The way we work Telstra Business Principles

The way we work - Telstra Business Principles is a key component of our corporate governance
framework. It sets out the practices, principles and standards of behaviour Telstra expects you to
adopt in carrying out your work. It contains the base level of information you need to know about any
area of Telstra's operations, and has been designed to drive business success.

Telstra Vision
To do for customers what no one else has done: create a world of 1 click, 1 touch, 1 button, 1 screen, 1
step solutions that are simple, easy and valued by individuals, businesses, enterprises and
government.

Telstra Values
The way we work Telstra Business Principles is underpinned by the Telstras Values, and provides
further guidance on the standards of personal and corporate behaviour required of you. The Telstra
Values are:
Service: I will be caring and responsive in the way I provide service to my customers and colleagues.
Respect for the Individual: I will treat all people with dignity and respect.
Integrity: I will be honest and ethical in all my dealings with others. Compliance with the law is my
minimum standard.
Commitment and Accountability: I will do as I say and accept accountability for my actions.
Trust: I will trust my colleagues and rely on them in order to achieve business success.
Leadership and Teamwork: I will strive to be a member of a champion team. Being competitive
demands my leadership, teamwork and collaboration.

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Overview of the Telstra Business Principles

Telstra Business Principles
1. Employment & Work Practices

1.1
1.2
1.3
1.4
1.5
1.6
1.7
1.8
1.9
1.10

Bribes, pay-offs and kick-backs

Confidential information
Conflicts of interest and outside activities
Drugs, alcohol and smoking
EEO and diversity
Employment
Gifts, prizes and hospitality
Health and safety
Internal resolution
Whistleblowing

2. Compliance and Legal Obligations

2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
2.9
2.10

Communication of information
Company records
Competition law
Compliance
Continuous disclosure
Insider trading
Intellectual property
Legal advice
Privacy
Regulatory

3. Sales and marketing

3.1
3.2
3.3
3.4

Customers
Marketing
Pricing
Product management

4. Infrastructure

4.1
4.2

Information Technology
Network service management

5. Finance & Administration

5.1
5.2
5.3

Finance & administration

Procurement
Treasury

6. Risk Management & Security

6.1
6.2
6.3
6.4

Business resilience
Protecting Telstras property
Risk management and internal controls
Security

7. Corporate Social Responsibility

7.1
7.2
7.3
7.4
7.5
7.6

Corporate social responsibility

Our people
Political activities
Shareholders
The community
The environment

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Definitions
Telstra Business Principles define the practices, principles and standards of behaviour Telstra expects
you to adopt in carrying out your work in accordance with Telstras Values. The principles are the
reference point from which to map proper business practices and conduct in a given situation. They
are complemented and supported by Company Policies, including the Code of Conduct, which expand
on expected behaviours.
Unless otherwise stated in the Application Section of each Policy Company Policies apply to:

all employees and contractors and to any other person who is notified that a Company Policy
applies to them.
subject to TBP and Company Policies Policy, each of Telstra's 100% owned Australian
subsidiaries and their employees and contractors.

Company Policies provide specific guidance to give effect to the Telstra Business Principles. They
define Telstras philosophy and rules about how we manage the company and, if there is any
inconsistency, prevail over Business Unit policy. The Company Secretary maintains a register of
approved Company Policies.
The Code of Conduct is the Company Policy that provides specific guidance on personal behaviour
and is supported by additional guidance material.
Business Unit policies (for example, Rules of the Road) are specific to each Business Unit. They are
subject to the Telstra Business Principles and Company Policies, and are developed to enable each
member of the CEO LT to ensure the appropriate management of their Business Unit. If there is any
inconsistency, Company Policy prevails over Business Unit policy.
Business Unit policies are available on the relevant BUs intranet site.

Ownership and Responsibilities

CEO Leadership Team (CEO LT)
Each Telstra Business Principle has a responsible CEO LT member who is accountable for:

regularly reviewing that principle (or principles) to ensure they meet the ongoing needs of
Telstra

developing, approving, reviewing, updating and administering Company Policies to give effect
to their Telstra Business Principles

implementing, providing training in, ensuring awareness of, and monitoring compliance with
their Telstra Business Principles and Company Policies.

The CEO LT members may appoint owners of their principles to assist them in discharging their
responsibilities.
General Managing Director, Finance & Administration
The GMD, Finance & Administration is responsible for the administration of the Telstra Business
Principles, and reports on that administration annually to the CEO and the Audit Committee.
Chief Executive Officer
CEO approval is required to remove or amend a Telstra Business Principle, for any specific variation to
or waiver of a Telstra Business Principle and to introduce a new Telstra Business Principle.

