Code of conduct



1          INTRODUCTION                                                                                                

Loloata Island Resort Ltd recognize that the manner in which the Company and its employee, contractors, suppliers and agents conduct themselves both professionally and personally.

We are committed to ensuring that the Code of Conduct is utilized and is developed in a consistent format, to agreed protocols and maintains its currency over the life of the document.

2          PURPOSE AND SCOPE                                                                                        

Loloata Island Resort Ltd promotes a workplace that is friendly, harmonious, and safe and recognises the local communities in which we work.

To ensure our success in this endeavour, it is incumbent on the Company and its managers to set conduct expectations and ensure that persons performing work for or acting on behalf of the Loloata Island Resort Ltd abide by this Code of Conduct when dealing with clients, colleagues and the wider community.

The Code of Conduct also supports the Company in complying with all applicable national and international laws.

This Standard applies to all Loloata Island Resort Ltd employees, contractors, subcontractors, and consultants. For the purpose of this Standard they shall be collectively referred to as employees.

That Standard is applicable in all of our workplaces on Loloata Island, Tahira mainland as well as Company supplied accommodation.


3          LEGAL AND OTHER  OBLIGATIONS                                                                      

The legal and other obligations applicable to this code include but are not limited to:

Employment Act 1978
Employment Regulation 1980
Employment of Non-Citizens Act 2007
Employment of Non-Citizens Regulation 2008
Industrial Relations Act 1962
Industrial Relations Regulation 1972
Companies Act 1997
Companies Regulation 1998
Companies Rules
Discriminatory Practices Act 1963
Anti-Money Laundering and Counter Terrorist Financing Act 2015
Criminal Code (Sexual Offences and Crimes Against Children) Act
Lukautim Pikinini Act 2015
Whistleblower Act 2020


4          DEFINITIONS                                                                                                    

Employee         Any person employed on Loloata Island Resort Ltd site or premises either directly or indirectly.

Contractor        A person or organisation (including Contractor personnel and their subcontractor personnel) engaged to deliver services for Loloata Island Resort Ltd.

Consultant        The provider of professional services or expert advice in a particular field to Loloata Island Resort Ltd.

Subcontractor  Any person, business or supplier engaged by Loloata Island Resort Ltd or supplier to perform all or any portion of the services or related activities on behalf of Loloata Island Resort Ltd or supplier.



5.1      General Manager

Is responsible for:

The development and authorisation of this Standard.

5.2      Business Unit Managers

Are responsible and accountable for:

Development and review of this Standard and related documents
Addressing significant breaches of the code
Reporting of overall analysis of breaches of the code to Executive Team

5.3      Human Resource Manager

Is responsible and accountable for:

Ensuring that employees are inducted into the requirements of the Code of Conduct and understand their obligations to comply with the code
Management and reporting of breaches of the code
Monitoring and evaluating the operation of this code

The development of this Standard and related documents
Review and maintenance of this Standard and related documents
Compliance of this Standard within Loloata Island Resort Ltd
The provision and distribution of this Standard to all persons with a legitimate right to know
Management and reporting of breaches of the code
Monitoring and evaluating the operation of this code

5.4      Supervisors or Team Leaders

Are responsible for:

Monitoring and evaluating the operation of this code
Management and reporting of breaches of the code

5.5      Employees

Are responsible for:

Complying with the Code of Conduct, applicable laws, regulations, as well as Loloata Island Resort Ltd policies and system requirements


6          DESCRIPTION                                                                                                   

6.1     Vision

With our unique history and location, Loloata Island Resort is devoted to creating enduring relationships with our local and international guests by providing a highly personalized service and gracious hospitality in an informally elegant private, tropical island atmosphere.

6.2     Mission

To create unique, personal experiences that our guests will treasure for a lifetime; to be the destination of choice for our discerning guests, members, associates, communities and investors. Pursuing this mission is a dedicated team of talented individuals. Knowledge and passion for exceptional, personalized service are the foundation upon which our experience is built

6.3     Values

Excellence: We perform at extraordinary levels. We are professional in our appearance, language, and behaviour

Tradition: We embrace and reflect the heritage and traditions of our location.

