6.3 Code of Conduct
Catalpa's Code of Conduct defines our values and standards of professional conduct.
This Code of Conduct is included in the onboarding process for all new hires to Catalpa. All new hires will be required to review and sign the Code of Conduct as a part of our compliance requirements during onboarding.
Previous version | May 2022 |
Reviewed on | December 2023 |
Next review | December 2026 |
A message from our Directors
Hi everyone,
Our Code of Conduct is an integral part of our DNA at Catalpa.
Catalpa’s Code of Conduct guides how we behave in accordance with our values. Our values help us navigate the way we work at Catalpa.
They shape our culture and influence what we do, how we work, how we make decisions, and even who we hire.
Catalpa’s Code of Conduct explains the standards of professional conduct we expect of every member of the Catalpa team. Our Code of Conduct helps us put our values in action and applies to everyone - staff, consultants, suppliers, partners, directors and board members, wherever we are located.
This document isn’t about throwing out some buzzwords, we are genuinely serious about creating an awesome, inclusive culture where our decisions and actions are consistent with our values.
If you have questions or doubts about a situation you are facing, or concerns about an action or behaviour that you’ve witnessed, you can speak to either your manager, the Head of your Area, People & Culture, or a member of the Senior Management Team, including us!
We encourage you to read this document closely so that you understand how our values will guide our behaviour and ensure Catalpa is respected for its safe, honest and professional approach and working environment.
David and Anders
Scope and responsibilities
Scope
This Code of Conduct applies to all staff at all times during their services with Catalpa.
All new employees and consultants will be asked to review and sign the Code of Conduct during their onboarding and at any contract extension thereafter.
The Code of Conduct applies to the behaviour of all staff at their place of work, as well as situations outside work where they are representing Catalpa. Examples include social functions, conferences, and work carried out at sites that are not operated by Catalpa, such as client premises.
Staff must comply with this Code of Conduct when using Catalpa’s equipment or facilities, including computer systems. This Code of Conduct applies when dealing with other staff, or with existing or prospective clients, visitors, contractors and suppliers.
This Code of Conduct requires our staff to behave at all times in a way that upholds our Catalpa Values and the integrity and good reputation of Catalpa. Staff should be mindful that any conduct at any time that has the potential to bring Catalpa into disrepute may be assessed and treated as suspected misconduct.
“Staff” in this Code refers to our directors, board members, staff, consultants, casual staff and partners we engage with across all geographies we live and work in.
Responsibilities
The obligations of our staff include:
Read, understand, and follow the Code of Conduct and seek guidance when needed
Promptly report all compliance concerns through one of the many channels provided by Catalpa
Avoid any practices that may lead to unlawful conduct or harm to Catalpa’s reputation
Fully support anyone who raises a compliance concern and never retaliate in any way against anyone who does raise a question or concern
Cooperate fully in all investigations.
The roles and responsibilities of managers at Catalpa:
Ensure your team has read, understands, and follows the Code of Conduct
Anticipate compliance risk areas that may affect your team and take steps to mitigate risks
Communicate regularly with your team about the importance of adhering to the principles and spirit of the Code of Conduct
Emphasise the value of reporting potential compliance concerns promptly and foster an environment of open reporting
Hire and promote only those people who have high standards of integrity
Regional laws and legislation
In every country we work in, we comply with applicable laws. When deciding whether to apply the laws of the country or the principles of Catalpa’s Code of Conduct, use whichever is stricter. If you break the law, or violate Catalpa’s Code of Conduct or any of our policies, you may face disciplinary action.
The principles of our code of conduct
Catalpa’s Code of Conduct is encapsulated under eight key areas:
We respect people
We act with integrity
We respect privacy of information
We actively protect Intellectual Property and Confidential Information
We are committed to the safety and wellbeing of Children
We are committed to the prevention of sexual exploitation, abuse and harassment
We are committed to the prevention of fraud and corruption
We are safety & security conscious
Principle 1 - We respect people
At Catalpa, equality and respect are fundamental to our culture. We respect all persons equally and without any distinction or discrimination based on nationality, race, gender, religious beliefs, class, disability, political opinions or any other personal attributes.
Catalpa promotes a diverse and inclusive workplace where opportunities for achievement and growth are supported for everyone. We are culturally agile - we take into account other peoples’ customs and values. We value the uniqueness of individuals and the varied perspectives and talents they provide. We respect and protect the human rights of all employees, clients and people, with whom we interact.