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Compliance structure
The way we work Telstra Business Principles is a key component of Telstras compliance program. The
GMD, Finance & Administration, together with the CEO LT members, administers the compliance
program. This responsibility includes:

assigning roles and responsibilities for the compliance program

overseeing compliance training and communications

overseeing compliance monitoring and auditing.

Who should follow the Telstra Business Principles?

Personal responsibility
Everyone who works on behalf of Telstra including employees, contractors and consultants is
responsible for acting in accordance with the Telstra Business Principles that apply to their work,
together with the Company Policies that support them.
As all these might change from time to time, you are responsible for knowing and complying with the
current versions and the laws, rules, regulations and industry codes of practice that govern your work.
You are required to act in accordance with the Telstra Values, the Telstra Business Principles and the
Company Policies, including the Code of Conduct, at all times.
The Telstra Business Principles represent a commitment to doing what is right. By working for Telstra
you are agreeing to uphold this commitment.
Telstra will encourage its controlled entities and other subsidiaries to adopt the Telstra Business
Principles or a similar set of Business Principles.
Managers responsibility
As a manager or supervisor you must take all reasonable steps to ensure that employees and
contractors under your supervision have access to, are aware of, and comply with, all relevant Telstra
Business Principles and Company Policies. Telstra expects you to foster a work environment that
encourages ethical behaviour and compliance. In the interests of this you are expected to maintain
open communication with your direct reports and be available to respond to questions or concerns.
As a manager or supervisor you are an example to other employees. In that role you are expected to
reinforce and demonstrate Telstra's commitment to the highest standards of quality and service, and
of business and professional behaviour.

Violation of the Telstra Business Principles

If you do not comply with a Telstra Business Principle or Company Policy, you may face disciplinary
action under Telstras Performance Improvement and Conduct Management (PICM) process. This
disciplinary action may involve a verbal or written warning or, in serious cases, termination of your
employment or engagement with Telstra.
If you break the law you may also be personally liable.

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Employment and Work Practices

Bribes, Pay-Offs and Kick-Backs
You must be honest in all your dealings with others. You must not make or accept bribes, pay-offs or
kick-backs.
Bribes, pay-offs and kick-backs occur when a person offers, makes, authorises, requests or accepts
payment of money or anything of value, either directly or indirectly, to:

influence the judgement or conduct of a customer, supplier or competitor

ensure a desired outcome from a customer, supplier or competitor
influence a decision of, or gain a benefit from, any government official, government agency,
political party or candidate for political office
gain an improper advantage.

Telstra conducts business in countries with many different laws, customs and business practices. You
must abide by the laws of host countries and must not engage in corrupt business practices.
Responsible CEO LT member: GMD Human Resources

Confidential Information
Confidential information is a valuable business asset and includes opinions, knowledge and facts
about Telstra, its employees, its business and its customers that have not been disclosed to the public.
It also includes information derived from the performance of your work with Telstra.
You should treat all Telstra information, including information contained in Telstra documents, files,
records, emails or on the intranet, as confidential unless it has been expressly approved for public
release.
If you have access to confidential information, you are responsible for ensuring that it is used only for
authorised purposes and is protected from theft, unauthorised disclosure or inappropriate use.
Confidential information must not be voluntarily disclosed to anyone except where:

you are acting in the best interests of Telstra; and

either:
o

the disclosure is in the course of the proper discharge of your duties; or

you have approval from a member of the Telstra Executive Team.

In some cases it will be appropriate to require the recipient of the information to enter into a
confidentiality agreement.
The disclosure of confidential information outside Telstra must only be made in accordance with
Company Policy.
Where you believe that you or Telstra is under a legal obligation to disclose confidential information,
you must seek immediate advice from your BU legal representative(s) before making any disclosure.
Your confidentiality obligations continue after your employment or contract with Telstra ends.
Responsible CEO LT member: Group General Counsel

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Conflicts of Interest and Outside Activities

We all have interests and activities outside our work with Telstra. However, when this results in
divided loyalties that is, when personal interests or activities influence, or could appear to influence,
someones ability to act in the best interests of Telstra a conflict of interest exists.
You must avoid actual and apparent conflicts of interest. Examples of situations where a conflict of
interest could arise are:

employment outside of Telstra

serving as a director of another business
holding interests or investments in, or having a personal or professional relationship with, a
competitor, customer or supplier with whom you deal
giving or receiving gifts, prizes and hospitality.

Outside employment or serving as a director of another business

You must not undertake outside employment or serve as a director of another business without first
obtaining written approval from your one up manager. If approval is obtained, you must ensure that:

there is no conflict between the outside employment or directorship and your duty to Telstra

commitments relating to the outside employment or directorship do not prevent you from
properly performing your functions with Telstra

the outside employment or directorship

activities are kept separate from Telstra work

does not involve the use of Telstra property, information, money, facilities or time, or
the services of co-workers

does not adversely affect your work or discredit you or Telstra

in the outside employment on directorship, you are not perceived as a nominee or

representative of Telstra.

