Code of Conduct

1 Purpose of this Code of Conduct

Each of our people has a role to play in embodying and protecting our great company, our brands and our reputation. The behaviour and conduct of our people affects the Flight Centre Travel Group's overall business success.

At Flight Centre Travel Group we are proud of our company and what our people say, how our people behave and conduct themselves. Everything we do (even our personal appearance) not only reflects on us as individuals, but also directly reflects on the Flight Centre Travel Group and our peers. We are all responsible for our actions.

This Code of Conduct outlines our Vision, our Purpose, our Core Values, our Philosophies, and sets out the Key Principles of the standards expected of our people. It is intended to provide our people with a practical guide as to what you should do in certain situations, how you should act, and the standards of personal and professional behaviour that we expect from all of our people when dealing with each other, with our customers, our suppliers and other external stakeholders.

Application

This Code of Conduct applies to all of our people globally including all of the Flight Centre Travel Group's employees, contractors, consultants, directors and officers (referred to as you, or our people).

Where this Code of Conduct refers to any policy or to any Training Compliance module in Compass, that should be read as a reference to the local equivalent of that policy or module in Compass (if any) in your geography as those policies and modules are named and modified from time to time.

It applies during all work activities and all work-related activities, work-related travel, work-related events (for example, at Buzz Nights, on Team Trips, at Global Gathering, while on 'famils' / 'educationals', while in the air, in transit, at airports). It applies to all of our people's conduct on social media, on email, text messaging, instant chat or messaging apps etc., where any of our people interact with each other, our customers, our suppliers or with other external stakeholders.

Flight Centre Travel Group’s directors and senior leadership team support this Code of Conduct.

Our people must complete all compliance training relevant to their role and position in Compass annually to ensure they can uphold these standards.

Flight Centre Travel Groups Guiding Principles and Philosophies

2 Our Vision - The Picture of What We Want To Become

To become the world's most SUCCESSFUL and profitable travel EXPERIENCE COMPANY, personally delivering amazing experiences to our people, our customers and our suppliers.

3 Our Purpose - Why Do We Exist?

To open up the world for those who want to see.

• For our people this means opening up their world by helping them develop professionally and personally.
• For our customers it is by delivering amazing travel experiences.
• To our suppliers, it is working together to provide amazing travel experiences to our customers.

4 Our Core Values - Lasting and Key Values Unique To Us

Irreverence - We take our business seriously but not ourselves. We respect each other, our customers and our suppliers.

Ownership – We take full responsibility for our business and treat it as our own.

Egalitarianism – Everyone has the same opportunities, rights and privileges. Self important people don’t fit in.

5 Our Philosophies

OUR PEOPLE - how we behave:

5.1 Our People - The right people

We care for our people's health and wellbeing, their personal and professional development and their financial security. We believe that work should be challenging and fun for everyone. The right people fit in with our culture, our values and our philosophies or they do not stay.

5.2 Our Customer

Our customers always have a choice and we care about personally delivering amazing travel experiences to them. This is delivered with respect, honesty, integrity and a great attitude.

5.3 Brightness Of Future

All of our people belong to a Team (family), a Village, an Area (tribe), a Nation and a Country. This supportive work community provides an exciting and challenging career path and future for committed people. Promotion and transfers from within will always be our first choice and will give people the opportunity to move globally across our company. As a company we recognise and celebrate our individual and collective successes.

5.4 Taking Responsibility

We take full responsibility for our own successes or failures. We do not externalise. We accept that we have total ownership and responsibility, but not always control.

5.5 Egalitarianism and Unity

In our company, we believe that each individual should have equal privileges and rights. In all our countries and all our businesses there should be no ‘them' and 'us’.

OUR BUSINESS MODEL - how we operate:

5.6 Ownership

Our people have the opportunity to share in our company’s success through outcome-based incentives and profit share. Leaders have ownership through our Business Ownership Scheme 'BOS' and Employee and Leadership Share Plans. Business leaders and business team members see the business they run as their business.