Service: We consistently anticipate and are responsive to, the expressed and unexpressed wishes and needs of our guests.

Empowered: We exercise good judgment and act to create unique, memorable and personalized experiences for our guests. We own and resolve guests’ problems brought to our attention.

Innovation: We continuously seek opportunities to apply creatively to improve our service and product

Teamwork: We create an environment of lateral service so that the needs of our guests and each other are met.

Growth: We value every individual’s contribution and personal growth within the company

Integrity: We treat everyone with dignity and respect at all times. We do what we say we will do and are honest and fair.

Community: We will take an active role in service to our community

Success: We are committed to the collective success of our resort and in the future development of Port Moresby and Papua New Guinea.


6.4     Professional Conduct

All employees are expected to act consistently with the fundamental Loloata Island Resort Ltd values, ethical behaviour, respect for others, accountability and transparency in business conduct.

Employees are expected to:

Ensure all business is conducted in accordance with the law and high ethical standards, including equal opportunity, anti-discrimination laws, gender equity and social inclusion and gender-based violence.
Perform their duties in a manner that minimises environmental impacts and maximises workplace safety.
Respect confidentiality and not misuse Loloata Island Resort Ltd information, assets or facilities.
Ensure their actions do not bring the Company into disrepute.
Avoid real or perceived conflicts of interest.
Denounce behaviour that might be perceived as bullying or intimidatory.
Exercise fairness, courtesy, respect, consideration and sensitivity in all dealings.
Act with honesty, integrity, decency and responsibility at all times.
Employees should behave and present themselves in a professional and positive manner that supports Loloata Island Resort Ltd’s vision and values at all times when an employee is representing Loloata Island Resort Ltd.
Not engage in any act of violence and in particular gender-based violence within or external to the workplace.


6.5     Business Relations

Loloata Island Resort Ltd will conduct its business relations as outlined below:

6.5.1       Confidentiality

All employees are required to protect proprietary, commercial and other information that is confidential to Loloata Island Resort Ltd.

The obligation of confidentiality shall continue after an individual’s employment with Loloata Island Resort Ltd ends.

Information that is not publicly available concerning the activities, results or plans of the Company must only be used for authorised purposes.

6.5.2       Conflicts of Interest

Employees of the Company are expected to act at all times by exercising sound judgment unclouded by personal interests or divided loyalties.

Employees must avoid the appearance of, as well as actual, conflicts of interest in both their performance of duties and in their outside activities.

Where conflicts of interest either perceived or real exist, the issue should be raised with the employee’s direct supervisor, who will ensure it is raised and clarified with Senior Management.

6.5.3       Entertainment, Gifts and Gratuities

Employees are to exercise care when giving or receiving business related gifts.

Entertainment of clients and suppliers provided (or received) should not extend beyond a level reasonably required to maintain a professional business relationship. The following principles should apply:

The hosting of Company sponsored functions or provision of gratuities is within the delegation and authority levels.
When considering options for expenditure employees will assess the value to the business e.g. the provision of coffee or a light lunch, over the provision of dinner.
Where alcohol is provided at the function, it is hosted in a socially responsible manner, which will not bring the Company into disrepute.
Expense records are maintained and allocated to entertainment cost code in the chart of accounts.

The employee must consider the monetary value of the gift and legal requirements when determining whether a gift should be retained, returned or shared.

Where doubt exists on what is reasonable, the issue should be raised with the employee’s direct supervisor, who will ensure it is raised and clarified with Senior Management.

6.5.4       Bribes and Kickbacks

Employees of the Loloata Island Resort Ltd must not offer or accept cash or any other incentive, inducement or reward in any form.

In particular payments to influence a business decision in the Company’s favour.

Violation of this is considered serious and will subject an employee to disciplinary action as well as potential criminal prosecution.

Employees should take all practical steps to ensure that agents, contractors or business partners do not engage in conduct on Loloata Island Resort Ltd’s behalf that would contravene this Standard.

Any attempted or alleged bribery must be raised with the employee’s direct supervisor, who will ensure it is raised with Senior Management.

Senior Management will initiate an investigation into the allegations. Where appropriate, Senior Management will utilise an independent investigator.