Telstra will endorse and support your involvement in public or community service wherever possible.
Holding interests or investments in a competitor, customer or supplier
If your position in Telstra allows you to influence transactions between Telstra and another business,
it is essential that you fully disclose to your 1-up manager any interests, investments or relationships
you have with that other person or business.
Responsible CEO LT member: GMD Human Resources

Drugs, Alcohol and Smoking

Drugs and alcohol use can impair work performance, pose health and safety risks and adversely affect
efficiency and productivity.
You must attend work free from the influence of illegal drugs or alcohol and in a condition to perform
your duties. Do not use, possess or sell illegal drugs on Telstra premises, in Telstra vehicles, in
conjunction with Telstra business or at Telstra functions.
Smoking in Telstra premises and Telstra vehicles is prohibited.
Responsible CEO LT member: GMD Human Resources

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EEO and Diversity

Telstra embraces diversity and is an equal opportunity employer. Telstra aims to build an inclusive,
supportive and flexible work environment where individual differences are respected and harnessed.
Telstra recruits, develops, promotes and rewards based on merit. Merit relates to a persons ability
to perform the job and is independent of membership of any group. Employment decisions based on
attributes unrelated to the inherent requirements of the job or job performance (for example,
attributes such as sex, disability, family responsibilities) may constitute unlawful discrimination and
are prohibited.
Telstra does not tolerate verbal, physical or visual harassment or any other behaviour where the
purpose or effect is to create an offensive, hostile or intimidating work environment or which disrupts
another persons ability to work. This includes:

sexual, sexist, racial or ethnic comments

offensive jokes or gestures

sexually suggestive pictures, email or voice messages

sexual advances or comments

bullying.

In the course of your work you must conduct yourself in accordance with all applicable equal
employment opportunity laws and Company Policy.
Responsible CEO LT member: GMD Human Resources

Employment
Telstra offers a number of employment instruments to meet the divergent needs of its employees and
the business.
Telstra places great value on the relationship between you and your 1-up manager. It is expected that
you will be open and honest in your dealings with your 1-up manager and that you will approach
him/her as a first resort with any of your questions or concerns.
Telstra is committed to ensuring that you develop skills and career aspirations while maximising both
your career possibilities and Telstras continued growth.
To ensure you have the capability to meet current and future business needs, you will receive the
necessary development and training and participate in performance reviews.
Telstra will encourage you and support you in the course of your duties. If you are acting in good
faith, in compliance with the law and with Telstra Business Principles and Company Policies, Telstra
will normally grant you an indemnity from any civil liability you may incur.
(This TBP only applies to Telstra employees)
Responsible CEO LT member: GMD Human Resources

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Gifts, Prizes and Hospitality

Giving and receiving gifts, prizes or hospitality can be an acceptable business practice. However, it can
be difficult to be objective about the person providing them.
You must ensure that neither you nor Telstra are in any way compromised by a gift, prize or
hospitality. Equally, you must ensure there is no suggestion of an improper connection between the
gift, prize or hospitality and a business opportunity or transaction.
Gifts and prizes means anything of value including direct payment (eg. money) and payments in
kind (eg. discounts, loans, favourable terms on any product or service, shares or other securities,
vouchers and gift certificates.) Hospitality includes meals, travel and invitations to sporting or
entertainment events.
Company Policy, legal requirements, the monetary value of the gift and local custom should all be
considered when deciding whether you should accept the gift, forward it to the Office of the Company
Secretary, or return it.
As a general rule, do not give or accept a gift, prize or hospitality in circumstances that could be
reasonably regarded as:

compromising your judgement

unduly influencing the recipient or creating a business obligation on their part

giving rise to a conflict of interest

damaging to relationships with others

indicating favouritism or prejudice towards a particular person or group

conflicting with any of the Telstra Business Principles.

