AGL Energy Limited Annual Report 2011 37 Principle 3: Promote ethical and  responsible decision making Recommendation 3.2 –  Companies should  establish a policy concerning diversity Compliance Policy Recommendation 3.1 –  Companies should  establish a Code of Conduct  Recommendation 3.3 –  Companies should  disclose the measurable objectives for  achieving gender diversity and progress  toward achieving those objectives Progress to date Ethical decision making is integral to the  conduct of AGL’s business. The Safety,  Sustainability and Corporate Responsibility  Committee assists the Board in enabling  AGL to operate its businesses ethically,  responsibly and sustainably. The Committee currently comprises three  non–executive and independent Directors,  Sandra McPhee (Chair), Bruce Phillips and  Les Hosking. The Committee has a formal  Charter that was most recently reviewed in  June 2010. A copy of that Charter is  available on AGL’s website. The Committee oversees and reviews: The Committee holds as many meetings as  practical at AGL business unit locations. It  met four times during the year with the  meetings held at AGL’s call centre in  Adelaide; the construction site for the  Oaklands Hill wind farm; Mount Beauty in  Victoria near AGL’s hydro generation  assets; and in the Hunter Valley near AGL’s  coal seam gas exploration activities. AGL has a Code of Conduct that applies to  AGL and its Directors, employees and  contractors (all of which are referred to as  “employees” in the Code). The Code of Conduct sets out a number of  overarching principles of ethical behaviour  and explains: AGL’s Compliance Policy sets out  responsibilities for compliance with AGL’s  various legislative and contractual  obligations. This Policy was reviewed and  amended during the year. The Policy is  published on AGL’s website. AGL is committed to the highest standards  of integrity, fairness and ethical conduct,  including full compliance with all relevant  legal requirements. There is no  circumstance under which it is acceptable  for AGL or a person associated with AGL to  knowingly or deliberately not comply with  the law or to act unethically in the course  of performing or advancing AGL’s business.  Behaviour of this kind will lead to  disciplinary measures that may  include dismissal. AGL’s Code of Conduct is available on  AGL’s website. During the year, the Ethics Panel  investigated two alleged breaches of the  Code of Conduct. One investigation found  there had been a breach of the Code of  Conduct by an AGL employee. The  employee was subsequently given a formal  written warning about his behaviour. The Code of Conduct provides a  mechanism to enable employees to report  actual or suspected breaches, including an  independently monitored Ethics Line  telephone and email service to allow for  anonymous reporting. An Ethics Panel  oversees the application of the Code of  Conduct in AGL, including investigating  alleged breaches of the Code, monitoring  compliance and recommending  amendments to the Board. The Ethics Panel  comprises the Company Secretary, Group  Head of People and Culture, the Head of  Legal, the Head of Group Audit, and Ms  Susan Cunningham – an independent  person who has expertise in managing  employee grievances. The Ethics Panel met  four times during the year. Training about the Code of Conduct is  part of the induction process for new  AGL employees. The ethical principles are set out under the  following headings: During the year, AGL adopted a new  Diversity and Inclusion Policy which  describes AGL’s approach to diversity and  inclusion and how these attributes are to  be embedded in AGL workplaces. The  Policy includes specific provisions regarding  gender diversity and the positive  correlation between increased  representation of women on company  boards and in senior management positions  and the achievement of better financial  performance, higher employee retention  rates, and enhanced corporate image and  reputation. The Policy is published on  AGL’s website. AGL has established a Diversity & Inclusion  Council to support the achievement of a  diverse workforce and an inclusive  workplace culture. The Council is chaired by  Michael Fraser, AGL’s CEO, and comprises  eight other members drawn from senior  leaders across AGL’s business. Five of the  members are women. During the year, the Board established  measurable objectives for achieving gender  diversity. The objectives focus on  establishing the foundations, policies and  practices to underpin an inclusive  workplace culture that supports gender  diversity. These objectives align with the  diversity focus areas established by the  Diversity & Inclusion Council: building AGL’s  inclusive workplace culture; flexible working  arrangements; carer’s needs; and women in  the workplace. The objectives, and progress made toward  achieving them, are set out below. A new, customised workshop for leaders  has been developed and successfully  piloted. It builds on traditional anti– discrimination and harassment  compliance training to cover concepts of  diversity, inclusion and bias; how these  play out in the workplace; and how to  manage issues when they arise. Leaders  across AGL will attend the workshops  during FY2012. 1  AGL will continue to build a culture of  inclusion that will support all employees  to contribute and achieve their potential.  By June 2012, AGL will deliver face–to– face diversity and inclusion training to  AGL leaders. > the obligations of AGL to put in place  mechanisms to assist all employees to  act in accordance with these principles;  and > how AGL employees should act  consistently with these principles. > AGL’s compliance with all relevant legal  obligations on the matters within its  responsibilities. > integration of safety, sustainability and  corporate responsibility in the  formulation of AGL’s corporate strategy,  risk management framework, and people  and culture priorities; and > initiatives to enhance AGL’s sustainable  business practices and reputation as a  responsible corporate citizen; > the social, environmental and ethical  impact of AGL’s policies and practices; > AGL’s actions to meet its obligation to  maintain the health and safety of its  people; Acting honestly and with integrity Observing the law Valuing and maintaining professionalism Respecting confidentiality Managing conflicts of interest Looking after our employees Looking after the community