Brambles businesses are part of the communities in which they operate and Brambles recognises its responsibility to manage the impacts of its business on those communities. The Code of Conduct addresses areas such as business integrity, competition and human rights. Employees receive training in the Code of Conduct and these aspects. In addition, the code is now available in a number of languages:, Chinese (simplified), Chinese (traditional), Danish, Dutch English, Finnish, French, French Canadian, German, Hindi, Italian, Norwegian, Portuguese, Spanish, Swedish, Tamil and Thai.

Brambles competes fairly in the markets in which it operates.

Brambles conducts business in accordance with the laws and regulations of each country in which a Brambles business is located. Brambles did not receive any significant fines or non-monetary sanctions for noncompliance with laws and regulations.

The Audit Committee of the Board reviews and approves the internal audit plan annually. The Audit Committee also monitors financial reporting risks. Internal audits are regularly conducted at a country level and reported back to the Audit Committee.

The Group Risk Committee reviews Brambles policies on risk management to satisfy itself that management has developed a sound system of risk management and internal control and that the system is operating effectively and efficiently.

Brambles operates in over 45 countries.

Brambles has interests in four countries that FTSE4GOOD classifies as ‘of concern’. The countries are:

• China (both CHEP and Recall have operations and employees in China);
• Saudi Arabia (CHEP has operations and employees in Saudi Arabia);
• United Arab Emirates (CHEP has operations and employees in the UAE); and
• Zimbabwe (CHEP has operations and employees in Zimbabwe).

Operations in these countries comprise less than 0.3% of Brambles’ global sales revenue. All operations are conducted in accordance with Brambles’ policies.

Brambles’ businesses benefit the local communities in which they operate by creating employment directly and indirectly, by providing high quality support services that assist customers in growing their businesses and by purchasing materials from local and national suppliers.

Brambles’ total market capitalisation as at 30 June 2009 was US$6.8b.

Because CHEP and Recall are multi-domestic operations, Brambles does not have a group policy on spending on locally-based suppliers. A high percentage of supplies are procured in the regions in which they operate.

Local purchasing and hiring decisions are the responsibility of management within the operating businesses.

The majority of employees are hired from within the regions in which Brambles’ businesses operate, including senior managers.

From time to time, CHEP provides pallets and containers free of charge to transport emergency supplies for relief efforts in times of disaster.

For example, CHEP provided pallets to transport emergency supplies to victims of bushfires in Victoria, Australia in February 2009, cage units to DHL in Boksburg, South Africa for refugee camps following widespread attacks on foreigners, pallets to the State Emergency Service in Queensland, Australia in response to the Warrego River flood in January 2008, pallets to provide aid to those affected by Hurricane Katrina in New Orleans, USA in August 2005 and containers to the Southern African Foundation for the Conservation of Coastal Birds in 2000 to wash penguins affected by a major oil spill.

Neither Brambles nor its operating businesses are recipients of any significant or material government subsidies or grants.

Brambles supports and upholds the principles contained in the United Nations Universal Declaration of Human Rights, which promotes the protection of people’s human rights against violations by individuals, groups or nations. The standards declare that respect for human rights and human dignity “is the foundation of freedom, justice and peace in the world”.

Brambles’ support of the principles set forth in the declaration is included in Brambles policies and Code of Conduct. Brambles respects the human rights of its employees and other stakeholders. Brambles will not tolerate child labour or forced labour in its own operations or those of its suppliers.

Brambles communicates its human rights policy to all employees globally through the Code of Conduct. The code is available in Chinese (simplified), Chinese (traditional), Danish, Dutch, English, Finnish, French, French Canadian, German, Hindi, Italian, Norwegian, Portuguese, Spanish, Swedish, Tamil and Thai.

The Senior Vice President – Human Resources (who reports to the Chief Executive Officer and who is a member of the Executive Leadership Team) has operational responsibility for the adherence to human rights across the Brambles Group.

None of Brambles operations are believed to be at risk for incidents of child or forced labour.

Bi-annual management declarations confirm, among other matters, the adequacy of internal control procedures, the effectiveness of risk management systems and compliance with all regulatory and statutory requirements. Designated General Managers at the country level of both CHEP and Recall are required to sign the management declaration standards questionnaires, which include specific questions regarding significant, or potentially significant, allegations of human rights abuses.

All sales agents, consultants and similar advisors who act on behalf of Brambles are expected to act in accordance with Brambles’ business integrity principles, as stated in the Code of Conduct. Further, all major suppliers are expected to share its social standards.

Corrupt practices are completely unacceptable to Brambles and strictly prohibited. This is clearly communicated to all employees in the Code of Conduct. No bribes or similar payments will be made to, or accepted from, any party. All of Brambles’ operations are monitored for risks related to bribery and corruption. All commercial transactions must be properly and accurately recorded. Sales agents, consultants and similar advisors must be appointed in accordance with these principles and paid at a rate consistent with their services. Assets and confidential information must be fully protected and must not be used by employees for personal gain.

Employees must not engage in activities that involve, or could appear to involve, a conflict between their personal interests and the interests of Brambles. Employees receive training in the Code of Conduct, including the area of Business Integrity.

Brambles’ internal practices include controls to monitor activities where there may be a risk of bribery or corruption. These internal controls have operated and subsequent action taken. Internal procedures include prevention controls, such as segregation of duties (eg a manager of a project does not control the expenses for that project), specified minimum control standards, bi-annual management declarations and detect controls (eg management review of expenditure, internal audits, test procedures, monitoring of invoices and amounts close to authorisation levels, etc). In the bi-annual management declarations designated General Managers at the country level of both CHEP and Recall are required to sign off on standards questionnaires, including questions based on the Code of Conduct. This declaration includes a direct question regarding bribery and the training provided to employees on the Code of Conduct.

Brambles does not make donations to political parties and will not do so without the specific endorsement of shareholders. In the bi-annual management declarations designated General Managers at the country level of both CHEP and Recall are required to sign off on standards questionnaires, including a direct question regarding donations to political organisations.

Brambles is the member of the Business Council of Australia (BCA), but representations by the BCA may or may not reflect Brambles position on specific public policy issues.

Brambles’ businesses and its people are part of the communities in which they operate and Brambles provides financial and other forms of support to a broad range of charitable and community organisations around the world.

This support is provided in three ways:

• donations funded by Brambles headquarters, primarily through the Community Reach program;
• contributions made by Brambles’ businesses to a range of local and national charities; and
• personal contributions made by Brambles employees around the world to a range of fundraising events and activities.

Brambles provided over A$600,000 in grants and donations during the year and supported causes that benefit health, the environment, education, or safety – in order to reinforce these key priorities of its business and culture.

Under the Community Reach program, grants were made to support organisations in the USA, UK, Spain, South Africa, China, New Zealand, Australia, India and other countries. The grants included donations to purchase equipment for an eye care clinic theatre in India, funding for the construction of a simple water treatment facility for a school in rural China and supporting a job training and functional living program for high school students with autism in Florida in the United States.

Brambles also continued to support the Great Barrier Reef Foundation’s ZooX Altas Project and Clean Up the World (CUW), an organisation that mobilises 35 million people in over 100 countries each year “to clean up, fix up and conserve the environment”. Further information about CUW and its activities can be found on its website at www.cleanuptheworld.org.

The Vice President Investor Relations and Corporate Affairs is responsible for overseeing Brambles’ Community Reach program and other community involvement.