Responsible CEO LT member: GMD Human Resources

Health and Safety

Telstra is committed to providing a healthy and safe work environment, and conducts its business in
accordance with all applicable health and safety laws, regulations and requirements.
You must understand and follow the health and safety requirements of your job, applicable health
and safety laws, and Company Policy. You must always work in a way that assures your own safety
and the safety of others around you. You must be alert to health and safety risks as you go about
your work and strive to prevent accidents, injuries and occupational illnesses.
Responsible CEO LT member: GMD Human Resources

Internal resolution
As a Telstra employee, you have the right to be treated fairly and to understand the reasons for the
decisions and actions that impact you and your employment. Fairness goes to the heart of how you
conduct yourself and is something Telstra demands of all its employees.
Telstras Internal Resolution process aims to achieve the fair resolution of issues jointly between an
employee and the decision maker at the earliest possible opportunity. You must attempt to resolve
any concerns informally and directly with your 1-up manager prior to formally initiating the Internal
Resolution process.
(This TBP applies only Telstra employees).
Responsible CEO LT member: GMD Human Resources

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Whistleblowing
You are encouraged to take action if you are concerned about any unethical, illegal or improper
behaviour within Telstra. Such behaviour can occur at an individual level or may involve the actions of
several people or a business group.
Examples of unethical, illegal or improper behaviour might be:

taking bribes in return for business favours

the unauthorised distribution or sale of customers private details

theft

fraud

improper use of email, intranet or Internet services

price fixing or financial misreporting

other breaches of the TBPs or Company Policies

In the first instance, you should raise any concerns you might have with your 1-up manager, 2-up
manager or the person concerned. If you prefer not to do this, or if you wish to raise an issue
anonymously, you may disclose your concerns through the Whistleblowing service. The
Whistleblowing service is confidential and is part of a suite of services designed to address staff
concerns and complaints.
Responsible CEO LT member: GMD Finance & Administration

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Compliance and Legal Obligations

Communication of information
A consistent and coordinated approach to the release of company information, whether as employee
communications or externally to the public, government and regulatory agencies, or law
enforcement and national security agencies, assists Telstra to:

maximise opportunities for full and fair coverage of messages and achievements
minimise adverse publicity and the use of incorrect or misleading information
comply with all relevant laws and regulations.

All Telstra information prepared for specific release or with the potential for use in the public domain
for example, media announcements, position statements, articles, speeches, marketing material,
advertisements, online information, Telstra News and other cross-company staff news stories etc
must:

be timely, accurate and fairly represent Telstras position

comply with company objectives
be consistent with other Telstra communications
be commercially correct
be free from ambiguity
appropriately use trademarks and trade names
comply with Company Policies
comply with relevant laws and regulations
be specifically approved for release

You must not publish or release company information unless you are specifically authorised to do so.
Responsible CEO LT member: GMD Public Policy & Communications.

Company Records
Telstra has commercial, legal and management obligations to keep complete, reliable and accurate
records of its business operations and financial condition. It is essential that all Telstra records and
recorded information be managed consistently and efficiently and in accordance with Telstras legal
obligations.
When performing your job role, you must:

use good judgement and common sense when preparing or generating information/records
ensure that records are accurate, complete, honest, objective and timely
not knowingly create a false, misleading or unsupported entry in a record or an information
system
only approve records that are accurate and complete
not knowingly withhold relevant information
disclose records only as authorised by Company Policy or in response to legal processes
follow all laws, external accounting requirements, Company Policies and process for
identifying, retaining, storing and disposing of records.

Responsible CEO LT member: GMD Finance & Administration.

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10

Competition Law
The objective of the Trade Practices Act is to promote competition and fair dealing in business and to
protect the interests of consumers. In response to our legal compliance obligations, the Telstra Values
and the expectations of our customers and the community require we strive continuously to conduct
our activities in ways that are competitive, fair and honest.
A breach of the Trade Practices Act carries potentially serious consequences for you personally and for
Telstra, including criminal prosecution, substantial fines and unwanted negative publicity. This in
turn jeopardises our valuable reputation and the good will of the market.
Do not engage in behaviour, or allow or ignore behaviour by others, that violates the principles and
laws of fair competition.
Responsible CEO LT member: Group General Counsel

Compliance
Telstra is committed to conducting its business in accordance with its legal and regulatory obligations
including relevant codes of practice. Compliance is integral to Telstras commitment to its employees,
customers, shareholders and the community. It is also good business. Telstra expects you to know,
understand and comply with the laws that apply to you as an ordinary person, as a Telstra employee
(including privacy, equal employment opportunity, and occupational health and safety), to your
specific job and in the location in which you work. If you do business outside Australia you might also
be subject to the laws and regulations of different countries. Ignorance of the law does not excuse you
from these obligations. It is also important to be aware that no one can be directed to carry out an
unlawful act and no one can justify an unlawful act by claiming to be acting under the direction of a
manager.
Compliance must be integrated seamlessly into the way we all do business. The Telstra Business
Principles and Company Policies and Business Unit Policies provide the framework for you to meet
many of the relevant legal obligations.
Managers are required to adopt a rigorous approach to identifying compliance risks, designing and
implementing controls and enhancing the existing compliance culture.
To protect Telstra and yourself it is expected that at all times you will carry out your duties in good
faith and in accordance with legal and regulatory obligations, the TBPs and Company policies.
Responsible CEO LT member: GMD Finance & Administration