Where allegations are made concerning government officials, Senior Management will report these allegations to the appropriate government department.

6.5.5       Donations, Grants and Requests

The Loloata Island Resort Ltd may supported worthy causes within PNG. This support may be through either direct financial support or the provision of goods, service and other company resources.

Where direct requests for financial support are requested, they must be:

In writing clearly stating the nature of the request and amount.
On  official letter head.
Authorised by the senior organisation officer.

All requests for financial donations/financial assistance must be forwarded to the General Manager.

All requests must be authorised by the General Manager.

The Loloata Island Resort Ltd additionally may provide some “in kind” support for small communities and/or landowner groups.

Requests of this nature should:

Be in writing.
Assessed as beneficial to the Company interests.
Within the responsible persons delegations and authorities level.
Kept as a documented record.

6.5.6        Loloata Island Resort Ltd Personnel Standing for Election

Loloata Island Resort Ltd respects the right of every PNG citizen to stand for public office.

Where Loloata Island Resort Ltd employee stands for public office, they must:

Inform the Company of their intention to stand.
Not utilise any Company resources of any kind (including Company time) without the direct approval in writing of the General Manager.


7          EMPLOYMENT PRACTICES                                                                                  
7.1  Human Resources

Loloata Island Resort Ltd has implemented a wide range of human resources policies, procedures, standards, and guidelines.

The key points of the policies, procedures, standards and guidelines, as well as any applicable laws will be included in the Company induction or handbook.

It is the responsibility of all employees to understand and comply with all policies, procedures, standards and guidelines at all times.

To understand and comply with these documents can all be obtained from the employees’ direct supervisor or the Human Resources Department.

Where changes to policies, procedures, standards and guidelines are implemented, the Human Resources department will ensure they are fully communicated to all parties with a legitimate right to know.

7.1.1       Equal Employment Opportunities and Anti-Discrimination

Loloata Island Resort Ltd has a commitment to ensuring all employees or potential employees are given equal opportunities and are not subject to discriminatory practices, when applying for vacant positions or promotions. This commitment is based on the following principles:

No person is unlawfully excluded from consideration for employment because of race, colour, religious creed, national origin, ancestry, sex, age, veteran status, marital status or physical challenges.
Management and supervisory levels have the responsibility to further implement this policy and ensure conformance by subordinates.
Any employee who engages in discrimination can be subject to disciplinary action
Any supervisory or managerial employee who knows of such behaviour and fails to take immediate and appropriate corrective action could also be subject to disciplinary action.
Any individual who is the target of discrimination is encouraged to discuss the matter with the Business Unit Manager.
Any individual who feels such a discussion would be or has been futile, unsatisfactory or counterproductive should contact the Human Resources department.
Furthermore, we will not tolerate any form of discrimination or harassment of our employees by co-workers, supervisors, customers, or vendors. This commitment extends to our policies on recruiting, advertising, hiring, placement, promotion, training, transfer, wages, benefits, termination and all other privileges, terms and conditions of employment.
The Loloata Island Resort Ltd will actively identify work opportunities for gender equity and social inclusion target groups.

7.1.2       Intellectual Property

Loloata Island Resort Ltd has exclusive rights to all improvements, discoveries, ideas and inventions whatsoever, including all documents, data, records and other paper writings, made or conceived, whether alone or with others, in the course of or arising out of your employment by the Company, whether patentable or otherwise registrable or not, will be the sole and exclusive property of the Company.

7.1.3       Entertainment and Gifts

Loloata Island Resort Ltd employees receiving gifts and tips must ensure to declare all gifts and tips to their managers.

7.1.4       The Zero Tolerance Policy / Gross Misconduct

Loloata Island Resort Ltd through the Company’s Zero Tolerance Policy ensures that any employees involved in gross misconduct will lead to termination or suspension with or without notice with immediate effect.

7.1.5       Criminal Offence

Loloata Island Resort Ltd employees’ must ensure to notify the Company immediately on being charged with any summary or indictable offence by:

Making full disclosure to the Company regarding relevant matters prior to commencing employment including disclosing any criminal convictions received in the preceding ten years.
The Employee consents to the Company obtaining any Police, Credit, Company, or other reference checks as it deems necessary during employment and will sign any authority required by the Company to obtain such background checks

7.2         Responsibility to the Community

The Loloata Island Resort Ltd recognises we have a “Duty of Care” to act responsibly to minimise the impact of our operations on the communities in which we operate.

