Netstrata
Transparency FAQs

Strata management affects millions of Australians, but the way it works is not always well understood. In recent years, media coverage and regulatory reviews have put the spotlight on Netstrata and the wider sector, and raised questions about fees, governance, and conflicts of interest. Netstrata understands that people have questions and want clear answers. If you have a question which isn't answered below, please let us know.

Frequently asked questions

‍Why was Netstrata featured in the media, and what concerns were raised?

In Progress

In March 2024, Netstrata was featured in an ABC 7.30 segment that raised concerns about insurance fees, supplier relationships and disclosure practices. While much of the segment relied upon isolated examples which are not representative of our broader operations, we took the issues seriously – resulting in Netstrata entering into an undertaking with NSW Fair Trading providing for an independent review by McGrathNicol, overseen by NSW Fair Trading.

The summary report with full detail can be accessed here. We want to highlight three findings we believe are relevant to the ABC report and which confirmed that:

  • our fees are fair;
  • our governance is sound; and
  • and our integrated service providers charge competitive rates for their services.

The independent review also raised other issues which we promptly resolved. We believe these mostly arose as a result of our governance or systems not keeping pace with our growth. Netstrata's aim is to be the benchmark for transparent, best-practise strata management – and we're confident the recent reforms we've already implemented or have recently set in motion achieve this.

Expanded Answer

In March 2024, Netstrata was featured in an ABC 7.30 segment examining the strata management industry in New South Wales. The program raised concerns about insurance brokerage fees, supplier relationships, and disclosure practices – specifically in relation to our subsidiary Strata Insurance Services (SIS), commercial arrangements with suppliers, and the transparency of related-party disclosures.

We took these concerns seriously. However, the segment relied upon isolated examples that are not representative of our broader operations. The program did not include hundreds of examples of insurance disclosures we provided, nor did it reflect the scale and diversity of our portfolio – which includes more than 1,400 buildings. It also omitted clarifications we offered to provide greater context.

Immediately following the broadcast, we invited NSW Fair Trading and the Strata Commissioner to conduct independent audits.

This led to the McGrathNicol Independent Expert Review – one of the most comprehensive assessments ever undertaken of an Australian strata management business. We contributed $450,000 to fund the review and provided full access to our systems and personnel.

The review confirmed that:

  • Our service fees – including insurance brokerage – are at or below market rates.
  • Our governance structures are mature and actively overseen.
  • Our integrated service providers charge competitive rates for their services.

It also identified areas where our governance or systems had not kept pace with our growth. In response, we implemented 17 of the review’s 22 recommendations ahead of schedule, with three more partially implemented and in progress. Netstrata consulted with NSW Fair Trading on two that it considered were not necessary. In addition, we introduced a suite of reforms that went beyond the review’s scope, further strengthening our governance and transparency.

On the specific issues raised:

Insurance Brokerage Fees

The ABC cited examples of brokerage fees as high as 64% of the base premium. These examples were extreme outliers which are not reflective of SIS’ usual operations. SIS operates under a transparent, fee-for-service model – not a commission model. This means:

  • No payments are received from insurers
  • All fees are disclosed upfront and itemised
  • Owners approve every appointment

Comparing the model adopted by SIS to commission-based brokers is misleading. Commission models often include commission costs within the premium, while SIS’ model separates them transparently. McGrathNicol in their independent review confirmed that our net service fees – including brokerage – are at or below market rates.

Supplier Relationships and “Kickbacks”

The ABC alleged that Netstrata received “kickbacks” from suppliers, including debt collectors and contractors. In reality:

  • We have never received “kickbacks”.
  • We maintain commercial arrangements that are permitted under the Strata Schemes Management Act and the Property and Stock Agents Act.
  • These arrangements are disclosed in our agency agreements and at annual general meetings.

Since the broadcast, we have further strengthened our disclosure protocols and now seek annual attestations from all suppliers to confirm that Netstrata does not request or receive incentives, so our owners don't just take our word for it.

Disclosure and Governance

The ABC suggested that Netstrata failed to disclose relationships with subsidiaries and family members. We acknowledge that some disclosures were not as clear as they could have been. This was a governance gap, not an attempt to mislead. We have since:

  • Implemented a formal Conflict of Interest Policy
  • Created a central register
  • Mandated conflict-of-interest training for all staff
  • Updated our Management Agency Agreements, AGM packs and Section 60 reports to ensure that all related-entity relations are accurately disclosed.

How has Netstrata improved governance and transparency?

