassment you are a victim of, or witness, in accordance with this Policy.

We will take active steps to prevent third-party harassment of staff. Action may include include details of action to be taken including, for example, warning notices to customers or recorded messages at the beginning of telephone calls.

We will assess the risk of third-party harassment in the workplace and undertake to keep our risk assessment under regular review. We encourage you to come forward with any areas in which you believe our third-party harassment protection could be improved. Please let your Manager know.

If any third-party harassment of staff occurs, we will take steps to remedy any complaints and to prevent it happening again. Action may include warning the harasser about their behaviour, banning them from our premises, reporting any criminal acts to the police, and sharing information with other branches of the business.

Creating a hostile work environment

Creating a hostile work environment on the grounds of sex is also unlawful. A hostile work environment can be created by anyone in the work environment, whether it be supervisors, other employees or customers. Hostile work environment harassment consists of verbiage of a sexual nature, unwelcome sexual materials or even unwelcome physical contact as a regular part of the work environment. Texts, e-mails, cartoons or posters of a sexual nature; vulgar or lewd comments or jokes; or unwanted touching or fondling all fall into this category.

Retaliation and Victimisation

No hardship, loss, benefit or penalty may be imposed on any employee in response to:

Retaliation or attempted retaliation in response to lodging a complaint or invoking the complaint process is a violation of this policy and is unlawful. Any person who is found to have violated this aspect of the policy will be subject to sanctions up to and including termination of employment.

Consensual Romantic or Sexual Relationships

We strongly discourage romantic or sexual relationships between a manager or other supervisory employee and his or her staff (an employee who reports directly or indirectly to that person). It should go without saying that these relationships tend to create conflicts of interest or the appearance of such conflicts. Legal words aside: It gets messy.

Such relationships may give rise to the perception that there is favoritism or bias at play. Moreover, given the uneven balance of power within such relationships, “consent” may be seen as suspect and may be viewed by others or, at a later date, by the staff member as having been given as the result of coercion or intimidation. The atmosphere created by such appearances of bias, favoritism, intimidation, coercion, or exploitation undermines the spirit of trust and mutual respect that is essential to a healthy work environment. If there is such a relationship, all involved need to be aware that one or both may be moved to a different department, or other actions may be taken when necessary.

If anyone here enters into a consensual relationship that is romantic or sexual in nature with a member of their team (one who reports directly or indirectly to him or her), or if one of the parties is in a supervisory capacity in the same department in which the other party works, the parties must notify the HR director or other appropriate corporate officer. Because of potential issues regarding quid pro quo harassment, InterWorks has made reporting mandatory. This requirement does not apply to those who do not work in the same department or to parties who do not supervise or otherwise manage responsibilities over the other. Again, don’t let it get messy.

Once the relationship is made known, we’ll review the situation with HR in light of all the facts (e.g., reporting relationship between the parties, effect on coworkers, job titles, etc.) and determine whether someone should be moved to another job or department. If it is determined that one must be moved and given that there are jobs in other departments available, all involved may decide who will be the one to apply for a new position. If an amicable decision cannot be made, or if the target department is not open to the change, the group will meet again with HR to find the best solution. That decision will be based on which move will be least disruptive to the organization as a whole.
We told you it can get messy. However, we are all human, and romantic relationships are an essential part of that human experience. It’s simply worth understanding the potential outcomes and knowing the process to keep everything from, well, getting messy.

What to Expect When Filing a Complaint

We commit to courteously and respectfully treating any person who invokes this complaint procedure and will handle all complaints swiftly and confidentially to the extent possible. Lodging a complaint will in no way be used against or have an adverse impact on the individual’s employment status. Because of the damaging nature of harassment to the victims and to the entire workforce, aggrieved employees are strongly urged to use this procedure. However, filing groundless or malicious complaints is an abuse of this policy and will be treated as a violation.

Confidentiality

During the complaint process, the confidentiality of the information received, the privacy of the individuals involved, and the wishes of the complaining person will be protected to as great a degree as is possible. The expressed wishes of the complaining person for confidentiality will be considered in the context of the company’s legal obligation to act on the charge and the right of the charged party to obtain information. In most cases, however, confidentiality will be strictly maintained by the company and those involved in the investigation. In addition, any notes or documents written by or received by the person(s) conducting the investigation will be kept confidential to the extent possible and according to any existing state or federal law.