Continuous Disclosure
Telstra is listed on the Australian Stock Exchange (ASX) and is required to act in accordance with the
ASX Listing Rules and the Corporations Act. The Listing Rules govern a number of matters, including
the disclosure of information to the market and some aspects of a listed entitys conduct. Telstra must
also comply with the disclosure of information obligations of overseas stock exchanges on which our
debt and equity securities are listed.
Telstra is generally required to disclose to the ASX information that is considered material from a
market perspective. Information is considered material if it would influence an investor to buy or sell
securities.
If Telstra contravenes its continuous disclosure obligations, it (and its officers, employees and
advisors) may face civil or criminal liability. This may also lead to the suspension of trading in or
delisting of Telstras shares or unwanted negative publicity for Telstra.
Responsible CEO LT member: GMD Finance and Administration

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11

Insider Trading
It is illegal for you to deal in Telstra shares while in the possession of price-sensitive information not
generally available to the public. It is also illegal for you to pass the information on to someone else
who may use the information to deal in Telstra shares.
Price-sensitive information is information that, if publicly known, would be likely to have a material
effect on the price or value of the shares, or to influence investors in deciding whether to buy or sell
the shares.
You may possess price-sensitive information and/or be subject to specific additional requirements in
relation to your share transactions as a result of your position in the company. If you violate insider
trading laws it could result in your criminal prosecution.
Responsible CEO LT member: GMD Finance & Administration

Intellectual Property
Intellectual Property (IP) is a collection of intangible rights that allow the IP owner to do certain things
to the exclusion of others. IP includes copyright, designs, patents and trade marks.
Telstra recognises IP as a key contributor to the value of Telstra's products and services and as an
asset in its own right. Telstra encourages innovation. In particular, Telstra will:

identify, manage, protect and as appropriate, exploit its IP assets

respect the IP rights of others
defend IP claims against Telstra
comply with IP laws
monitor and where appropriate, engage in public debate on IP laws and policy.

Responsible CEO LT member: Group General Counsel

Legal advice
Telstra has an in-house legal group, Legal Services, which is solely responsible for sourcing and
providing legal services to each of the Business Units and to Telstra as a whole. If you are unclear of
the legal requirements applying to your work you should seek advice from your Business Unit legal
counsel.
Telstra's legal counsel have ethical and professional obligations, including giving independent legal
advice, that Telstra considers of paramount importance. Each legal counsel and all other Telstra staff
must not compromise the independence of the legal counsel or impede the fulfilment of their ethical
and professional responsibilities.
Responsible CEO LT member: Group General Counsel

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Privacy
Privacy matters at Telstra!
Telstra is committed to handling the personal information of customers in a way that ensures that its
customers can be confident that the privacy of their personal information is protected.
Everyone at Telstra is responsible for protecting the privacy of the personal information of its
customers. Telstra maintains a Privacy Compliance Program to ensure that everyone at Telstra knows
their responsibilities in handling personal information.
Every customer has access to Telstras Privacy Statement and Telstras Privacy Policy.
Responsible CEO LT member: GMD Finance and Administration

Regulatory
You must comply with the regulatory environment that applies wherever you work.
Telstras Regulatory Group manages Telstras involvement with industry regulators. This involvement
includes influencing the development of, and facilitating compliance with, industry and competition
policy, technical regulation and consumer protection.
Telstras products, services and networks and associated activities including marketing, sales, service
delivery and customer service must comply with relevant regulatory obligations, including selfregulatory industry codes. When developing or changing existing products, services, networks or
associated activities, regulatory issues and risks must be identified and managed.
Responsible CEO LT member: GMD Public Policy & Communications

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Sales and marketing

Customers
Customer satisfaction is fundamental to Telstras business success. Every job ultimately affects our
customers. At Telstra, everyones first priority must be our customers - both to exceed their
expectations and to make sure the experience in dealing with Telstra is professional and courteous.
Telstras aim is to give customers a powerful and seamless experience across all devices and all
platforms in a one click, one touch, one screen way - whether the customer is an individual consumer,
small business, large business or government agency.
To achieve this, we must all:

ensure Telstras customers receive fair and respectful treatment.

make every customers experience a valuable one where:
o
the interaction is simple and efficient
o
the information provided is correct and relevant
deliver innovative, customer-focused services which suit customers individual needs by
ensuring:
o
Telstras products, services and offers are clear and easy to understand
o
Telstras services add value to the customers personal life and/or business
supply all Telstra services in a timely manner that meets the customers expectations
make commitments to customers that Telstra can deliver and deliver to those commitments
provide access to telecommunications for every Australian and deliver excellent customer
service whilst complying with relevant laws and regulations

Responsible CEO LT member: Each CEO LT member is responsible for the Customer Business Principle within
their Business Unit.