As a good corporate citizen, all employees, contractors and consultants must and are expected to maintain, open, cordial and professional relations with these communities.

7.2.1       Health, Safety and Environment

The Loloata Island Resort Ltd is committed to ensuring that the communities in which we operate are not exposed to unacceptable risk arising from our operations.

Employees will ensure that when interacting with our community’s appropriate strategies will be implemented to reduce the risk of accident, injury or impact on the environment.

As a member of the Loloata Island Resort Ltd team it is important that employees act and promote these principles in the workplace and raise any concerns in the appropriate forum.

7.2.2       Addressing Community Concerns

Where community members raise concerns over health and safety or environmental issues the responsible managers will ensure:

All concerns are fully documented
Remedial action to address the issue is developed and implemented


7.2.3       Requests for Compensation

Where potentially impacted communities request or demand compensation arising from alleged impact on health and safety or the environment. These requests should be forwarded to senior management for assessment.

At no time are employees without the appropriated authorisation allowed to admit to an alleged compensable act or to make promises with regard to compensation.

8          INTERPERSONAL RELATIONSHIPS                                                                       

Loloata Island Resort Ltd recognises that many personal relationships occur when people meet within the working environment.

We additionally recognise that many of our employee’s children and relations work within the business.

We do however expect that standards of interpersonal behaviour must be maintained at all times. This includes but is not limited:

Acts of violence and in particular gender based violence (GBV) WILL NOT BE TOLERATED even when occurring outside of our operations.
Inappropriate sexual relations or conduct.
Utilising personal relationships to unfairly promote or provide unmerited opportunities or benefits.
Gossip based on unfounded allegation and/ or innuendo

9          DISCIPLINARY ACTION                                                                                      

Employees who breach this Code of Conduct can be subject to disciplinary action. This includes:

Termination for Cause
Suspension without pay
Letters of Warning
Verbal cautions

10.1      Termination for Cause

The basic principles will apply when considering termination of an employee. Termination must be:

Lawful: meaning it must satisfy the requirements of the PNG Employment Act.
Fair: meaning whether or not the principles of natural justice have been satisfied by the employer.
Rules & Policies must be posted on all notice boards in an understandable language and form not giving room for the excuse of “not knowing the rules”.

Examples of Termination for Cause Events:

Breach of Law - Theft of Company property, embezzlement, assault.
Breach of Code of Conduct – Bringing the Company into disrepute, dishonest dealings, bribery.
Breach of Policies - Drunk at work or coming to work drunk, use of narcotic drugs at work or coming to work after the use of narcotic drugs, consistently chewing betel nut at work or chewing betel nut and coming to work, misuse of Company property, bullying and harassment.

10.2      Suspension

Suspension can be used as a disciplinary action depending on the seriousness of the offence. It must not be more than once and 2 weeks or less.

Suspension due to an offence will require a formal documented investigation as soon as practicable after the event. It must take less than a week and a formal Letter of Suspension must be issued to the employee.

Investigation documents and Letters of Suspension must be signed by the responsible manager and the employee and recorded in the employees file.

10.3      Letters of Warning

Warnings can be given as first, second and final warnings, depending on the seriousness of the event.

Warnings can also be issued as First and final, depending on the seriousness of the event.

Warning letters must be signed by the employee and the responsible manager issuing the warning. Letters of Warning recorded in the employees file.

Where the employee refuses to sign, it should be noted as “refused to sign on the notice”.

10.4      Verbal Cautions

Verbal cautions can be used as a tool to improve employees’ performance prior to a Termination for Cause, suspension of Letter of Warning.

Where verbal cautions are utilised, the responsible person must maintain a diary note as evidence the discussion took place. This should be initialed by the employee.

10     REVIEW                                                                                                            

This document will be reviewed and modified where significant changes to statutory obligations or Loloata Island Resort Ltd policies, standards and procedures occur.