Code Of Conduct Policy Template For Australian Businesses

If you’re building a startup or small business, you’re probably juggling a lot: customers, cash flow, product, hiring, and everything in between.

A code of conduct policy is one of those “behind the scenes” foundations that can quietly make your business run smoother - and help you manage risk when things get stressful (which they often do as you grow).

In this guide, we’ll walk you through what a code of conduct policy template should include, how to tailor it to your business, and how it fits into your wider set of workplace policies and legal obligations in Australia.

We’ll keep it practical and startup-friendly, so you can get a clear policy in place without overcomplicating it.

What Is A Code Of Conduct Policy (And Why Does Your Business Need One)?

A code of conduct policy is a written set of expectations about behaviour at work. It explains what “professional conduct” looks like in your business - both in day-to-day operations and when issues arise.

For startups and small businesses, a code of conduct is often the difference between:

• solving problems early vs letting them escalate into disputes,
• having consistent standards vs “it depends who’s managing that day”, and
• making confident decisions vs worrying you’ll be accused of being unfair or inconsistent.

Even if you have a small team, having a clear policy helps you set the tone for culture, safety, compliance, and performance. And as soon as you start hiring (or working with contractors regularly), the value increases quickly.

A good code of conduct policy also supports your other documents - for example, your Employment Contract and workplace policies - by making your expectations easy to understand and enforce.

Is A Code Of Conduct Policy A Legal Requirement In Australia?

There isn’t one single law that says “every business must have a code of conduct policy”. But in practice, it can help you comply with a mix of legal obligations, including:

• Work health and safety (WHS): setting behaviour standards supports a safe workplace (including psychological safety).
• Fair and lawful management: if you need to address misconduct, a written policy helps you show the standard was communicated.
• Privacy and confidentiality expectations: particularly important if your team handles sensitive customer data or commercial information.

So while it may not be mandatory in the strictest sense, it’s often one of the most practical “must-haves” once you employ staff or operate in a higher-risk environment (client sites, regulated industries, health services, finance, education, and so on).

What To Include In A Code Of Conduct Policy Template (With Practical Clauses)

If you’re searching for a code of conduct policy template, it’s usually because you want a starting point that you can customise.

The key is to avoid a generic document that looks professional but doesn’t actually help you manage your workplace. A strong template covers the issues that commonly arise in real businesses - and makes it clear what happens if the policy is breached.

Here are the sections we usually recommend including.

1) Purpose, Scope, And Who The Policy Applies To

Start by clarifying:

• why the policy exists (e.g. to promote a safe, respectful, compliant workplace),
• who it applies to (employees, contractors, interns, volunteers), and
• where it applies (office, remote work, client sites, work events, online work channels).

This avoids arguments later like “that was outside work hours” or “I’m a contractor so that doesn’t apply to me”.

2) Expected Standards Of Behaviour

This is the “heart” of your code of conduct policy template. Keep it clear and practical.

• Professional conduct: being punctual, respectful communication, following reasonable directions, cooperating with colleagues and clients.
• Integrity: being honest in reporting, not falsifying records, not misleading customers or suppliers.
• Compliance: following applicable laws, safety requirements, and internal procedures.

If your team interacts with customers directly, you can also reference behaviours that reduce consumer law risk (for example, not making promises your business can’t deliver). If your business sells goods or services to consumers, your standards should align with the Australian Consumer Law expectations around advertising and customer statements.

3) Discrimination, Harassment, Bullying, And Respectful Conduct

Most small businesses don’t think they need this section until there’s a complaint - and then it becomes urgent.

Your code should explain that bullying, harassment, and discrimination aren’t tolerated, including in:

• in-person conduct,
• emails and messaging apps (Slack, Teams, SMS), and
• work events (including social functions).

To keep this section practical, you can include examples of unacceptable behaviour (e.g. repeated unwanted jokes, intimidation, exclusion, aggressive communication).

If you manage a hybrid team, it’s worth stating explicitly that remote work channels are still “workplace conduct”.

4) Conflicts Of Interest (And Gifts & Benefits)

Conflicts of interest come up more often than founders expect - especially once you start hiring experienced people who have side projects or industry connections.

