Code of Business Ethics

• Information about our business shall be communicated clearly and accurately in a non-discriminatory manner and in accordance with local regulations. 
• We select and promote our people on the basis of their qualifications and merit, without discrimination or concern for race, religion, national origin, colour, sex, sexual orientation, gender identity or expression, age or disability. 
• We believe that a workplace should be safe and civilised and that employment must be freely chosen; we will not tolerate sexual harassment, discrimination or offensive behaviour of any kind, which includes the persistent demeaning of individuals through words or actions and the display or distribution of offensive material. 
• We will not tolerate the use, possession or distribution of illegal drugs, or our people reporting for work under the influence of drugs or alcohol. 
• We will treat all information relating to our business and our clients, as confidential. In particular, “insider trading” is expressly prohibited and confidential information must not be used for personal gain. 
• We are committed to protecting consumer, client and employee data in accordance with national laws and industry codes. 
• We will not undertake work which is intended or designed to mislead, including in relation to social, environmental and human rights issues. 
• We will not knowingly create work which contains statements, suggestions or images offensive to general public decency and will give appropriate consideration to the impact of our work on minority segments of the population, whether that minority be by race, religion, national origin, colour, sex, sexual orientation, gender identity or expression, age or disability. 
• We will consider the potential for clients or work to damage Launch’s reputation prior to taking them on. This includes reputational damage from association with clients that participate in activities that contribute to the abuse of human rights. 
• We will not give, offer or accept bribes, whether in cash or otherwise, to or from any third party, including but not restricted to government officials, clients and brokers or their representatives. We will collectively ensure that all staff understand this policy through training, communication and by example. 
• We will not offer any items of personal inducement to secure business. This is not intended to prohibit appropriate entertainment or the making of occasional gifts of minor value unless the client has a policy which restricts this. 
• We will not accept for our personal benefit goods or services of more than nominal value from suppliers, potential suppliers or other third parties. 
• We will not have any personal or family conflicts of interest within our businesses or with our suppliers or other third parties with whom we do business. 
• No corporate contributions of any kind, including the provision of services or materials for less than the market value, may be made to politicians, political parties or action committees, without the prior written approval of Jaye Cowle
• We will continue to strive to make a positive contribution to society and the environment by: maintaining high standards of marketing ethics; respecting human rights in our business, respecting the environment; supporting community organisations; supporting employee development; and managing significant corporate responsibility risks in our supply chain. 

Monitoring and reviewing the policy