Wilderness Internal Conduct Policy

Last Updated 11 AUG 2025

Objective

To outline the expectations of behaviour of all of our team members whilst employed by or representing the company.


Background

As part of our core value, “He tangata he tangata, he tangata!”, we're committed to caring for our people. This policy ensures everyone connected to our organisation—team members, customers, and suppliers—feels respected, valued, and supported. We foster an environment that embraces diverse perspectives and backgrounds, boosting our collective creativity and effectiveness.

We value every individual and strive for a workplace where everyone feels included, respected, and has equal opportunities. We provide fair employment regardless of background, promote equity through transparent practices, and maintain a safe, accessible environment free from harassment. We support diverse suppliers and continuously improve our Diversity, Equity, and Inclusion (DEI) efforts, always complying with relevant laws. Team members are expected to be respectful, act as allies, use inclusive language, and report any incidents of bias or harassment.

Our company values and professional standards outline the behaviours we expect from all team members. While employed, you must obey the law, treat colleagues and guests/customers with honesty, integrity, and respect, and always represent the company positively and professionally. This policy applies to all team members, whether on our premises, working from home, or representing our business elsewhere, and when using company equipment. 

Wilderness is committed to operating ethically and ensuring full compliance with all laws and company policies. Our Senior Leadership Team (SLT) provides governance, monitors compliance, investigates misconduct, and takes corrective actions. The SLT also acts as the oversight committee, evaluating and resolving compliance concerns with the assistance of the Board of Directors. The Board of Directors provides guidance, and team leaders oversee their areas. We conduct regular internal audits, engage external auditors as needed, and perform risk assessments to proactively identify and address compliance or ethical concerns.

Definitions

Diversity

Refers to the presence of differences. This includes differences in race, ethnicity, gender, age, religion, disability, sexual orientation, socioeconomic status, education, marital status, language, and physical appearance. It also involves different perspectives, work experiences, lifestyles, and cultures.

Equity

Ensures fair treatment, equality of opportunity, and fairness in access to information and resources for all. It is not about treating everyone the same way, but rather, adjusting supports based on individual needs to achieve equal outcomes.

Inclusion

It is about creating environments in which any individual or group can be and feel welcomed, respected, supported, and valued to participate fully.

Whistleblowing

Reporting suspected or actual wrongdoing, such as illegal acts, regulatory violations, or safety risks.

Compliance with this conduct policy is mandatory; failure to do so may lead to formal disciplinary action.

This policy, in conjunction with other company protocols, supersedes all previous company policies and protocols.


Policy

  1. Discrimination, harassment, and/or bullying
    1. We have zero tolerance for any form of discrimination or harassment that negatively affects our workplace. This includes unlawful acts based on gender, gender identity, race, age, disability, or any other protected status.

      This covers, but isn't limited to:

      1. Verbal: Derogatory comments, unwanted sexual advances.

      2. Visual: Offensive posters, photos, drawings, or gestures.

      3. Physical: Assault or unwanted touching.

      4. Online: Cyberbullying.

      5. Retaliation: Punishing a team member for reporting harassment.

    2. Team members who witness or experience harassment, intimidation, or bullying must report it immediately to their leader or via the compliance helpdesk. All complaints are kept confidential, investigated promptly, and the company will take action to prevent it from happening again.

  2. Drug & alcohol use

    1. The use, making, sale, purchase, transfer, distribution, consumption, or possession of drugs or alcohol on company property or in a company vehicle is prohibited. An exception applies to alcohol use in a company vehicle when a team member is covered by a Wilderness Motorhomes rental agreement.

    2. The CEO may, at their sole discretion, authorise alcohol consumption on company property and at company events (e.g., team days, Christmas parties) for special occasions.

    3. Team members consuming alcohol at such events are responsible for their own behaviour, and irresponsible drinking may result in disciplinary action.

    4. All team members must notify their team leader if they:

      1. Suspect another team member is adversely affected by drugs and/or alcohol.

      2. Feel unfit to work due to the influence of drugs and/or alcohol.

      3. They are prescribed medication that may affect their ability to work.

    5. The company reserves the right to conduct searches for drugs or alcohol, including work vehicles, lockers, desks, and packages on company property or premises. Any drugs or alcohol found will be confiscated, and the associated team member will be subject to disciplinary action, up to and including termination.

    6. All team members are expected to report fit for duty for scheduled work and perform assigned duties safely without limitations due to the use or after-effects of alcohol, illicit drugs, non-prescription drugs, prescribed medications, or any other substance.

    7. The company may require a team member to complete a drug and alcohol test as per their employment agreement if their role is designated safety-sensitive. Testing may also be required if a team member shows signs of being affected by drugs or alcohol, has been involved in a workplace accident or near-miss, is unable to perform normal work safely, or shows unreliability (e.g., absence, routine lateness). This will occur after discussion with the team member, providing an opportunity for comment.

    8. Drug and alcohol testing may occur during:

      1. Pre-employment medicals for safety-sensitive roles (employment offers may be conditional on a test).

      2. Random testing for team members in safety-sensitive roles. Oral fluid (saliva) testing may be the preferred method for immediate results; a non-negative result will require a urine test for further analysis.

      3. Post-incident testing if a team member is involved in:

        • An incident with death or serious harm.

        • An incident requiring medical professional treatment.

        • An incident or near-miss with significant potential for serious harm.

        • An incident involving damage to a vehicle, property, plant, or equipment.

      4. Reasonable cause where a team member's behaviour suggests drugs or alcohol may be impacting their ability to work effectively and safely.

    9. Rehabilitation for drug and alcohol issues in safety-sensitive roles is at the company's discretion. Wilderness may choose not to refer a team member to such a program and instead treat the matter as serious misconduct. Return to work decisions will be based on the role's nature. If a normal role is safety-sensitive, alternative employment may be considered. If no alternative is available, the team member cannot return to any work until a subsequent drug and/or alcohol test shows results below the "cut-off" level.