A template usually includes rules like:

• workers must disclose actual or potential conflicts,
• workers must not use their role for personal gain, and
• gifts and hospitality must be disclosed or approved above a certain threshold.

This section is even more important if your team manage procurement, supplier relationships, or tender processes.

Depending on your structure and governance, a separate Conflict Of Interest Policy may also make sense (particularly for companies with directors, boards, or grant funding requirements).

5) Confidentiality, Information Security, And Privacy Expectations

Almost every business has confidential information - even if you’re “just” a small team. Think:

• customer lists, pricing, proposals, and contracts,
• internal financials and runway,
• product roadmaps and source code, and
• personal information about customers or staff.

Your code should set expectations around:

• keeping confidential information secure,
• using business systems appropriately,
• not sharing information without authorisation, and
• extra care when working remotely or on personal devices.

If you collect personal information (for example through a website, app, bookings, marketing lists, or HR systems), you should also ensure your external-facing Privacy Policy aligns with what your team is actually doing internally.

6) Use Of Company Property And Systems (Including Social Media)

This section helps prevent avoidable mess, like inappropriate use of company devices, misuse of software licences, or risky posts on social media that customers link back to your brand.

Your code of conduct policy template can cover:

• appropriate use of email, messaging, and internet,
• rules for personal use (if allowed),
• security requirements (passwords, MFA, device storage), and
• guidelines about representing the company online.

If your team uses generative AI tools, you may also want to include rules about what information can be entered into these tools (especially confidential or customer data).

7) Workplace Health, Safety, And Reporting Obligations

A code of conduct policy can reinforce that everyone has responsibilities for safety.

This may include:

• following safety procedures and training,
• reporting hazards and incidents promptly,
• not being under the influence of drugs or alcohol at work, and
• behaving safely at client sites or events.

For some businesses, you may also want to include expectations around fatigue management, driving for work, or working alone.

8) Breaches, Investigations, And Consequences

This is where many templates fall short. It’s not enough to say “we expect high standards”. You also need a clear pathway for what happens if the policy is breached.

A practical clause set usually covers:

• how staff can raise concerns (including options for confidential reporting),
• that you may investigate alleged misconduct,
• that outcomes depend on severity and context, and
• possible consequences (training, warning, reassignment, termination).

If you have a growing team, align this with your performance management and termination processes so you’re acting consistently and fairly.

How To Tailor A Code Of Conduct Policy Template To Your Startup (Without Making It Too Complex)

A template is a starting point, but your policy will be much more useful if it reflects the way you actually operate.

Here are practical ways to customise your code of conduct without turning it into a 40-page manual.

Start With Your Real Risks

Different businesses face different “pressure points”. For example:

• A tech startup might prioritise confidentiality, data security, and acceptable use of systems.
• A hospitality business might prioritise customer conduct, harassment prevention, and health and safety.
• A professional services business might prioritise conflicts of interest, client confidentiality, and reputation management.

Aim for a code that helps you manage what is most likely to happen in your workplace, not a generic list of everything that could happen anywhere.

Match The Policy To Your Team Structure

If you have a mix of employees and contractors, make that explicit in the scope section. You can set conduct expectations for contractors too, but you’ll usually want to make sure your contractor agreements (and onboarding) clearly reflect those expectations and the consequences of a breach.

Also consider whether you need different rules for:

• managers,
• client-facing roles, or
• remote vs on-site workers.

Keep Language Clear And Enforceable

The best code of conduct policy templates use plain English. That’s not just nicer to read - it also reduces misunderstandings.

Try to avoid vague statements like:

• “Employees must always behave appropriately.”
• “Employees must not damage the company’s reputation.”

Instead, anchor the expectations to observable behaviour (what someone did or didn’t do), and include examples where helpful.

Decide Where The “Detail” Lives

Your code of conduct should set the overall standards. Then you can link it (internally) to more detailed policies where needed, like:

• anti-bullying / harassment policy,
• IT acceptable use policy,
• workplace surveillance or camera policy (if relevant),
• social media policy,
• leave and attendance rules.

This approach keeps your code readable, while still giving you the detail you need for specific scenarios.

How To Roll Out And Enforce Your Code Of Conduct Policy

Having a code of conduct policy template saved in Google Drive isn’t the same as implementing it.

To get real value (and reduce risk), you’ll want to roll it out in a way that makes it part of how your business operates.