We act at all times in accordance with Catalpa values - both internally and when liaising with Clients, beneficiaries and partners. These are:
We put people first: In all we do, we aim to improve and support the lives of people.
We focus on what matters: We do work we believe in, and focus on the change we want to create.
We learn and get better: We are committed to continuous improvement, because we achieve more when we combine our passion with ability.
We are kind and share. Nice people work here. We believe inclusivity and collaboration begin with sharing and being kind.
We value ideas over hierarchy: Great ideas are great, no matter who they come from. We all listen and build together.
We are a genuine partner: When our partners succeed, we succeed. We share the wins and the losses.
Change takes time: We're in it for the long haul, we persist, we grind it out, because we know that societies and systems don’t change overnight.
We will watch out for decisions that are inconsistent with these values or violate the right to equal opportunity. We are aware of our assumptions and biases and are prepared to challenge them.
We do not treat anyone differently because of a personal characteristic. Discrimination, harassment, and retaliation, in any form, are prohibited.
We will not create hostile work environments, we will not tolerate offensive conduct, such as making derogatory comments or displaying materials that are offensive.
We will not take adverse action against anyone because they raised a good faith concern regarding a violation or potential violation of Catalpa’s Code of Conduct or an applicable law.
Nice people work at Catalpa. We achieve better results when we work together. That means we can still be honest with each other, but we are critical of ideas, not of each other. We are all open to constructive feedback and ways to develop ourselves professionally.
Above all, we know our work benefits ourselves and others. We are here because we love it and want to make a difference.
Principle 2 - We act with integrity
At Catalpa, we do business the right way. We promote a culture of integrity through mutual respect, trust in each other and high standards of ethics in all our work and interactions with each other.
When interacting with government officials, we follow high ethical standards and act in a transparent manner. We are honest, truthful, and accurate, and we follow Catalpa’s policies and procedures and any applicable country laws.
We minimise conflict of interest by:
Always acting in the best interests of Catalpa and using Catalpa property and resources primarily for Catalpa’s benefit.
Declaring to your manager all personal or business interests that might reasonably be perceived as affecting our judgment to perform our roles at Catalpa or that may create an appearance of impropriety. This includes:
Any potential conflict of interest with another employee, consultant, supplier, service provider, or third party. For example, you start a business on the side with a friend offering the same services as Catalpa, or, you accept a gift from a supplier in exchange for business.
Financial interest or position in companies that we could use to influence Catalpa’s current or future business
Where we are recruiting, promoting or directly supervising family members or personal friends
Avoiding any activity at work or outside of work that might interfere with our obligations to Catalpa or that could hurt the good reputation of Catalpa.
Not intentionally misrepresenting our official functions or title to any entities or persons.
We always comply with Catalpa policies and Country laws by:
Understanding and complying with Catalpa policies and the terms of our employment contracts
Following reasonable and lawful management instructions
Complying with the applicable laws of the countries in which we are each located and work in
Catalpa will act in accordance with the Australian Modern Slavery Act (Cth), by understanding that modern slavery occurs when vulnerable people are exploited for personal gain or commercial profit. Therefore, the following practices are prohibited:
Human trafficking (including orphanage trafficking)
Slavery
Servitude
Forced labour
Debt bondage
Forced marriage
Child labour
We remain neutral by:
Not publicly expressing opinions connected with political affairs or engaging in political activities that may reflect adversely on the impartiality of Catalpa.
Not exercising any activity or outside employment that could be regarded as inconsistent with, or reflecting adversely upon their impartiality, or that would result in a conflict of interest, without previous agreement of Catalpa’s Directors
We act ethically when dealing with Government Officials by:
Conducting all official duties with integrity, free from any taint of dishonesty or corruption, including not engaging in any act of favouritism, nepotism, cronyism, or bribery.
Not offering gifts or hospitality to any officials when the gifts or hospitality do not comply with local rules and regulations. This includes not accepting from any external source (including governments and other organisations) without authorisation, any honour, decoration, gift, remuneration, favour or economic benefit which is more than a “token gift”. Examples of token gifts include cheap pens, desk diaries, trinkets, etc.
Not behaving in a way that might be perceived as an attempt to influence the behaviour or decision of a governmental official.
Principle 3 - We respect privacy of data
It is necessary for Catalpa to hold itself up to the highest standards in relation to protecting client and personal data. Respecting privacy is not simply about being compliant with laws; it is fundamental to the way that Catalpa works as a trustworthy and ethical company.
Catalpa adheres to the principles of Australia’s Privacy Act 1988 which describes how organisations must collect, handle and store personal information.