  3. Whistleblowing

    1. Wilderness strictly prohibits retaliation against anyone who reports concerns in good faith. Any form of retaliation, including dismissal, harassment, or discrimination, will result in disciplinary action.

    2. While we encourage reporting genuine concerns, we take deliberate false reporting very seriously. Any team member found to have intentionally made a false report will face disciplinary action.

  4. Corruption

    1. We have zero tolerance for corruption. Team members, contractors, and associated individuals are strictly prohibited from offering, giving, soliciting, or receiving any form of bribe or kickback. This includes attempts to improperly influence or be influenced by decisions.

    2. Gifts & hospitality: Do not accept or offer gifts or hospitality that could be seen as a bribe or influence business. Any gift or hospitality must be of nominal value and avoid impropriety. Report offers or receipts over NZ$100 via the compliance helpdesk.

    3. Contract payments: Do not offer, solicit, or accept any part of contract payments or financial incentives not explicitly detailed in the contract. All financial transactions and contract terms must be transparent and documented.

    4. Reporting: Promptly report any suspected or actual bribery, kickbacks, or corruption via the compliance helpdesk. The company will pursue all available legal remedies against those involved.

  5. Conflict of Interest

    1. Team members must avoid any situation where personal interests conflict or appear to conflict with company duties or judgment. This includes financial interests, family relationships, or any other relationship that could affect objectivity.

    2. Disclosure: Any potential or actual conflict of interest must be disclosed immediately. Retaliation for good-faith reporting is strictly prohibited.

    3. Financial & business interests: Do not have financial interests in or engage with competitors, suppliers, or clients in a way that compromises impartial decisions. Disclose any such ownership or interest immediately.

    4. Family & personal relationships: Team members should not supervise, be supervised by, or influence employment conditions for family members or close personal relationships. Disclose such relationships to ensure conflicts are prevented.

    5. Outside activities: Obtain Senior Leadership Team approval before outside employment, consulting, or business activities. These must not interfere with your company duties or create a conflict.

    6. Confidential information: Do not use confidential company information for personal gain or to benefit others. This is a prohibited conflict of interest.

    7. Addressing conflicts: Actions may include removing the individual from decision-making, reassigning duties, or requiring divestment of conflicting financial interests. Board members may be recused from relevant discussions and votes.

  6. Child labour and forced labour

    1. The company strictly prohibits child labour and any form of forced or compulsory labour in our operations or supply chains.

  7. Serious misconduct

    1. Serious misconduct is behaviour that can lead to immediate disciplinary action, including the termination of your employment. It includes, but isn't limited to:

      1. Discrimination, harassment, and/or bullying: as outlined above.

      2. Drug & alcohol use: as outlined above.

      3. Retaliation against whistleblowing or deliberate false reporting: as outlined above.

      4. Corruption: as outlined above.

      5. Conflicts of interest: as outlined above.

      6. Child labour or forced compulsory labour: as outlined above.

      7. Dishonesty: falsifying company records, theft, or misrepresenting information.

      8. Property misuse/damage: unauthorised possession, deliberate damage, or careless handling of company or personal property (belonging to employees or customers).

      9. Unauthorised use: improper or unsafe use of company vehicles, equipment, resources, time, materials, or facilities.

      10. Security breaches: failing to secure company premises, property, vehicles, or systems.

      11. Workplace harms: discrimination, harassment, or bullying (as detailed in section 3 of this policy).

      12. Interfering with testing: any attempt to falsify or interfere with the drug and alcohol testing process or its results.

      13. Disruptive behaviour: actions that disrupt the workplace or prevent others from doing their jobs.

      14. Threats & weapons: threatening behaviour or bringing weapons to work.

      15. Physical altercations: excessive rough play, fighting, or provoking a fight during work hours or on company property.

      16. Fraud & breach of trust: committing fraud or breaking trust in any situation.

      17. Criminal conduct: engaging in criminal acts, whether or not they're related to your job.

      18. Information misuse: sharing confidential company information or posting anything online that harms the company's reputation (defamatory, derogatory, inflammatory content).

      19. Online risks: any online behaviour that puts the company, its systems, property, or people at risk. This includes opening suspicious emails, viewing adult content on work devices, downloading unapproved apps, or using social media for personal reasons during work hours.

      20. Refusing work/sleeping: refusing to work or sleeping when assigned to a job.

      21. Unauthorised absence: failing to get permission to leave or being absent from work for any reason during your employment.

      22. Poor punctuality/attendance: consistent poor punctuality or attendance.

      23. Insubordination: including, but not limited to, failing or refusing to follow reasonable instructions.

      24. Unauthorised media contact: engaging with any form of media by communicating directly with any media outlet without authorisation from the CEO.

      25. Retaliation: retaliating against anyone who reports concerns in good faith, including dismissal, harassment, or discrimination.

      26. False reporting: deliberately making a false whistleblowing report.

      27. Repeated policy violations: consistently failing to follow company or departmental policies and protocols.

  8. Suspension and investigation

    1. For serious misconduct, the company may need to suspend a team member with full pay to complete an investigation. This will always be discussed with the team member beforehand.


Enforcement of this Policy

  1. Breach of company policies, protocols, or any clauses in the team members' employment agreement will be investigated as a potential act of misconduct unless the circumstances are such that the act amounts to serious misconduct.

  2. If the breach is found to be misconduct but is not deemed serious misconduct, a disciplinary process will be followed.    

  3. If the conduct amounts to serious misconduct, the team members' employment with the company may be terminated. In these situations, the team member will not be entitled to be paid out their notice period as outlined in their employment agreement.