1) Introduce It During Onboarding

Make the policy part of your onboarding checklist. Ideally, staff should:

• receive it before they start (or on day one),
• have a chance to ask questions, and
• confirm they’ve read and understood it.

This works best when paired with well-drafted employment documentation, including an Employment Contract that references company policies.

2) Train Your Managers On How To Apply It

Policies often fail because managers interpret them differently - or they avoid addressing issues because they’re unsure what to do.

Even a short manager briefing can help you stay consistent on:

• what behaviour is a “conduct issue” vs a performance issue,
• when to document concerns, and
• how to escalate serious matters.

3) Document Issues Early (But Fairly)

If misconduct happens, it’s usually easier to manage if you address it early and keep good records.

That doesn’t mean jumping straight to disciplinary action. It means being clear about expectations, giving someone a chance to respond, and keeping notes of what happened.

Where matters are serious, sensitive, or likely to escalate, it’s worth getting advice before taking action.

4) Keep It Updated As You Grow

Startups move quickly. The code you wrote when you had 3 people in a co-working space might not work once you have:

• multiple teams,
• team leads and managers,
• a remote workforce, or
• regulated clients and larger contracts.

As a general rule, review your code of conduct at least annually, and any time you change your systems, your structure, or your risk profile.

Common Mistakes Small Businesses Make With Code Of Conduct Policies

Most problems we see aren’t caused by having “no policy”. They’re caused by having a policy that doesn’t match how the business actually operates - or a policy that isn’t used properly.

Using A Template That Doesn’t Fit Your Business

A generic code of conduct policy template can include obligations that don’t match your operations, which creates confusion and inconsistency.

For example, it might refer to “union delegates”, “clinical standards”, or “regulated financial advice” when your business doesn’t operate in those areas.

That’s why tailoring matters: your policy should feel like it was written for your team, not copied from somewhere else.

Not Aligning The Policy With Employment Documents

If your code of conduct says one thing and your employment contracts or workplace processes suggest another, enforcing the policy becomes harder.

For example:

• your contract may need to reference policies and require compliance,
• your warning/disciplinary approach should be consistent with your internal procedures, and
• your confidentiality expectations should align across contracts and policies.

Where your team includes multiple founders or directors, clear governance documents (like a Company Constitution) can also help support consistent decision-making when serious conduct issues arise.

Writing Rules That Are Too Vague To Enforce

It’s tempting to keep policies broad, but overly vague rules can lead to “grey areas” - and those grey areas can become disputes.

Instead, aim for:

• clear standards,
• examples of unacceptable behaviour, and
• a fair process for investigating and deciding outcomes.

Ignoring Privacy, Surveillance, Or Recording Risks

Many workplaces now use CCTV, access logs, GPS tracking, call recording, or monitoring tools - especially in retail, warehousing, and customer service teams.

If that’s relevant to your business, your code of conduct should not accidentally conflict with your approach to monitoring and workplace privacy. The rules around surveillance and recordings can vary depending on your state or territory, the type of monitoring, and whether consent and notification requirements apply. In many cases, it’s better handled through a dedicated workplace surveillance/monitoring policy (and properly drafted employment documents) rather than relying on a code of conduct alone. Depending on your setup, it can also be important to understand the rules around workplace monitoring and recording, including business call recording laws.

This is an area where “common sense” doesn’t always match the law, so it’s worth getting it right early.

Key Takeaways

• A well-drafted code of conduct policy sets clear behavioural expectations and gives you a practical framework for managing workplace issues consistently.
• A strong code of conduct policy template should cover scope, expected behaviour, respectful conduct, conflicts of interest, confidentiality, use of company systems, WHS expectations, and consequences for breaches.
• Templates are a great starting point, but tailoring your policy to your actual risks (industry, team structure, remote work, client sites) makes it far more effective.
• To be enforceable in practice, your code of conduct should be rolled out through onboarding, manager training, and consistent documentation of issues.
• Your code of conduct works best when aligned with your employment documentation, including an Employment Contract and supporting workplace policies.

If you’d like help preparing or reviewing a code of conduct policy for your startup or small business, you can reach us at 1800 730 617 or team@sprintlaw.com.au for a free, no-obligations chat.