5.7 Financial Incentives

Our people have financial incentives which are based on measurable, outcome based, quantitative KPIs. What gets rewarded gets done is our basic principle, and we reward outcomes - not behavior.

5.8 Standard Team Operating Systems – One Best Way

In each of our thousands of small businesses there is ‘one best way’ to operate. These are standard (in 7 areas) systems employed universally until a better way is shown. We value common sense over conventional wisdom in running our business.

The 7 Team systems are:

• Goals
• Plans and Budgets
• Branding and Advertising
• Customer Sales and Service
• Our People and Communications
• Finance and Reporting
• Directorships

5.9 Family, Village, Tribe

Our structure is simple, lean, flat and transparent, with accessible leaders. Our Business Model is being one of the world's best and biggest small business operators. We have a maximum of 5 layers. The village is an integral part of the structure with a Village Leader running their own team and 3-5 other Teams and Leaders.

One. Family (Teams – min 3, max 7 members) Villages (min 3, max 7 Teams)

Two. Tribe (Areas – min 10, max 50 Teams-with a strong village structure)

Three. Nations/Brands (min 8, max 15 Areas-or 20-60 villages)

Four. Regions/States/Countries

Five. Board and senior leadership team (Taskforce)

5.10 Profit We Are Proud Of

A fair margin, resulting in a business profit we can be proud of, is the key measure of whether we really are providing our customers with an amazing experience, amazing product and a caring and respectful service – an experience customers genuinely value.

6 Key Principles of this Code of Conduct

It is important that all of our people adhere to and abide by this Code of Conduct to ensure that we conduct our business with honesty, integrity and to the highest standards of personal and professional ethical behaviour.

Our people are required to adhere to and obey these Key Principles in all of their activities and dealings:

• always act honestly and with integrity and to the highest standards of personal and professional ethical behaviour and always consider: 'Is this the right thing to do?'
• deal honestly and fairly with, and be courteous and respectful to, all of our people, our customers and our suppliers
• act in the best interests of the Flight Centre Travel Group while employed or engaged by Flight Centre Travel Group, and in a manner which upholds our brands, values, Philosophies and our reputation
• not enter into any arrangement or engage in any personal business or financial activity that would conflict with your role, the best interests of the Flight Centre Travel Group or that would be likely to negatively impact the brands or reputation of the Flight Centre Travel Group
• create and support a safe work environment that aligns with Flight Centre Travel Group's commitment as an equal opportunity employer, and which does not tolerate or encourage discrimination, bullying, harassment, victimisation, is respectful of the human rights of others, and is in accordance with our Philosophies and policies (including, without limitation, our Workplace Bullying and Harassment Policy, Diversity Policy and Equal Employment Opportunity Policy)
• comply with all laws and regulations that apply to the Flight Centre Travel Group and not knowingly participate in any illegal or unethical activity
• not take advantage of your position or any information about the Flight Centre Travel Group or any of its customers or suppliers for your own personal gain, the gain of another person, or to cause harm to Flight Centre Travel Group
• ensure you are familiar with and comply with all of the Flight Centre Travel Group's policies, including those listed below and all of our HR Policies, undertake all required annual training modules in Compass and always ask for further guidance if you are unsure about anything required of your conduct, behaviour or responsibilities
• notify your operational leader, your GM of Finance or CFO, or anyone from our Peopleworks, Enterprise Risk or Legal Services Teams, or the Whistleblowing Hotline, if you believe anyone is not acting in accordance with this Code of Conduct
• only deal with our business partners and suppliers who demonstrate ethical and responsible business practices which are consistent with this Code of Conduct

Key Flight Centre Travel Group Policies

The following Flight Centre Travel Group policies, together with this Code of Conduct, reflect our Key Principles and outline the minimum standards expected of our people and in order for us to achieve and uphold our Vision, Purpose, Core Values and Philosophies and to protect our great company, our brands, our reputation and all of our people.

