Ethical Conduct Policy

This policy outlines the steps Impossible Metals takes to ensure the actions and behavior of employees, contractors and directors is at all times of the highest ethical standard.

Compliance & Ethical Conduct

Directors, employees and contractors of Impossible Metals must at all times comply with the relevant laws and regulations of States, territories and international organizations in which they operate. Moreover, directors, employees and contractors of Impossible Metals are expected to conduct themselves to the highest ethical standards, and with integrity, professionalism and honesty at all times.

Responsibilities of Directors, Employees & Contractors

All directors, employees and contractors of Impossible Metals are required to:

  • Be honest, cooperative, and respectful in their interaction with employees, contractors, directors and stakeholders;
  • Deliver work of the highest professional standard at all times;
  • Deliver professional findings in an impartial, unbiased and clear manner;
  • Respect Impossible Metals property; and
  • Respect the privacy of employees, contractors and stakeholders, and not disclose confidential information.

Equal Opportunity

Impossible Metals is committed to equal employment opportunity and providing a safe, inclusive and supportive workplace. Impossible Metals provides equal employment opportunities to all applicants, without regard to unlawful considerations of or discrimination against race, religion, creed, color, nationality, sex, sexual orientation, gender identity, age, ancestry, physical or mental disability, medical condition or characteristics, marital status, or any other classification prohibited by applicable local, state or federal laws. Equal opportunity applies to hiring, termination, promotion, compensation, schedules, job assignments, discipline, training, working conditions, and all other aspects of employment.

Zero Tolerance

Impossible Metals has zero-tolerance for all forms of:

  • Child and forced labor, including unethical or unlawful labor conditions;
  • Direct discrimination – treating someone with a “protected attribute” (such as age, gender, race, religion, sexual orientation, pregnancy, disability or marital status) unfavourably because of that attribute. In determining whether a person discriminates, it is irrelevant whether or not the attribute is the only, or main, reason for the unfavourable treatment;
  • Indirect discrimination – imposing an unreasonable requirement or condition that is likely to disadvantage persons or groups of people with a “protected attribute”;
  • Victimisation – treating or threatening to treat a person detrimentally because that person has made an allegation or complaint of discrimination or harassment;
  • Vilification – inciting hatred, contempt, revulsion or ridicule of a person or persons on the basis of race, gender or religion;
  • Workplace Bullying, which is an ongoing and deliberate misuse of power in relationships through repeated verbal, physical and/or social behaviour that intends to cause physical, social and/or psychological harm and may include abusive and offensive language, insults, teasing, unreasonable criticism and trivialisation of work achievements;
  • Occupational Violence, which occurs when someone is abused, threatened or assaulted in relation to their work;
  • Sexual and Non-Sexual Harassment, which includes behavior towards a person or persons that could reasonably be expected to make that person(s) feel offended, humiliated or intimidated. Harassment includes physical, verbal, visual or written harassment.

Employees, directors and contractors are expected to comply with this policy at all times. Failure to do so will result in performance management, up to and including termination. More information on ethical conduct expected of Impossible Metals employees and contractors is provided in the Employee Handbook.

Privacy & Confidentiality

Impossible Metals collects, stores and uses personal information in accordance with relevant privacy laws in the jurisdictions in which it operates. Impossible Metals takes all reasonable technical and organisational precautions to prevent the loss, misuse or alteration of personal information, including storing all personal information provided to it on its secure servers. All persons have the right to request access to personal information that Impossible Metals may hold about them, or to correct personal information held by Impossible Metals. Impossible Metals may disclose information to a government agency when required to do so by law, or in order to establish, exercise or defend its legal rights.

Conflicts of Interest

A conflict of interest arises when an employee, contractor or director of Impossible Metals has a ‘secondary interest’ which could improperly influence the performance of that person’s duties and responsibilities in their work for Impossible Metals.

A ‘secondary interest’ means anything that can have an actual or perceived impact or influence on the workplace participant, including:

  • The personal, professional or business interests of a Impossible Metals director, employee or contractor; or
  • The personal, professional or business interests of individuals or groups with whom a Impossible Metals director, employee or contractor is closely associated (for instance, relatives, friends or even a rival).

Improper use of Position, Information & Assets

This Policy prohibits Impossible Metals directors, employees and contractors from using their position, information acquired in their position, or access to Impossible Metals assets, to obtain a benefit or advantage for themselves or any other person connected with them.

Declaring & Managing a Conflict of Interest

All Impossible Metals directors, employees, contractors and volunteers have a responsibility to consider whether their actions or decisions associated with Impossible Metals could give rise to an actual or perceived conflict of interest, and if so, to take action to declare and manage that conflict.

Impossible Metals employees and contractors must register or declare actual or perceived conflicts of interest in writing to the Chief Executive Officer, who shall note them on the Register of Interests.

Measures that may be adopted to mitigate a conflict of interest include (but are not limited to):

  • Engagement of a qualified third party without an interest in Impossible Metals to advise on or participate in the matter;
  • Restricting or removing involvement of a director, employee or contractor in matters in which they have (or are perceived to have) a conflict of interest;
  • Requiring a director, employee or contractor to relinquish assets or other private interests that conflict with the interests of Impossible Metals, if the director, employee, or contractor wishes to retain his or her involvement with Impossible Metals.

Complaints

Complaints or allegations of misconduct against employees, directors and contractors, must be managed in accordance with the Complaints and Disputes Policy.

Changes to this Policy

This policy is reviewed under Impossible Metals’s mandatory annual policy review schedule and is next due for formal review in October 2022.

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