In Progress

We’ve added stronger compliance oversight, clearer disclosures, upgraded agreements, and tools that give owners full visibility over finances and services. These reforms go beyond industry norms and reflect our commitment to best-practice operations.

Expanded Answer

Since early 2024, Netstrata has implemented a comprehensive reform program to strengthen governance, transparency and owner confidence.

These reforms are detailed exhaustively in a dedicated Initiatives & Reforms section on this website.

The changes we've made go beyond what is typical in the industry. They reflect our commitment to best-practice operations in a sector that is still developing consistent professional standards.

Does Netstrata’s work with subsidiaries or other related entities create a conflict of interest?

In Progress

No. There is no actual conflict. We always ensure our tenants get the best value regardless of whether they’re being serviced by an owned subsidiary or an external provider. A conflict of interest happens when private benefit to a person or organisation could improperly influence its decision-making. In strata, this could mean appointing a family member’s business or a company you own even if it’s not the best option for the owners. At Netstrata, all family and related entity relationships are disclosed, appointments are approved by owners, and decisions are backed by service quality, compliance and market pricing – which the independent review confirmed are at or below market rates.

Expanded Answer

No. There is no actual conflict. We always ensure our clients get the best value – regardless of whether a service is delivered by a wholly owned subsidiary or an external provider.

Conflicts of interest can be actual, perceived or potential. Generally:

  • An actual conflict arises when a decision-maker is improperly influenced by private benefit.
  • A perceived conflict exists when it appears to others that a decision may not be impartial – even if it is not influenced.
  • A potential conflict is a situation where a conflict could reasonably arise in the future.

At Netstrata, we take all three types seriously and have governance in place to manage them transparently and effectively.

While Netstrata does have family members working in the business and wholly owned subsidiaries providing services such as insurance broking and fire safety, the potential or perceived conflict is managed through clear safeguards. These include:

Full disclosure: All related-entity relationships – including familial ties, ownership structures and commercial arrangements – are disclosed before any appointment. These disclosures are made in our Management Agency Agreements, AGM packs and Section 60 reports. These commercial arrangements are permitted under the Strata Schemes Management Act and the Property and Stock Agents Act, and are disclosed in accordance with those requirements.

Owner control: The Owners Corporation always has the final say on who is engaged for insurance, maintenance or compliance work. No related entity is appointed without owner approval. There is no obligation to use our subsidiaries. Owners are free to appoint any provider they choose, and we support those decisions fully.

Compliance oversight: Our group structure allows us to set performance standards for related-entity work to ensure it meets both legal requirements and our quality standards. This includes quarterly audits, internal KPIs, and performance reviews. Subsidiaries are held to delivery KPIs, and strata managers are scored against individual performance metrics covering service quality, compliance and owner satisfaction.

Benchmarking: Fees are at or below market rates to ensure competitiveness. We periodically assess competitiveness against the market where fees for comparable services can be obtained.

Independent validation: The McGrathNicol Independent Expert Review – commissioned by NSW Fair Trading – was one of the most comprehensive assessments ever undertaken of an Australian strata management business. It confirmed that our service fees – including those of our subsidiaries – are at or below market rates.

We created our related entities – including Strata Insurance Services (SIS), Winfire (fire safety), and others – to address persistent gaps in the strata sector, particularly in areas like insurance, fire compliance and maintenance, where external providers often struggle to meet governance and reliability standards. These businesses operate to the same exacting standards we apply to our strata management. What we expect from our related service providers:

  • Completed on time – with internal teams familiar with the buildings they service, reducing delays and improving responsiveness.
  • Compliant with all legal requirements – with oversight from our compliance function to ensure statutory obligations are met.
  • Delivered to best-practice standards – using rigorous internal standards and performance metrics.
  • Benchmarked against market pricing – with periodic reviews to ensure fees remain competitive and fair

With this governance in place, the use of related entities does not create an unmanaged conflict of interest – it creates a quality-controlled, transparent way to deliver services that owners approve, can scrutinise, and can replace with alternatives if they wish.

Why does Netstrata have wholly owned subsidiaries?

In Progress

We created our own service businesses to close gaps in the market and ensure all work meets our exacting standards. This means owners get reliable, compliant, best-practice outcomes in industries where external providers may not always meet those standards.

Expanded Answer

The strata industry often overlaps with sectors that can be inconsistent in quality, compliance, and governance. On the other side, we deal with industries such as insurance and safety that demand precision, thorough record-keeping, and strict adherence to rules. Many external providers in these sectors deliver excellent results, but some fall short, causing delays, compliance risks, or higher costs for owners.