The policies and training modules referred to in this Code of Conduct will apply and vary by country and they apply to our people as named & modified for each country in which we operate.

If you are unsure about which or how any of these policies or modules apply in your geography, or what the policy is called in your local country, you should contact your local Peopleworks Team for clarification.

Global Policies	Local Policies *
This Code of Conduct	Communications, Email, Chat and Internet Policy
Anti-Bribery and Corruption Policy	Diversity Policy
FC Share Trading Policy	Travel Etiquette Policy
Communications and Continuous Disclosure Policy	Social Media Policy
Whistleblowing Policy	Acceptable Use Policy
Anti-Fraud Policy	Privacy Policy
	Data Security Policy
	Risk Management Policy
	Drugs, Alcohol and Smoking Policy
	Competition and Consumer Law Training Policy
	Anti-Money Laundering and Counter-Terrorism Financing Programme
	Equal Employment Opportunity Policy
	Workplace Bullying and Harassment Policy

* The above "local" policies will apply and vary by country and they apply to our people as named & modified for each country in which we operate. The policies referred to in this Code of Conduct are the names of those policies as used in our Australian businesses. If you are unsure about which or how any of these policies apply in your geography, or what the policy or training module is called in your local country, you should contact your local Peopleworks Team for clarification.

7 Our Expectations

At all times, we expect our people to work in accordance with the standards outlined below.

7.1 Lawful and Ethical Behaviour

We are committed to acting ethically and responsibly, and complying with the relevant laws and regulations in all countries and regions in which we conduct our business.

Acting ethically and responsibly goes beyond mere compliance with legal and regulatory obligations. It involves being a good corporate citizen, by acting with honesty, integrity and in a manner that is consistent with the expectations of our customers, our suppliers, our shareholders, other external stakeholders, our board and senior leadership team and the broader community and also acting in accordance with the spirit as well as the letter of the law.

Our people must ensure that they act in compliance with applicable laws, regulations, company policies and procedures at all times. You should promote legal compliance amongst your co-workers.

In some cases, it may be difficult to understand which laws and regulations apply. If you find this to be the case, seek advice from your operational leader, your GM of Finance or CFO, or anyone from our Peopleworks, Enterprise Risk or Legal Services Teams.

If you become aware of a breach or potential breach of any law, regulation, group policy or procedure, you must refer it to one of these people/teams or to the Whistleblowing Hotline (see the Whistlblowing section below and also our Whistleblowing Policy for information on how to report your concerns).

To ensure that our reputation and credibility is maintained, it is important that our people act ethically and honestly at all times. This Code of Conduct does not cover all Flight Centre Travel Group policies or all laws. If a law conflicts with this Code of Conduct, we follow the law. If a local custom or practice conflicts with this Code of Conduct, we follow this Code of Conduct.

All of our people must read and comply with your region's local equivalent of our Anti-Fraud Policy and Anti-Money Laundering and Counter-Terrorism Financing Programme and all associated procedures.

All of our people must also complete our mandatory Code of Conduct Training Compliance module in Compass annually. That module contains guidance about what is legal and ethical behavior and what is not. Our people must also complete any other Ethical Business Practices module/s relevant to their role and position in Compass annually.

7.2 Anti-Bribery and Corruption law compliance

Bribery and Corruption

Our people, must, regardless of position or location comply with all applicable anti-bribery laws. Failure to comply with anti-bribery laws is a criminal offence. The penalties for breaching anti-bribery laws are significant for both individuals and for the Flight Centre Travel Group, including imprisonment, large fines and reputational damage.

Our people must not:

• bribe another person;
• receive a bribe;
• make "facilitation payments" or pay "kickbacks" to induce a favourable business decision;
• bribe a foreign public official or government entity/official to induce the official to make a favourable business decision; or
• make or fail to make, alter, destroy or conceal a document that shows the payment or receipt of a bribe.

