Code of ethics
& conduct policy

1. Introduction

Iress Limited, along with all companies within its group (together “Iress”), is committed to:

• complying with its legal obligations and also to acting ethically and responsibly;
• conducting its business in a way that is open and accountable to shareholders and the wider marketplace; and
• creating a safe and non-discriminatory workplace.

2. Applicability

This Code of Ethics and Conduct (“Code”) applies to all staff globally: directors, senior executives and employees alike.

3. Purpose of the Code

The purpose of this Code is to ensure that:

• high standards of corporate and individual behaviour are observed by all Iress staff;
• staff are aware of their responsibilities to Iress under their contract of employment / engagement; and
• all persons dealing with Iress, whether it be staff, shareholders, suppliers, customers or competitors, can be guided by the stated values and policies of Iress.

4. Obligation to Comply with the Code

Staff will adhere to this Code both in letter and in spirit. Adherence to this Code is a term of employment with Iress. Violation of this Code by any employee, or unethical behaviour which may affect the reputation of Iress, may be subject to disciplinary action, including termination of employment.

5. Primary obligations of the Code

Iress expects that all staff will:

• act in the best interests of the group;
• act honestly and with high standards of integrity and fairness;
• comply fully with the content and spirit of all laws and regulations which govern Iress and its operations;
• not knowingly participate in any illegal or unethical activity;
• not enter into any arrangement or participate in any activity that would conflict with Iress’ best interests or that would be likely to negatively affect Iress' reputation;
• not take advantage of the property or information of Iress or its customers for personal gain or to cause detriment to Iress or its customers; and
• not take advantage of their position or the opportunities arising therefrom for personal gain.

Staff must actively promote compliance with this Code.

6. Iress’ responsibilities to shareholders and the broader financial community

It is Management’s task to achieve, and the Board’s role to oversee, the delivery of shareholder value through the sustainable and efficient operation of the company, sound reporting and risk management practices and compliance with the continuous disclosure regime. The mechanisms to achieve this include the risk management structures, the Audit & Risk Committee, and the Board’s oversight of strategic and business objectives.

7. Care and Diligence

Iress and its staff should exercise due care and diligence in the performance of their duties and responsibilities. This should include such activities as ensuring the accuracy of all decision-making information, attending to detail in all aspects of work, being mindful of the sensitivities of others, protecting confidentiality, and being courteous, open and honest.

Iress aims to provide high quality software and services. Iress and its staff will endeavour to deliver its software and services to its customers in a timely and equitable manner, and prioritise customer satisfaction.

8. Confidentiality

Staff will not breach Iress’ confidentiality or make use of confidential information obtained from Iress for personal gain or in a manner which would be detrimental to Iress.

Confidential information of Iress will not be used except in ways which are authorised by Iress or legally mandated. The same applies to confidential information belonging to third parties which an employee may obtain in the course of their duties.

All staff acknowledge this need for confidentiality in their contracts of employment. Iress will respect the confidentiality of its staff.

Iress and its staff will comply with the content and spirit of all relevant laws and regulations concerning employment, such as anti-discrimination, equality of employment, health and safety. Iress will endeavour to ensure that all staff are treated fairly, equitably, and honestly.

9. Anti-bribery and slavery

Iress has a separate Anti-bribery and Corruption policy (available at its website) which describes the group's processes for preventing the offering or acceptance of bribes and other unethical payments or inducements. Iress is also committed to ensuring that there is no slavery or human trafficking in any part of its business, and Iress’ Global Modern Slavery Act Statement is available on its website.

10. Use of Company Assets

Iress assets must be acquired, maintained and used in an efficient manner and for legitimate business purposes.

11. Privacy

Iress’ Global Data Protection policy regulates the handling of any personal information that Iress collects. It contains detailed information on Iress’ functions and activities, and privacy issues and its data protection policy provisions. A copy of the policy is available on our website at https://www.iress.com/trust/corporate-governance/governance-documents/

12. Other Policies Regulating Employee Behaviour

Iress also requires staff to comply with policies relating to:

• acceptance of gifts and hospitality;
• employee relations / anti-harassment; and
• computer usage, desktop software, internet usage and email.

These policies are available to all staff on the Iress intranet site.

13. Monitoring Compliance with the Code

Iress’ legal and compliance teams monitor compliance with this Code. The Company Secretary will also periodically review this Code to ensure it is operating effectively and to propose any changes required to this Code.

14. Reporting Violations of the Code of Ethics or other Unethical Conduct

Staff are required to report violations of this Code using conflict escalation procedures. The procedures provide for a staged escalation and ultimately provide for the Managing Director and the Chair of the Audit & Risk Committee to become involved. The policy underlying the procedures is designed to ensure that staff are not disadvantaged in any way for reporting violations of this Code or other unethical conduct, that the matter is dealt with promptly and fairly and that the procedures are not used maliciously or mischievously.