Marketing
Telstras reputation for desirable, innovative and quality products and services, as well as for integrity
and honesty, is of critical importance. All Telstra marketing must be clear, effective and timely,
enhance its image and support its commercial objectives.
Marketing, advertising and sales activities must describe products and services fairly, honestly and
accurately, and must not create false or misleading impressions. All information seen by Telstras
customers must be factual and correct, comply with relevant Telstra Business Principles, Company
Policies and legal and regulatory requirements and reflect the Telstra brand strategy.
Responsible CEO LT member: GMD Strategic Marketing

Pricing
Prices must be developed to meet the needs of the market place, reflect the value proposition of the
product being sold, support Telstras business strategies to maximise its commercial position and
shareholder value and optimise product positioning. Proposals to establish or vary prices must
comply with Company Policies, pricing guidelines and legal and regulatory requirements.
Responsible CEO LT member: GMD Strategic Marketing

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Product Management
Telstra seeks to provide all customers with a high quality customer experience across all platforms
and devices.
Telstra Product Management is responsible for leveraging new and existing platforms and technology
to deliver innovative and profitable products which meet the needs of individual customers.
All Telstras product activities must be managed by Telstra Product Management.
Responsible CEO LT member: GMD Telstra Product Management

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Infrastructure
Information Technology
Information Technology is accountable for all technology activities necessary to support Telstra
internally. These activities must not be carried out elsewhere in Telstra without the prior written
consent of the Chief Information Officer and GMD Information Technology. Technology activities
include the setting and implementation of the strategic direction for internal technology, as well as
the planning, development, implementation, operation and support of all technology infrastructure,
systems and applications, incorporating the requirements of associated Telstra standards and
controls.
Responsible CEO LT member: Chief Information Officer and GMD, Information Technology

Network Service Management

Telstra Networks and Services is responsible for the design, activation, operation, maintenance and
evolution of Telstras network infrastructure and all associated interactions with Telstras customers.
This function must not be carried out elsewhere in Telstra without the prior written consent of the
GMD Telstra Networks and Services.
Responsible CEO LT member: GMD Telstra Networks and Services

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Finance and Administration

Finance & Administration
Telstra seeks to produce and maintain complete, reliable and accurate reports and records, be
forthright in measuring and reporting financial performance, and be proactive in identifying and
managing risk.
All Telstra finance operations are carried out by Finance & Administration. They may not be carried
out elsewhere in Telstra without the consent of the GMD Finance & Administration.
Finance operations include:
Policy and advice

provision of corporate financial advice

setting finance policy and standards

management and oversight of compliance with the Company Delegations and the Internal
Management Delegations

Planning and reporting

preparation of the corporate plan

development of forward financial targets and parameters

reporting and monitoring financial and operational information in evaluating business

performance

Accounting and financial management

preparation of all internal financial management and statutory reports

compliance with all accounting standards and pronouncements

managing accounting and taxation ledgers

overseeing the treatment of cash receipts, including cheques, funds transfers and currency
from initial receipt to reconciliation of bank accounts

performance of the payroll function

credit management

paying for goods and services

investing Telstras finite resources to support its business objectives

providing financial and taxation advice to the Business Units

providing the conduit to external markets on strategy and financial performance

Administration

storing, retrieving and disposing of records

Responsible CEO LT member: GMD Finance & Administration

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Procurement
Products and services must be acquired in a way that achieves the most advantageous terms for
Telstra, its shareholders and customers. All business units and employees must source products and
services only in accordance with Company Policy and associated processes and legal and regulatory
requirements.
Procurement is responsible for:

developing and enforcing a standardised approach to sourcing, purchasing, vendor

management, warehousing and distribution activities across Telstra

managing Telstras fleet

property portfolio management.

Procurement activities must not be carried out elsewhere in Telstra without the written consent of the
GMD Finance & Administration.
Responsible CEO LT member: GMD Finance & Administration.

