Overarching Principle —
Act with Integrity

Brighthouse acts with integrity towards our clients and everyone we are in contact with, throughout any project.

Brighthouse  conducts its business honestly and ethically wherever we operate. We strive to  constantly improve the quality of our services, products and operations and maintain our reputation for honesty, fairness, respect, responsibility, integrity, trust and sound business judgment.

No illegal or unethical conduct on the part of officers, directors, employees or affiliates is in the company’s best interest. Brighthouse will not compromise its principles for short-term advantage. The ethical performance of this company is the sum of the ethics of the people who work here. Thus, we will adhere to high standards of personal integrity.

Officers, directors, employees and our consultants will never permit their personal interests to conflict, or appear to conflict, with the interests of the company, its clients or affiliates.

Officers, directors, employees and our consultants are particularly careful to avoid representing Brighthouse in any transaction with others with whom there is any outside business affiliation or relationship.

Officers, directors, employees and our consultants avoid using their company contacts to advance their private business or personal interests at the expense of the company, its clients or affiliates.

 No bribes, kickbacks or other similar remuneration or consideration will ever be provided to any person or organisation in order to attract or influence business activity. Officers, directors and employees shall avoid gifts, gratuities, fees, bonuses or excessive entertainment, in order to attract or influence business activity.

Brighthouse personnel often come into contact with, or have possession of, proprietary, confidential or business-sensitive information and take appropriate steps to assure that such information is strictly safeguarded. This information – whether it is on behalf of our company or any of our clients or affiliates – sometimes includes strategic business plans, operating results, marketing strategies, customer lists, personnel records, upcoming acquisitions and divestitures, new investments, and manufacturing costs, processes and methods.

Proprietary, confidential and sensitive business information about companies, individuals and entities will be treated with sensitivity and discretion and only be disseminated on a need-to-know basis.

Misuse of material and inside information in connection with listed public company securities can expose an individual to civil liability and penalties.  Directors, officers, employees and our consultants in possession of material information not available to the public are “insiders.” Spouses, friends, suppliers, brokers, and others outside the company who may have acquired the information directly or indirectly from a director, officer or employee are also “insiders.”

Securities regulations prohibit insiders from trading in, or recommending the sale or purchase of, the company’s securities, while such inside information is regarded as “material”, or if it is important enough to influence any person in the purchase or sale of securities of any company with which we do business.

The following guidelines will be followed by all Brighthouse personnel in dealing with inside information:

• Until the material information has been publicly released by the company, an employee must not disclose it to anyone except those within the company whose positions require use of the information.
• Employees must not buy or sell securities when they have knowledge of material information concerning the company until it has been disclosed to the public and the public has had sufficient time to absorb the information.
• Employees shall not buy or sell securities of another corporation, the value of which is likely to be affected by an action by the company of which the employee is aware and which has not been publicly disclosed.
• Officers, directors and employees will refrain from gathering competitor intelligence by illegitimate means and refrain from acting on knowledge which has been gathered in such a manner. The officers, directors and employees of Brighthouse will seek to avoid exaggerating or disparaging comparisons of the services and competence of their competitors.
• Officers, directors and employees will obey all Equal Employment Opportunity laws and act with respect and responsibility towards others in all of their dealings.
• Officers, directors and employees will remain personally balanced so that their personal life will not interfere with their ability to deliver quality products or services to the company and its clients.
• Officers, directors and employees agree to disclose unethical, dishonest, fraudulent and illegal behavior, or the violation of company policies and procedures, directly to management.

Violation of this Code of Ethics can result in discipline, including possible termination. 

Cultural Competence

Brighthouse personnel will take all reasonable steps to ensure that research and development work is appropriate to the values, culture/s and circumstances of the participants.

All of Brighthouse’s work is underpinned by the advancement of all people towards positive outcomes for society. Brighthouse believes it is pertinent to have an understanding of issues relevant to Indigenous Australians and migrants. In all its consultation processes, it acts in accordance with its beliefs of equity and social justice.

It will ensure:

1. Collaboration among service providers, researchers and members of the various ethnic communities to enhance the knowledge transfer of research findings for providers and the community.
2. Research findings are disseminated to all service providers and communities.

Where appropriate, Brighthouse will provide an appropriate person from the participant ethnicity to support the interview process. Indigenous respondents will be offered a appropriate recompense their contribution, time and sharing of knowledge.

Principles Relating to Research Project Participants:

Informed Consent:
Participants will be informed verbally and in writing about:

• the purpose of the project;
• the names of the agencies responsible for the project;
• contact details of responsible persons for questions and/or complaints;
• what involvement entails;
• their right not to participate and to withdraw their consent at any stage without explanation;
• their access to the information they provide and feedback on the results;the likely risks and benefits resulting from their participation;

Freedom from Coercion to Participate:
Undue pressure will not be used to persuade people to participate, or to continue participating, in the research.

Confidentiality and anonymity:
Guarantees of confidentiality and/or anonymity given to research participants will be provided. Consultants will not breach the 'duty of confidentiality' and not pass on identifiable data to third parties without participants' consent.

Sensitivity to Participants’ Circumstances:
Physical and mental harm to the participant will be avoided, and sensitivity given to individual circumstances - e.g. age, gender, cultural background, disabilities, and values.

Preliminary work:
Prior to undertaking any project, consultants have a responsibility to survey relevant literature and information to determine the project focus.

Selection:
The selection of consultants conducting work will take account of their acceptability to, and ability to communicate well with project participants.

Awareness:
Consultants will be fully informed of their responsibilities as part of the project, and of the code of ethics.

Accountability:
Principal consultants are responsible for taking all reasonable steps to ensure that research personnel conduct their work in a professional manner.

Principles Relating to Consultants Commissioned to do the Research:

Before the project commences, the principal consultant will clarify the following:-

Use of project findings:
The right of consultants to use the research results commercially or otherwise, or to publish research and information independently, will be negotiated with the client. When project results are published independently, the institutional context within which the project took place will be made clear. This includes the objectives of the organisation commissioning the research, the nature and extent of funding, and the role of the organisation in framing and defining the project.

Multiple clients:
When working for a multiplicity of clients who can be, or are in competitive positions, the right to use information and results across projects will be negotiated and carefully defined.

Acknowledgement:
Consultants will acknowledge the due contributions of all people and organisations associated with the project or publication.

Peer Review:
Consultants will make draft research reports available for objective peer review.

Feedback of Results:
The client/s, participants and personnel involved in the project, will normally be given a report or a summary of the findings, or be informed as to how they can access the report.

Information storage:
Files containing confidential information will be password protected. Computer disks, CD/DVD and backup media will be securely stored. Identifying information and cross-matching lists will be stored securely in a separate location to the data itself.