For schemes under our care, we wanted to ensure there were reliable, high-standard service options available in every category. So, our prefernce is to utilise wholly owned subsidiaries to bridge this gap, and operate to the same high standards we apply to our strata management.

Owners always have the final say on whether to use our subsidiaries or appoint an external provider. Where an external provider is chosen, we work with them to ensure they can meet the needs of the scheme.

The McGrathNicol Independent Expert Review confirmed that the service fees of our subsidiaries are at or below market rates, validating that the services we provide deliver fair value.

Why are brokerage fees sometimes seen as high?

In Progress

Our brokerage fees reflect the work required to secure and manage the best insurance coverage for each scheme. While the insurance is placed through our wholly owned brokerage subsidiary, owners benefit from professional service, competitive pricing, and no hidden commissions.

Expanded Answer

Brokerage fees cover the work involved in sourcing, negotiating, placing, and managing insurance policies for strata schemes. This includes liaising with insurers, tailoring policies to suit each scheme’s needs, processing claims, and ensuring compliance with regulatory requirements.

For schemes we manage, the insurance is often arranged through our wholly owned subsidiary, Strata Insurance Services (SIS), which also provides these same services to other strata management companies.

Importantly:

  • We do not take insurer commissions through SIS: fees are transparent and represent the true cost of the service. This differs from commission-based models where typically fees are bundled into the premium and not disclosed.
  • The McGrathNicol review found our net service fees – including brokerage – to be at or below market rates.
  • All appointments of SIS as broker are approved by the Owners Corporation: Owners have full control over who is appointed.
  • Owners always have the right to appoint an alternative broker if they wish: In practice, many choose to stay with SIS because of the reliability, service quality, and the efficiencies gained from close integration with our strata management systems.

It’s important to understand the difference between fee-for-service and commission-based models. SIS operates on a fee-for-service basis, meaning:

  • Fees are disclosed upfront
  • No commissions are received from insurers
  • Owners know exactly what they are paying for

In contrast, many external brokers operate on a commission model, where:

  • The broker receives a percentage of the premium from the insurer
  • This commission is bundled into the policy cost
  • Owners may not realise they are paying it

This model is common across the strata industry in NSW. According to the Strata Community Association (NSW), commissions have long been a source of concern due to their lack of transparency and potential to create conflicts of interest. In September 2025, SCA NSW announced it would begin phasing out insurance commissions across the industry, starting 1 January 2026. This reform aims to:

  • Improve transparency
  • Reduce conflicted incentives
  • Ensure owners understand what they are paying for

Netstrata supports the principle of transparency and operates under a fee-for-service model for its own brokerage, SIS.

Furthermore, from 1 January 2026, Netstrata will begin phasing in a Zero Commissions policy across its entire business, which includes insurance commissions.

Netstrata will continue dialogue with both government and regulators to drive improved change across the industry, and will continue to comply with all regulatory changes and industry standards as they evolve.

Are commissions in strata bad – and what is Netstrata’s position?

In Progress

Commissions in strata insurance are payments made by insurers to brokers or managers, usually as a percentage of the premium. They are often built into the policy cost, which means owners may not realise they are paying them. When external brokers are used, some operate on a commission model. This is a broader industry issue, and only industry bodies can drive sector-wide reform in this area. SCA NSW announced it hopes to phase out commissions from 1 January 2026, though recently updated that this change would not be mandatory. From 1 January 2026, Netstrata will begin phasing in a Zero Commissions policy across its entire business, which includes insurance commissions.

Expanded Answer

In strata insurance, a commission is a payment made by the insurer to the broker or strata manager as a percentage of the premium. It is included in the policy cost, meaning owners often don’t realise they are paying it. Because it is built into the premium, it can be difficult to see how much it is or what it is for.

This creates two key problems:

  • Transparency: Owners may not know they are paying a commission, or how much it is.
  • Conflicted incentives: If a manager or broker is rewarded with a percentage of the premium, they may have less incentive to negotiate for lower premiums, because their commission would also go down.

Strata Insurance Services (SIS) operates on a fee-for-service model. This means:

  • No commissions are received from insurers
  • Fees are disclosed upfront and itemised on every invoice
  • Owners approve every appointment

This model ensures that owners know exactly what they are paying and what they are getting for it. It also aligns with our commitment to transparency, as outlined in our Code of Conduct.

However, when external brokers are used – either by owner choice or due to scheme-specific needs – some operate on a commission model. In this model:

  • The broker receives a percentage of the premium from the insurer
  • This commission is bundled into the policy cost
  • Owners may not realise they are paying it

This model is common across the strata industry in NSW. According to the Strata Community Association (NSW), commissions have long been a source of concern due to their lack of transparency and potential to create conflicts of interest. In September 2025, SCA NSW announced it would begin phasing out insurance commissions across the industry, starting 1 January 2026. More recently, they updated this announcement to clarify that this change would not be mandatory.