Treasury
All treasury transactions for Telstra and its subsidiaries are carried out by Corporate Treasury. They
may not be carried out elsewhere in Telstra without the consent of the Corporate Treasurer.
Treasury transactions include:

conducting all types of funding, borrowing, lending and hedging activities, including bank
and corporate guarantees (both externally and internally)
managing foreign currency and interest rate exposure
managing the credit risks associated with all Treasury transactions
controlling the total daily inflow and outflow of funds
managing Telstras overall liquidity position
arranging and coordinating Telstras corporate banking relationships, including opening and
closing all bank accounts, to achieve the best outcome for Telstra
establishing and managing insurance arrangements

Responsible CEO LT member: GMD Finance & Administration

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Risk Management & Security

Business Resilience
Business Resilience focuses on building a companys readiness and capability to respond and recover
from severe disruptions, regardless of the cause or origin of the event.
Corporate Security & Investigations (CSI) drives activities to manage a Business Resilience program for
Telstra that integrates the principles of Business Continuity Management, Crisis Management,
Emergency Planning, Service Continuity, Risk Management, Critical Infrastructure Protection and
Recovery Planning under a single cohesive strategy.
The Business Resilience Team in CSI has the responsibility to manage three key focus areas, supported
by all areas of Telstra's business:

Business Continuity Management - this includes developing business continuity plans in

accordance with a Telstra Business Continuity Management methodology, and operational
resilience measures such as remediation, redundancy, back-up and fail-over initiatives.
Crisis Management this includes establishment and capability development of a corporate
Crisis Management Team to focus on pre-event prevention and preparedness, response during
and immediately following events, and post event restoration.
Critical Infrastructure Protection this includes activities aimed at effectively protecting
Telstras National Critical Infrastructure under the National Counter-Terrorism Plan and
working with other Infrastructure owners and operators on interdependencies so that there is
a cohesive approach to incidents that may impact other sectors .

Responsible CEO LT member: GMD Finance & Administration

Protecting Telstra's Property

Telstras assets must be appropriately protected and used for the benefit of the company in the
conduct of its business.
You share the responsibility of securing Telstras assets, especially when those assets are under your
control. You must make proper and efficient use of Telstras assets, including its networks, network
products, systems, applications and information and must follow policy and procedures to prevent
their loss, theft, unauthorised use or damage.
Company assets must not be removed without authorisation and must not be used for personal
benefit or improper or criminal purposes.
Responsible CEO LT member: GMD Finance and Administration

Risk Management and Internal Controls

Telstra is committed to the management of risk throughout its operations. Managers have primary
responsibility for risk management and the operation and enhancement of internal controls.
Managers must:

regularly review and update their significant business risks and their overall internal control
environment

implement remedial actions recommended as a result of RM&A reviews.

Risk Management & Assurance (RM&A) uses a risk based approach to prepare an annual Assurance
Plan of risk and control reviews. RM&As findings include an evaluation of the adequacy and effective
operation of the controls the Business Units have implemented to manage risk.

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RM&A also develops and promotes a common language and approach to be used by Business Units to
enable them to identify, manage and control their risks.
Responsible CEO LT member: GMD Finance & Administration

Security
Telstra takes the security of its people, property and information very seriously. Security in Telstra is
focused on providing a secure workplace for employees, contractors and other people on its premises,
the protection of sensitive business and customer information, the safeguarding of plant, equipment
and other assets, and the integrity of its networks, products, information technology systems and
applications. Telstra adopts a risk based and commercial approach to securing all aspects of its
business.
Corporate Security and Investigations drives activities and develops appropriate policies and
processes that focus on:

protection of Telstra's employees, assets and sensitive information

security of Telstra's critical infrastructure including liaising with government on national
security issues
internal investigations of fraud, criminal and corrupt conduct and other serious misconduct
liaison with law enforcement agencies
provision of Telstra data in response to lawful requests under legal and regulatory
frameworks
operational security support for Telstra special events, overseas business travel and response
to any significant security related incidents
management of security risks that have the potential to negatively impact on Telstra's
business

Security is the responsibility of all people in Telstra. This means that all employees, contractors and
other people who work for or on behalf of Telstra, must comply with Telstras requirements and
policies in relation to security.
Responsible CEO LT member: GMD Finance & Administration

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Corporate Social Responsibility

Corporate Social Responsibility
At Telstra, our commitment to corporate responsibility begins with a simple and straight-forward
commitment to principled decision-making, in all that we do.
From a principled perspective, our primary corporate responsibilities are to:

provide good jobs at good wages

serve the needs of our customers
increase shareholder value and protect shareholder interests
provide good stewardship of the environment - first and foremost by conservation (i.e., by
increasing efficiency in the way we use resources), reducing operating costs, and minimising
our environmental footprint
contribute resources - people, money, technology, products and services - to support the
communities in which we operate and the needs of the larger society
advance the national interest by strengthening the capacity of the nation's
telecommunications nerve centre, operated by Telstra, and providing the nation a foundation
for economic growth, productivity improvement, sustainable prosperity, and global
competitive advantage.