Catalpa collects, uses, holds, and otherwise processes personal and client data responsibly, lawfully, and carefully. We build privacy and security into the design of our products and services and employ appropriate safeguards to protect personal data against unauthorised use or disclosure. We uphold our Data Privacy and Storage Policy with the greatest of care to ensure all confidential information and intellectual property is not disclosed.
Catalpa aim’s to preserve data security and integrity through the following guiding principles:
Authorisation:
The only people able to access specific data are those who need it for their work
Data is not shared informally. When access to confidential information is required, staff request it from their managers.
We will make all efforts to protect personal information from misuse, interference and loss; and from unauthorized access, modification or disclosure.
Strong passwords are used and they are never shared or stored in an accessible place.
Data stored in our products is not disclosed to unauthorized people, either within Catalpa or externally.
Accuracy:
We go to great effort to ensure that data is accurate.
Data is regularly reviewed and updated if it is found to be out of date. If no longer required, it is deleted and disposed of.
Awareness:
Catalpa provides training to relevant partners and users to help them understand their responsibilities when handling data.
We ensure information is only used and disclosed for the purpose for which it was collected.
Response:
In addition to prevention, we also prepare ourselves in the event we need to respond to a breach. Every product and project has a defined Data Security Team.
If there is any suspicion of a data breach we ensure that the respective Data Security Team is informed to take appropriate action and inform affected parties.
Principle 4 - Intellectual property and confidential information
Catalpa’s intellectual property – which includes reports, data, tools, software, know-how and trade secrets are among our most valuable assets. We actively protect our intellectual property. We respect our intellectual property and the confidential information of others.
To safeguard our intellectual property and confidential information, all employees and consultants will:
Agree that Catalpa owns all rights to intellectual property.
Use our best endeavours to keep confidential information in a safe place and implement adequate security measures to ensure that third parties do not use, disclose or copy Confidential Information.
Honour obligations under nondisclosure agreements as outlined in employment agreements or any formal correspondence with Catalpa, if applicable.
Immediately report to their manager if they become aware of any breach of confidential information.
Not misuse intellectual property or confidential information - whether it belongs to Catalpa or is provided by others.
Not use, disclose or copy confidential information in any form or in any manner.
Not collude, or inappropriately exchange information with competitors nor will we gather competitive intelligence inappropriately.
Not make any comments to the media unless we are specifically authorised to do so.
Not publish any work (including writings, photographs, video footage, etc.) that has been produced in connection with, or that is related to, their role at Catalpa without prior approval of the Catalpa Directors.
Principle 5 - Child Safeguarding
Every child has the right to be safe from harm, and yet Catalpa recognises that children face abuse and exploitation in every country and culture around the world, and that in some cases child sex offenders have sought employment with non-governmental organisations (NGOs) for this specific purpose.
Catalpa is committed to the safety and wellbeing of all children. Catalpa supports the rights of children and will act to ensure a child safe environment is maintained.
contractors, and partners engaged with Catalpa in order to protect children.
Expected Standards of Behaviour
I agree that while working with or engaged in activities funded or organised by Catalpa I will:
treat children with respect regardless of race, colour, sex, language, religion, political or other opinion, national, ethnic or social origin, property, disability, birth or other status
not use language or behaviour towards children that is inappropriate, harassing, abusive, sexually provocative, demeaning or culturally inappropriate
not engage a child (under the age of 18 years) in any form of sexual activity or acts, including paying for sexual services or acts nor request any service or favor from a child in return for protection or assistance; and never engage in any sexual relationship nor any other exploitative relationship (emotional, financial or employment related) with a child under 18 years old. This is regardless of the local age of consent in the country in which I work. Ignorance or mistaken belief of a child’s age is no excuse and does not change my responsibilities.
wherever possible, ensure that another adult is present when working in the proximity of children
not invite unaccompanied children into my home, unless they are at immediate risk of injury or in physical danger
not sleep close to unsupervised children unless absolutely necessary, in which case I must obtain my supervisor’s permission, and ensure that another adult is present if possible (noting that this does not apply to an individual’s own children)
never use social media to contact, befriend, access or solicit a child nor to misuse children’s images on personal social media
never use any computers, mobile phones, video or digital cameras, or social media to exploit or harass children or to access child exploitation material through any medium (see also ‘Use of children’s images for work related purposes’, below)
not use physical punishment on children
not engage in behaviour to shame, humiliate, belittle or degrade a child or young person or otherwise emotionally or psychologically abuse a child or young person including exposing them to family violence
not hire children for domestic or other labour which is inappropriate given their age or developmental stage, which interferes with their time available for education and recreational activities, or which places them at significant risk of injury
comply with all relevant local legislation, including labour laws in relation to child labour
immediately report concerns or allegations of child abuse and exploitation in accordance with Catalpa Child Safeguarding Policy
immediately disclose all charges, convictions and other outcomes of an offense that relates to child exploitation and/or abuse including those under traditional law, which occurred before or occurs during my association with Catalpa
be aware of behaviour and avoid actions or behaviours that could be perceived by others as child exploitation and abuse.
These behaviours are not intended to interfere with normal family interactions.
When photographing or filming a child or using children’s images for work related purposes, I must:
take care to ensure local traditions or restrictions for reproducing personal are adhered to before photographing or filming a child
obtain informed consent from the child and a parent or guardian of the child before photographing or filming a child. As part of this I must explain how the photograph or film will be used
ensure photographs, films, videos and DVDs present children in a dignified and respectful manner and not in a vulnerable or submissive manner. Children should be adequately clothed and not in poses that could be seen as sexually suggestive
ensure images are honest representations of the context and the facts, and
ensure the file labels, meta data or text descriptions do not reveal identifying information about a child when sending images electronically or publishing images in any form.
Principle 6 - Prevention of Sexual Exploitation, Abuse and Harassment
Catalpa is committed to further improving standards, practice and culture to prevent and respond to sexual exploitation, abuse and harassment in our sector. Catalpa is building a culture that prioritises the safeguarding of vulnerable groups, and proactively addresses the power and structural inequalities that remain at the root cause of this issue.
We recognise that the nature of development and humanitarian initiatives can exacerbate inequitable power dynamics within the communities we work with and therefore requires vigilant attention to maintain the highest professional and ethical standards.
Catalpa is committed to nondiscriminatory and respectful behaviour - misconduct is not accepted, power is not abused and vulnerabilities and power inequality are not exploited.
In order to prevent sexual exploitation and abuse, Catalpian’s will:
Treat everyone with respect regardless of race, colour, gender, sex, language, religion, political or other opinion, national origin, ethnicity or social original, disability status, or social or other personal attribute.
Not commit any act of sexual exploitation, sexual abuse or sexual violence. This prohibition extends to all forms of sexual abuse or exploitation.
Not engage in any form of transactional sex. This could be any form of sexual activity in exchange for goods or services, money, employment or preferential treatment.
Not use language or behaviour that is inappropriate, harassing, abusive, sexually provocative, demeaning or culturally inappropriate.
Not abuse or attempt to abuse anyone who is vulnerable, or over whom I exercise power or confidence over, for sexual purposes.
Not engage anyone under the age of 18 in any form of sexual intercourse or sexual activity, including paying for sexual services.
Not engage in any form of sexual intercourse or sexual activity with any adult without their free and express consent.
Never use any computers, mobile phones, video cameras, cameras or social media to sexually exploit, abuse or harass anyone.
Not engage in any conduct which could be construed as sexual harassment:
staring or leering
unnecessary familiarity, such as unwelcome affection or touching
suggestive comments or jokes
insults or taunts of a sexual nature
intrusive questions or statements about your private life
displaying images/photos of a sexual nature
sending sexually explicit emails or text messages
inappropriate advances on social networking sites
accessing sexually explicit internet sites
requests for sex or repeated unwanted requests to go out on dates
Comply with all domestic laws on sexual exploitation, abuse and harassment
Immediately report concerns or allegations of sexual exploitation, abuse and harassment and non-compliance with the Code of Conduct and PSEAH Policy
Immediately disclose all charges, convictions and other outcomes of an offence that relates to sexual exploitation, abuse and harassment, including those under traditional law, which occurred before or during association with Catalpa
Contribute to creating an environment where our people know the expected behaviours and how to raise complaints and concerns.
Principle 7 - Preventing Fraud and Corruption
Catalpa does not tolerate fraudulent or dishonest behaviour and is committed to preventing, detecting and responding to fraud in all aspects of our business. Fraud and corruption is dishonestly obtaining a benefit, or causing a loss, by deceptions or other means.