Our people must:

• read and comply with our Anti-Bribery and Corruption Policy;
• complete your mandatory Anti-Bribery and Corruption Training Compliance module in Compass annually;
• to the extent that you become aware of any suspected, attempted or actual bribes or facilitation payments, contact our Legal Services Team or follow the procedures for reporting concerns as set out in Flight Centre Travel Group’s Whistleblowing Policy;
• ensure that all third parties (such as contractors and suppliers) are aware of Flight Centre Travel Group's Anti-Bribery and Corruption Policy, and understand that they are required to comply with it and in certain circumstances, ensure that this Policy is applied to third parties by including appropriate anti-bribery and anti-corruption provisions in their engagement documentation.

Political and Other Donations

The Flight Centre Travel Group does not make contributions to political parties nor does it make donations at the request of government officials.

We only make charitable donations that are legal and ethical under local laws and practices that are in accordance with our charitable objectives. Requests for sponsorship should be forwarded to your local CFO for approval in the first instance or to the Flight Centre Foundation.

Gifts, Entertainment and Hospitality

Good faith hospitality, promotional or other, business expenditure which seeks to improve Flight Centre Travel Group’s image, to better present our products and services, or establish cordial relations, is an important part of our business. Our Anti-Bribery and Corruption Policy does not intend to prohibit reasonable and proportionate hospitality, promotional or other similar business expenditure intended for these purposes. However, all gifts and hospitality must be for a genuine purpose, reasonable and given in the ordinary course of business. Gifts and/or hospitality can never be given or received where there is an intention to influence, induce or reward improper performance.

Dealing with public officials poses a particularly high risk in relation to bribery due to strict rules and regulations in many countries. The provision of money or anything else of value, no matter how small, to any public official for the purpose of influencing them in their official capacity is prohibited. The prior written approval of your local CFO is required in relation to gifts and hospitality in the public sector.

Bribes include giving, offering, promising, requesting, agreeing to receive, or receipt or acceptance of, any advantage, whether financial or not, in order to influence a person corruptly or improperly in the exercise of that person's duty.

Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.

Government officials include those in government departments, but also employees of government owned or controlled commercial enterprises, international organisations, political parties and political candidates, and any person acting in an official capacity on behalf of a foreign government or an instrumentality.

Kickbacks are typically payments made in return for a business favour or advantage.

Please also read and be aware of your local Operational Expense Policy which will also be available on your local intranet.

7.3 Modern Slavery and Human Trafficking

Modern slavery is an overarching term encompassing various forms of human rights abuses including forced labour, child labour, domestic servitude, bonded labour and human trafficking. Modern slavery is punishable as a criminal offence in most countries in the world and companies found to be involved in these offences could face prosecution, administrative actions and civil claims.

Flight Centre Travel Group is committed to ensuring that it identifies and prevents occurrences of modern slavery in its business and supply chains and it expects the same standard of behaviour from its suppliers. Flight Centre Travel Group will not conduct business knowingly with anyone engaged in modern slavery or knowingly permit such conduct to be carried out in any of its supply chains.

The detection and reporting of modern slavery is the responsibility of all employees. Whilst modern slavery can occur in any industry or region, high risk areas for travel and tourism have been identified as hotels (in particular, hotel cleaning staff), cruise ships and tour operators. Sectors which engage high numbers of low-paid, seasonal or agency workers through third party labour providers also present a greater risk of exploitative practices. High risk regions for modern slavery include the Middle East, Africa and South East Asia.

You must report any knowledge or suspicion that any person or organisation in our business or supply chains may be subject to, or involved in, any form of modern slavery. If you are unsure about whether a particular act, the treatment of workers, or their working conditions within any tier of our supply chains constitutes any form of human rights abuse, you must raise it with your operational leader, your GM of Finance or CFO, or anyone from our Peopleworks, Enterprise Risk or Legal Services Teams as soon as possible. If you feel uncomfortable reporting the issue or suspicion directly, you may report any concerns you may have anonymously through our Whistleblowing hotline, as set out below and in our Whistleblowing Policy.