Responsible CEO LT member: GMD, Public Policy & Communications

Our People
Telstra is one of Australias largest employers. For Telstra to succeed, it is essential that we:

have a skilled workforce

have a robust succession management and planning process

have a safe work environment where diversity of thought and capability is encouraged

have fair processes

have programs in place to recognise and reward high performance and the efforts of our
people

provide opportunities for all to learn and develop

provide our people with the opportunity to express their views on Telstra and their job and
working environment through regular employee engagement surveys.

Responsible CEO LT member: GMD Human Resources

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Political Activities
Telstra communicates regularly with governments on a range of commercial, policy, regulatory and
other matters in the interests of its shareholders, customers and employees.
Telstras dealings with governments are conducted openly and honestly.
Employees authorised by Telstra to provide communications to governments must do so in
compliance with all relevant laws, regulations and Company Policies.
Telstra supports the right of all employees to hold political opinions and affiliations and to pursue
these in their own time as private citizens and with their own resources. However, employees are not
permitted to use company time, property or resources for personal political activities. You must not
use your position within Telstra or Telstras name to advance your political causes or to support a
political party, a member of a party or an independent politician either in Australia or overseas. You
should always make it clear that your views and actions are your own and not Telstras.
Telstra does not make financial contributions to political candidates or parties.
Responsible CEO LT member: GMD Public Policy & Communications

Shareholders
Telstras shareholder communications are founded on the principle that Telstra is owned by its
shareholders and must protect and advance their best interests.
Telstra is committed to:

open, clear, accurate and timely communications with our shareholders about matters
affecting the value of their investment in the company;

making appropriate use of technology and emerging new media tools to inform and engage
our shareholders; and

ensuring all communications are consistent with Telstras continuous disclosure and other
applicable legal obligations.

Telstra values a direct, two-way dialogue with shareholders and believes it is important not only to
provide relevant information as quickly and efficiently as possible, but also to listen, understand
shareholders perspectives and respond to their feedback.
Responsible CEO LT member: GMD Finance & Administration

The Community
Telstras community involvement and contributions are organised at a corporate, business unit and
local level. Telstra is active in the community in many ways including:

the Telstra Foundation - Telstras philanthropic entity supporting children and young people
Disaster Relief for customers and communities in times of natural and civil disaster
Community Business Partnerships where Telstras products, services, infrastructure and
peoples capabilities are used to address social needs especially in the areas of health and
education
Telstras Telstra Connected Seniors, a program supporting training for seniors in new
technologies
Telstras sponsorships, awards and grants
Telstras Access for Everyone program which helps people on low incomes to access
affordable products and services.

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Responsible CEO LT member: GMD Public Policy & Communications

The Environment
Telstra is committed to minimising any adverse impact on and injury to the environment and
preserving the beneficial qualities of the environment, while providing quality products and services.
Telstra therefore seeks to conduct its business in a way that is compatible with the environmental
needs of the communities in which we operate and in accordance with all applicable environmental
laws, regulations, codes of practice and Company Policies.
Telstra supports programs for waste management, control of greenhouse emissions, recycling
initiatives and improvements in the uses of resources. It also encourages vendors to actively pursue
environmental improvements.
Responsible CEO LT member: GMD Human Resources

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Seeking Assistance, Questions or Concerns

The way we work Telstra Business Principles will not address every situation you encounter during
the course of your work. In such circumstances, use your common sense and good judgement, review
the additional resources referred to in this document, and consult with your co-workers, managers or
supervisors, legal counsel or HR contacts.
If you have any questions or concerns about any of the TBPs or any doubt about whether your
actions, or those of a fellow employee or contractor, comply with a Telstra Business Principle,
Company Policy or Telstra Business Process, you should discuss this with your 1-up manager.
If you are unable to or do not wish to do this, you can alternatively contact any of the following:

your 2-up manager

the HR or legal representative for your Business Unit
the owner of the Telstra Business Principle
a member of Governance & Compliance
the Company Secretary.

If you are uncomfortable about approaching any of the contacts listed above, or wish to raise an issue
anonymously, you can contact Telstras Whistleblowing service.
The Whistleblowing service is operated by an independent external provider.
You will not be disciplined for reporting, in good faith, a possible breach of a Telstra Business Principle,
Company Policy, Telstra Business Process, law or regulation. Any Telstra employee who engages in
retribution against you will be subject to disciplinary action.
Useful contacts are listed below.
Key Contacts and Links
Employee Assistance Program:
Whistleblowers Service:

Office of the Company Secretary:

Governance & Compliance
Business Unit Compliance Managers
Health & Safety home page
Regulatory group
HR Connecting homepage

1300 361 123

Telstra C/- STOPline Pty Ltd
Locked Bag 8, Hawthorn, Vic 3122
Phone 1300 30 45 50
Email:Telstra@stopline.com.au
03 9634 6400

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