Compliance with this Code


Compliance With This Code

CSL's Commitment:

CSL is committed to helping our employees and third parties to understand and abide by the principles and expectations contained within this Code.

We will:

  • Ensure that all employees have access to the Code by translating it into the main local languages where we operate and distributing to every member of staff – new and existing;

  • Ensure the Code is readily available to our third parties;

  • Implement mandatory training programs to help our employees understand the Code, its relevance to them and their individual obligations;

  • Monitor participation in mandatory training programs, take corrective action where required and review the effectiveness of Code training and education;

  • Ensure that our employees, contractors and other third parties can raise concerns regarding illegal conduct, breaches of CSL policies or malpractice in good faith, anonymously (if desired and permissible) and without fear of retaliation (except where such concerns are frivolous or vexatious); and

  • Seek and respond to feedback from our employees and other stakeholder groups about potential improvements to the Code.

Framework of Responsibility

CSL Board Approves the Code and sets review milestones.
Global Leadership Group Raises awareness, ensures accessibility, monitors compliance.
Corporate Responsibility Steering Committee Reviews and recommends improvements, facilitates stakeholder feedback.
CSL Compliance/ CSL Legal/ CSL HR Oversee training requirements and manage breaches/reports of noncompliance. Support supervisors/managers with enquiries and actively support reviews of the Code.
Supervisor/ Manager Review the Code and participate in training programs. Seek clarification when required and raise issues of non-compliance.
Employees Review the Code and participate in training programs. Seek clarification when required and raise issues of non-compliance.

Raising Concerns

CSL has prepared this Code with the intent of continuing a positive and transparent relationship with our employees, contractors and other third parties. However, we recognise that there may be times where employees, contractors and other third parties have a need to bring instances of inappropriate conduct to our attention. To enable this to happen, without reprisals, we will continue to maintain and promote the existence of procedures for our employees, contractors and other third parties to report situations where they have concerns, including the use of our "whistleblower" process and other management systems.



Q. I have been assisting my supervisor/ manager to conduct a tender for CSL for a large supply contract. I am concerned that the way the tender specifications are written and the process we are following favours one supplier, who is also an old friend of my supervisor/manager, over others. How do I seek advice on whether the tendering process we are undertaking is consistent with the Code and CSL's procurement policies, and what should I do in the case of suspect noncompliance?

A. CSL encourages employees to speak up about suspected breaches of the Code and ethical issues and provides mechanisms for doing this while having regard to the privacy and reputations of all involved. You should direct your questions about whether the tender process is consistent with the Code to a senior manager or to CSL Compliance or CSL Legal in the first instance. If you are not comfortable with speaking directly to a senior manager or CSL Compliance or CSL Legal, CSL has a "whistleblower" process to report concerns. Please refer to CSL's intranet for further details.