7.4 Competition laws

We seek to outperform our competitors fairly and honestly. We are required to comply with all competition and antitrust laws and similar laws governing competition in all countries in which we operate.

It is prohibited to enter into agreements, arrangements or understandings with our competitors or suppliers:

• that have even the appearance of impropriety,
• if they are prohibited exclusive supply or distribution arrangements,
• if to do so would be a misuse market power to damage competition, or
• if they involve any misleading or deceptive conduct.

All of our people must be aware of their obligations under competition laws in the countries and regions in which we conduct business. Failure to comply with relevant competition laws has significant effect on both the individuals concerned and on the Flight Centre Travel Group. Penalties include substantial fines, reputational damage, and in some cases, imprisonment.

Our people must:

• understand how their obligations under competition laws affect their dealings with customers, competitors or suppliers;
• comply with consumer guarantees, and not engage in anti-competitive conduct, or misleading and deceptive advertising;
• comply with all internal conduct, advertising, marketing and availability checking guidelines;
• immediately report any suspected, attempted or actual non-compliance with competition laws to our Legal Services Team; and
• complete any applicable local: (i) mandatory Competition and Consumer Law Training Compliance module; and, for certain Australian roles and positions, and (ii) mandatory Competition and Consumer Law (Restrictive Trade Practices) Training Compliance modules, each in Compass, annually.

7.5 Inside Information & Insider Trading

Our people must not deal in Flight Centre Travel Group securities or securities which are in any way associated with Flight Centre Travel Group while they are in possession of non-public information which might have a material effect on the price or value of Flight Centre Travel Group securities.

If our people are in possession of material non-public information relating to other listed entities (inside or outside the Flight Centre Travel Group), they must not deal in the securities of that entity.

All of our people must read and comply with our FC Share Trading Policy.

7.6 Conflicts of interest

Our people must avoid conflict of interest situations and avoid placing themselves in compromising situations.

A conflict of interest will generally arise where your own personal or commercial interests conflict or could potentially conflict with Flight Centre Travel Group’s interests (please also refer “Close Personal Relationships” below).

Our people must not do anything or act in any way that would result in their loyalty being divided between themselves and Flight Centre Travel Group. These situations may arise when:

• the private interests of our people conflict directly or indirectly with the interests of the Flight Centre Travel Group; or
• our people are involved in a business that is in competition with the Flight Centre Travel Group.

In the event that a conflict of interest does arise, the circumstances should be disclosed immediately to that person's direct leader. Flight Centre Travel Group will either confirm how such a conflict of interest can be managed effectively or alternatively direct that person to cease the activity causing the conflict of interest. Any person with a conflict of interest (whether actual or perceived) must not participate in any decision making process related to the conflict.

7.7 Close personal relationships

All of our people involved in a close personal relationship (e.g. two of our people in direct reporting lines who are dating, or any personal relationship where there may be an actual or a perceived conflict of interest may arise) or a close relative relationship (e.g. family including defacto spouse, children, siblings, parents or other relatives residing in the same household) must disclose this relationship to the National HR Team Leader.

This is to avoid a conflict of interest where our people concerned may have the ability to influence the other's employment or the way they conduct their role (e.g. recruitment and appointment process, promotion, remuneration or termination of employment).

The National HR Team Leader will disclose the relationship to the Global Peopleworks Leader where appropriate, to discuss any reasonable steps that should be put in place to avoid possible conflicts of interest that may arise. These types of reporting lines will only be approved where there is no viable alternative (e.g. in remote / rural areas). Failure to disclose such a relationship to the National HR Team Leader may result in the company taking whatever action is considered appropriate including possible disciplinary action.

7.8 Confidentiality

Our people may obtain confidential information about Flight Centre Travel Group during the course of their employment or involvement with Flight Centre Travel Group.

Our people must not reveal any confidential information concerning Flight Centre Travel Group, use that information in any way which may injure or cause loss to Flight Centre Travel Group, or use that confidential information to gain an advantage for themselves.

Sometimes, persons outside Flight Centre Travel Group may request confidential information from our people. It is important that our people do not disclose such information unless it is authorised by your local CFO, who may obtain authorisation from our Legal Services Team.

7.9 Privacy

Flight Centre Travel Group is committed to ensuring that the privacy of individuals is maintained, and that appropriate safeguards are in place to protect the personal information of our people, contractors, customers, suppliers and potential employees. We are required to comply with all privacy and data protection laws and similar laws governing the handling of personal information, in all countries in which we operate.

Our people must not collect personal information unless it is required in order to perform one of our legitimate functions, and must not use, access or disclose any personal information of another person for anything other than the purpose for which it was collected. We handle large amounts of personal information, given the nature of our business, and it is important that we do so in accordance with our legal obligations, and treat it with care and respect.

Personal information must not be used for marketing purposes without the express consent of the individual concerned.

Our people must read and comply with our Privacy Policy and our Data Security Policy for your region and all applicable Information Security Policies, and must also complete our mandatory Privacy and Data Protection Training Compliance module in Compass annually (or any applicable local equivalents).

7.10 Intellectual property

Intellectual Property (IP) is the intangible legal right in creations of the mind such as inventions, artistic works, images, designs, written materials, business and domain names, and confidential information. Legally, IP rights allow the IP owner to do certain things to the exclusion of others.

Under your employment or engagement agreement, you agree that Flight Centre Travel Group owns the IP rights to anything you create or develop while employed or engaged by Flight Centre Travel Group, including products, services, documents, software code, content, reports or processes.

You are also required not to engage in the unauthorised use of a third party's IP. This is a breach of the law and may result in Flight Centre Travel Group breaching its contractual obligations to third parties.

The obligations in this section apply during the course of your employment or engagement, and also continue after your employment or engagement with Flight Centre Travel Group ends.

7.11 Continuous Disclosure & Public statements about Flight Centre Travel Group

Continuous Disclosure

Flight Centre Travel Group is listed on the ASX and must comply with the relevant continuous disclosure provisions of the Corporations Act and the ASX Listing Rules which require that Flight Centre Travel Group must immediately announce all 'price sensitive information' to the ASX (except in certain limited circumstances). Information requiring ASX disclosure must not be provided to any external party until it has been announced to the ASX. This is generally known as the company's ‘continuous disclosure obligations’.

Broadly, information is 'price sensitive information' if it is not generally available and a reasonable person would expect the information to have a material effect on the price or value of Flight Centre Travel Group’s securities. Please refer to our Communications and Continuous Disclosure Policy for examples of information which may be price sensitive information. Our Managing Director has established a 'continuous disclosure consultation group' to handle these types of issues.

All of our people must immediately notify full details of any potentially material non-public information relating to the Flight Centre Travel Group that comes to their attention to their CFO, EGM, Company Secretary or Legal Services Teams. They will then refer it to our continuous disclosure consultation group which will decide whether an ASX announcement is required. This information must not be disclosed to any external party without permission.

Public Statements

On some occasions, our people may be asked to express their views on a particular issue about Flight Centre Travel Group, for a newspaper article, television program or other publication. However, our people must refrain from making any public comments.

Only the Chairman of the Board, our Managing Director, CEO, COO, CFO, Company Secretary and Communications and Investor Relations Manger are authorised spokespersons for Flight Centre Travel Group, unless express approval has been obtained.

Flight Centre Travel Group regularly conducts open briefings for analyst, investor and media groups to discuss information that has been announced to the market. This is part of an investor relations program designed by Flight Centre Travel Group to facilitate effective two-way communication with investors. The Communications and Investor Relations Manger is responsible for this program.

All internal communications are to be treated as confidential, and not distributed to any parties (except in limited circumstances permitted by our policies).

Please refer to our Communications and Continuous Disclosure Policy for further information.

7.12 Harassment, bullying and discrimination

Flight Centre Travel Group is committed to ensuring that our people are treated fairly and with respect. Harassment, bullying, victimisation or discrimination, any kind of conduct that (whether intentionally or otherwise) offends or intimidates others in the workplace, or which creates a hostile or threatening work environment or disrupts a person's ability to work, will not be tolerated in any of our workplaces. This obligation extends to the use of email, text messages, instant chat or messaging apps, on social media and networking sites where any of our people interact with each other, our customers, suppliers or with any other third parties.

Any incidents or potential incidents of harassment, bullying, victimisation or discrimination should be reported immediately to Peopleworks or in accordance with our Whistleblowing Policy.

Our people must read and comply with all applicable HR Policies.

Flight Centre Travel Group expects to reasonably direct and lead its people under standard terms of performance management. Refer to our Performance Counselling, Discipline and Termination Policy (or any applicable local equivalent) for more information on what is considered harassment, bullying and discrimination. Flight Centre Travel Group does not condone malicious or vexatious claims of harassment, bullying or discrimination and any instances of such will likewise be handled in accordance with our Performance Counselling, Discipline and Termination Policy (or any applicable local equivalent).

7.13 Equal opportunity

Flight Centre Travel Group recognises that we are all different and our differences can include our gender, age, marital status, parental status, family responsibilities, pregnancy, race, religion, disability or impairment, political belief, sexual preferences and identity, and physical features.

We must respect these differences and not treat people unfairly because of these differences. Flight Centre Travel Group is committed to ensuring our workplace is an enjoyable place to work. To do this we must ensure that no one is subjected to discrimination, victimisation or vilification and that these differences do not prevent anyone from enjoying the work opportunities that Flight Centre Travel Group provides.

Our people must read and comply with our Diversity Policy (or any applicable local equivalent).

Any conduct that contravenes these standards is unacceptable and may be considered misconduct.

7.14 Safe working environment

The safety of all of our people is of the upmost importance to Flight Centre Travel Group. We are committed to providing a safe working environment for all of our people and, in doing so, we ensure that we comply with all laws and regulations regarding occupational health and safety.

You should report any occupational health and safety issues to your local Peopleworks Team via the incident report on Flight Deck, so that we can pro-actively manage safety in our workplaces.

Our people must read and comply with all of our HR Policies, including our OH&S Commitment and our OH&S Responsibilities Policy (or any applicable local equivalents of these).

7.15 Drugs, alcohol and smoking

As part of our Flight Centre Travel Group’s commitment to our health and safety obligations, our people are required to read and comply with our Drugs, Alcohol and Smoking Policy (or any applicable local equivalent).

We like to celebrate our successes, but we must do that without risking the health and safety of ourselves or others. When at work you must ensure that you are in a condition to perform your duties safely and efficiently, and without risk of causing harm to yourself or others.

If you are required to take any prescription or authorised or legally permitted medication or drugs which may impair your ability to work safely and effectively, you must notify your immediate Team Leader and discuss any work restrictions that may be necessary as a result of the medication or drugs. Any such disclosure will be treated as sensitive information and we will work with you (so far as is reasonably practicable) to ensure that you suitable work restrictions are applied, and that neither you nor any other person is placed at risk as a result.

You must not possess, use, distribute, sell or offer to buy illegal drugs at any Flight Centre Travel Group premises, functions, or through the use of Flight Centre Travel Group communication systems, including phone, chat and email. Any attempt to do so will be treated as serious misconduct.

Flight Centre Travel Group provides a smoke-free work environment in all of our premises, including before and after normal office hours, and therefore smoking is prohibited while on the premises.

7.16 Maintenance and retention of records and information

Keeping accurate and up-to-date records and information is essential to Flight Centre Travel Group’s business. Our people must ensure that all accounting and business records are complete, accurate and properly and honestly reflect Flight Centre Travel Group’s performance, transactions, assets, liabilities and position.

You must ensure that all records are maintained and retained in accordance with all applicable laws and Flight Centre Travel Group policies and dispose of records in a secure manner when they are no longer required.

7.17 Communicating with investigators and auditors

When dealing with investigators or internal or external auditors of Flight Centre Travel Group, you must co-operate with their instructions and ensure that any information given is complete, correct and in no way misleading. Always engage our Enterprise Risk or Legal Services Teams to ensure that they are aware of any investigation.

7.18 Communication, email, chat, internet and social media

Flight Centre Travel Group is committed to the highest standards of honesty, integrity and professionalism. We are accountable for what we do and we are respectful in our dealings with others. Our people must always maintain professionalism, use respectful and appropriate language at all times, and ensure that any comments made via any communication channel, including social media, do not infringe copyright or defame another person. Our people must also avoid making any statements that might bring the Flight Centre Travel Group or any of its businesses into disrepute.

Our people are provided with computer, email, chat and internet facilities for business purposes, and for limited personal use. Any personal use must not interfere with Flight Centre Travel Group's use of facilities, cause additional cost to Flight Centre Travel Group, or affect your work performance.

You should be aware that telephone conversations may at anytime be recorded for the purpose of performance evaluation, and your use of Flight Centre Travel Group’s IT and online resources can be and is subject to monitoring. You consent to such recordings and monitoring as a condition of your employment.

Our people must read and comply with our Communication, Email, Chat and Internet Policy (or local equivalent), and our Social Medial Policy (or local equivalent), and must also complete our mandatory Communication and Social Media Training Compliance module in Compass annually (or local equivalent).

7.19 Whistleblowing Policy

It is important that our people feel comfortable raising issues that are of legitimate concern to them, such as any actual, potential or suspected fraud, theft, harassment, workplace bullying, discrimination, falsification of any documents or records, or bribery and corruption.

Our people should report these concerns to their team, area or nation leader, CFO, EGM, Peopleworks, Enterprise Risk, or Legal Services. If our people feel uncomfortable or unable to report their concern to any of these people, reports can be made by contacting the Whistleblowing hotline, which is independently managed by an external provider, PricewaterhouseCoopers. The hotline is open 24 hours per day / 7 days per week.

Our people can make their report anonymously, however, it is preferred that our people identify themselves as this assists the investigation process. The Whistleblowing hotline protects the identity of people who make a report.

Any disclosures made will be investigated fully. The person who reported the issue will be kept informed of the progress and, where possible, the outcome of the investigation. Their identity will remain confidential, unless required to be disclosed by applicable law, for legitimate investigative purposes, or in the course of related legal proceedings.

If an allegation is made in good faith, but is not confirmed by the investigation, no action will be taken against the person raising the misconduct concern. If however, the allegation is or appears to be vexatious or frivolous, or without good reason, the same protection may not be provided.

Further guidance can be found in the Whistleblowing Policy.

8 Breaches

Flight Centre Travel Group attaches great importance to this Code and takes compliance with and enforcement of our legal, ethical and social responsibilities seriously. We require that all of our people comply with this Code of Conduct (as may be amended from time to time) at all times in connection with their employment or engagement by the Flight Centre Travel Group.

Any breach of applicable laws, business ethics, or other aspects of the Code may be considered misconduct and result in disciplinary action.

Depending on the severity of a breach, disciplinary action may include reprimand, formal warning or termination of employment, with or without notice. In addition, if you breach the law, you may be personally liable for your actions and you may, in some cases, face criminal prosecution.

9 Related Documents

The most up to date version of this Code of Conduct, and other Policy documents that are relevant to this Code of Conduct, can be found on your local intranet.