Complaint Procedure

InterWorks has established the following procedure for lodging a complaint of bullying harassment, discrimination or retaliation. The company will treat all aspects of the procedure confidentially to the extent reasonably possible.

The tasks and timeframes outlined above should be considered guidelines; investigatory tasks and conversations may be undertaken by such other people appropriately assigned by HR, and timeframes may be adjusted as circumstances warrant.

Alternative Legal Remedies

Nothing in this policy may prevent the complainant or the respondent from pursuing formal legal remedies or resolution through local, state or federal agencies or the courts.

Employees can seek advice from the Fair Work Commission (www.fwc.gov.au), anti-discrimination tribunal in their State or the Police, if potential criminal conduct is suspected.

Ethics and Compliance Hotline

At Interworks, we’re committed to creating a transparent and ethical workplace. To help us achieve this, we have available a third-party ethics and compliance hotline, ComplyLine, which provides a safe space for you to speak up if you see anything that falls short of legal and regulatory standards.

ComplyLine is here to help you report issues like:

It’s important to note that ComplyLine isn’t for:

You can report your concerns in a way that works best for you, online or by phone. Feel free to remain anonymous, or you can share your name – it’s your call. Either way, we promise to keep things confidential and professional.

Online: report.complyline.com

Organization PIN: 389631

Your Theatre’s Site ID:

By Phone:

No Retaliation – We’ve got your back. InterWorks won’t tolerate any form of retaliation against anyone who reports a concern in good faith or helps with an investigation. Retaliation is prohibited and will lead to disciplinary actions.

Employee Privacy Notice

Employee Privacy Notice

1. Introduction

InterWorks respects your privacy and is committed to protecting your personal information. This Privacy Notice outlines how we collect, use, and manage personal information about you during and after your employment, in accordance with the Australian Privacy Act 1988 (Privacy Act) and the Australian Privacy Principles (APPs).

2. Who We Are and Contact Information

InterWorks AUS Pty. Ltd. is responsible for managing the personal information we collect about you. If you have any questions about this Privacy Notice or your information, please contact our Privacy Officer at dataprivacy@interworks.com.

3. Types of Personal Information Collected

We may collect and hold the following types of personal information about you:

4. Sources of Information Collection

Personal information is collected from various sources, including:

5. Purposes of Collecting Personal Information

We collect, hold, use, and disclose your personal information for purposes related to your employment, including:

6. Disclosure of Personal Information

We may disclose your personal information to trusted third parties for employment-related purposes, including:

Where we share your personal information with third parties, we ensure that they handle it in compliance with the Privacy Act.

7. Overseas Disclosure of Personal Information

If we need to transfer your personal information outside Australia (e.g., to a parent company or service providers), we will ensure that the overseas recipient complies with Australian privacy requirements or is subject to privacy laws that offer similar protection.

8. Data Retention

We will retain your personal information only as long as necessary for employment purposes or as required by law. Generally, employee records are kept for [insert duration, e.g., 7 years after employment ends] to comply with tax, employment, and other legal obligations.

9. Your Rights

Under the Privacy Act, you have rights regarding your personal information:

To exercise any of these rights, please contact our Privacy Officer at [Privacy Officer Email Address].

10. Security of Your Personal Information

We take reasonable steps to protect your personal information from misuse, loss, unauthorized access, modification, or disclosure. This includes using secure data storage, encryption, and access controls. Only employees and authorized third parties who need to access your information for legitimate purposes will have access.

11. Updates to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our practices or legal requirements. We will notify you of any significant changes, and the latest version will be made available on the company intranet.

12. Complaints and Further Information

If you believe we have not handled your personal information in accordance with this Privacy Notice or the Privacy Act, you may lodge a complaint with our Privacy Officer. If we cannot resolve your complaint, you may contact the Office of the Australian Information Commissioner (OAIC).

Contact Information

For questions about this Privacy Notice or to exercise your rights, please contact: