Ethical & responsible behaviour

We expect our employees to act with integrity and to comply with UniSuper policies and the law.

At all times, our employees must act with the utmost integrity, objectivity and in compliance with UniSuper policies and the law. That's why we've implemented a comprehensive Code of Conduct and Fraud Control Plan. UniSuper’s investment staff and directors must also adhere to our Securities Trading Policy.

Code of Conduct

In order to protect our stakeholders, our Code of Conduct sets out the high standards of honest, ethical and law-abiding behaviour we expect of our officers and employees. It also sets out the responsibility and accountability of UniSuper to investigate reports of unethical practices.

Our Code of Conduct applies to all directors, officers, representatives and employees of UniSuper. It is discussed with each new employee as part of their induction training and all employees must sign an annual declaration confirming their compliance.

Preventing fraud

To help prevent fraud, we have a formal Fraud Control Plan and we use an external anonymous reporting service to encourage whistle blowing. Suspected incidents of fraud, whether perpetrated by staff or external persons can be reported to the Fraud Control Officer or via an external confidential phone number.

Significant issues raised under the whistleblower program are first investigated by our internal auditors, and then reported to the Audit and Compliance Committee.

Securities trading policy

Our securities trading policy works alongside the 'insider trading' provisions of the Corporations Act. It states that no officer or employee should ever receive any personal advantage from information which has been obtained because of his or her role at UniSuper.

Under our securities trading policy, relevant staff must adhere to the following conditions:

• No trading without prior consent
• No investment option switching without consent
• Maintaining the Price Sensitive Information Register
• Annual declarations

Examples of misuse of information obtained through the performance of an officer or employee's role at UniSuper include:

• 'piggy-backing' or 'front-running'. This includes selling or purchasing securities in a manner consistent with the trades made by one of UniSuper's investment managers or in a manner consistent with significant ad-hoc allocations of capital into, or out of, asset classes by UniSuper itself.
• switching UniSuper's investment options as a result of specific product-related information gained only in the person's role at UniSuper, or
• buying or selling securities as a result of price sensitive information gained in the course of the person's role at UniSuper.

Any breach of this policy is handled in accordance with the Code of Conduct, and consequences can include suspension or termination of employment, as well as any civil and criminal liabilities.

Error rectification policy

UniSuper works hard to minimise errors in the administration of your super. However, because matters such as interim crediting rates and benefit calculations are a best estimate based on information available at a given time, some errors may occur despite our best endeavours.

If an issue is identified with your super, UniSuper will investigate and respond to it in a timely manner. If an error was caused by UniSuper or its administrator and it is found to be material, UniSuper’s policy is to compensate members who were adversely affected.

UniSuper will generally use a materiality threshold of 0.30% of the amount of the error in determining whether individual compensation should be paid. Where a member’s account is closed, compensation payments of less than $20 will not normally be made. These thresholds are in line with industry standards and regulatory practice guidelines. More details can be found in our Errors rectification policy.