To prevent fraud and corruption in our work, Catalpians will:
Not engage in any fraud, bribery, corruption, misappropriating, misusing funds or property of Catalpa, this includes but is not limited to:
Theft
Obtaining financial advantage or any other benefit by deception;
Causing a loss, or avoiding or creating a liability by deception;
Providing false or misleading information to Catalpa or failing to provide information where there is an obligation to do so;
Making, using or possessing forged or falsified documents, for example receipts;
Bribery, corruption or abuse of position;
Unlawful use of Catalpa computers, vehicles, telephones and other property or services;
Divulging confidential information to outside sources;
Hacking into, or interfering with a Catalpa computer system; and
Invoicing for goods or services under-delivered or not delivered;
Billing for a quality service/product and delivering something lower.
Actively prevent and detect fraud in our business and operations
Declare any conflict of interest
Principle 8 - We are safety and security conscious
We are passionate about making sure that everyone who works for, or on behalf of, Catalpa goes home safely at the end of the day. We earn the respect of each other, our contractors, our partners, our clients, and beneficiaries by providing a safe, healthy, and fair working environment.
We do this through the robust and consistent implementation of our internal safety processes. We also expect the same of our contractors and suppliers.
To ensure our safety and security, Catalpians will:
Not put ourselves in situations that could be dangerous, without the proper safeguards in place.
Follow Catalpa policies and not act in a way that places others at risk
We will provide support to each other when someone is struggling at work or is not coping because they feel overloaded, are concerned about organisational change, or have pressures outside of work that are contributing to a feeling of being overwhelmed and in need of support.
We will seek opportunities in our daily work routines that will increase the likelihood of everyone going home safely following a good day at work.
Comply with any security requirements and regulations for the countries in which we work, as well as any other security procedures or instructions that may be issued.
Abide by the Driver Rules and Regulations for the country when operating a Catalpa vehicle (refer to Vehicle Policy).
Comply with local traffic laws and regulations at all times, including drinking and driving laws, whether driving Catalpa vehicles or their private vehicles.
At no time use or have in their possession any drugs prohibited under local law.
Ensure that no firearms or ammunition of any kind are brought to or kept in Catalpa vehicles or Catalpa offices or premises.
Decision making
Catalpa’s Code of Conduct and our values also set clear guidelines and boundaries to help understand and consider the choices we face in our work. Sometimes we encounter situations that can test our judgment.
If you face a tough or testing situation, ask yourself:
Do you have enough information? Consider consulting with a manager or others who may be knowledgeable about the relevant subject and can provide the information you need to make a proper decision about a matter touching upon ethics and compliance.
Are my actions consistent with the Catalpa Code of Conduct and Catalpa’s policies? If the proposed decision or action is not consistent with Catalpa’s values, our Code of Conduct, and related policies, reassess your decision.
Is the decision or action ethical and legal? If the proposed decision or action violates applicable laws and regulations, stop. We comply with applicable laws wherever we work.
Will it reflect well on me and Catalpa?
Reporting
Staff have a duty to report any breach of this Code to the appropriate person (refer to Contact information). All reports and concerns raised will be properly considered and treated with discretion. The organisation will take all necessary steps against any form of retaliation suffered by staff reporting possible breaches of this Code.
Contact Information
All general inquiries on the Code of Conduct and its interpretation, reports and allegations of breaches of the Code should be directed to either:
Your manager, or another manager at Catalpa
The People & culture Manager
phoning the Catalpa Chief Operating Officer Brian Francisco (also the Safeguarding Focal Point) on brianfranciso@catalpa.io or by phoning on WhatsApp +17547027426
Further information about different kinds of complaints is provided below:
Child safeguarding concerns, and/or Prevention of sexual exploitation, abuse and harassment: Email safeguarding@catalpa.io or phone the Safeguarding Focal Point on WhatsApp +17547027426
As per the Whistleblowing Policy, if an eligible whistleblower (someone connected to Catalpa) reports a ‘disclosable matter’ to a Catalpa ‘protection officer’ (including the COO, or the People and Culture Manager) then they will be protected under the Whistleblowing Policy - please see the Whistleblowing Policy for more information including for definitions.
Reports can be made to Catalpa via Stopline, an independent third party platform which allows anonymous reporting and provides support to people trying to report including translation / interpretation services if needed. You can reach Stopline on:
Telephone: 1300 30 45 50 (Australia Only)
Email: makeareport@stopline.com.au
On-line: https://catalpa.stoplinereport.com
Mail: Catalpa, c/o Stopline, PO Box 403, Diamond Creek VIC 3089, Australia
Catalpa encourages anyone with concerns that the Staff Code of Conduct has been breached to report them immediately. All reports will be respected with confidentiality and the safety of personnel reporting will be a priority.
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