So, where do we stand? Owners deserve clarity, fairness and control. Netstrata supports the principle of transparency and has been operating on a fee-for-service model for its own brokerage, Strata Insurance Services (SIS). Whether working with SIS or an external broker, we ensure that all fees are disclosed and all appointments are approved by owners, and all decisions are made in the owners’ best interests.

Furthermore, from 1 January 2026, Netstrata will begin phasing in a Zero Commissions policy on all new agreements across its entire business, which includes insurance commissions. We believe that the only way to successfully implement this model sector-wide is via government reform. We will continue to comply with all regulatory changes and industry standards as they evolve, and work proactively with government and industry bodies to drive positive change as the sector evolves.

Why do some commercial tenants affect insurance costs?

In Progress

Certain commercial tenants, like tobacconists or restaurants, can significantly increase insurance premiums because they are considered higher risk. This affects a scheme’s overall costs and may require additional administration.

Expanded Answer

Insurance premiums for strata schemes are based partly on the perceived risk of the building and its occupants. Some commercial tenants – such as tobacconists, tattoo studios, and certain food outlets – are classified by insurers as higher risk. These businesses can increase the likelihood or cost of claims (e.g. fire, theft, liability), which in turn pushes up premiums for the entire building.

For example:

  • A tobacconist in a mixed-use building may be considered a fire and theft risk due to the nature of stock and storage. Insurers may apply higher premiums or stricter policy conditions.
  • A restaurant might increase fire risk due to commercial kitchen operations, especially if ventilation, fire suppression or maintenance records are inadequate.

Netstrata manages this by:

  • Ensuring accurate disclosure of all commercial occupants to insurers. This includes tenant type, business activity, and any known risk factors.
  • Working with brokers to minimise premium impacts where possible. This may involve negotiating exclusions, adjusting coverage, or sourcing alternative quotes.
  • Advising owners on the likely insurance implications before changes in occupancy are approved. This ensures committees understand the financial and compliance consequences of tenant decisions.

This is a normal and widely recognised dynamic in mixed-use buildings, and not unique to Netstrata. Our role is to ensure owners are informed, insurers are accurately briefed, and premiums reflect the true risk profile of each scheme.

Do Netstrata strata managers financially benefit from creating unnecessary work or overcharging?

In Progress

No. Schedule B remuneration is designed to incentivise positive behaviours by strata managers that are directly aligned with the interests of the Owners Corporation. It rewards managers for identifying and delivering non-standard services – such as project oversight or major works coordination – that fall outside the base management agreement but contribute to the long-term maintenance and improvement of the scheme. These services are only undertaken when there is a genuine need and with owner approval. By compensating managers for going above and beyond their core remit, the model encourages proactive stewardship, ensures transparency, and helps schemes receive the full benefit of a manager who knows the property intimately and is motivated to act in its best interests.

Expanded Answer

No. Schedule B work refers to services that fall outside the standard scope of the strata management agreement – such as project management, insurance claim coordination, major works oversight, or additional administrative tasks not covered under the base fee. These services are not automatically included in the agreement and are only undertaken if scoped, agreed to, and approved by the Owners Corporation.

Netstrata strata managers may receive additional remuneration when Schedule B work is identified, approved, and performed. The purpose of this incentive is to encourage managers to actively investigate and recommend work that helps maintain or improve the scheme – above and beyond the default remit of their role. This ensures that schemes receive proactive service and that managers are fairly compensated for delivering non-standard outcomes and the extra time they expend in doing so.

This can only occur where there is a genuine need for the work, and where the Owners Corporation has approved it. Netstrata managers know their schemes better than anyone – and the Schedule B incentive structure is designed to reward them for identifying and delivering additional value beyond the standard scope of the management agreement. By linking remuneration to owner-approved, non-standard services, the model encourages proactive stewardship and ensures that the interests of the manager and the Owners Corporation remain aligned.

While Schedule B fees may sometimes include services delivered by related parties, there is no specific incentive for a manager to appoint a related entity. The same remuneration applies whether the work is performed by a related provider or an independent third party. Appointments are made based on service quality, compliance, and value – and always subject to owner approval.

Can owners see all fees, records and decisions relating to their scheme?

In Progress

Yes – Netstrata provides owners with real-time access to every invoice, payment, levy, report and decision through the Owners Portal, AGM packs and enhanced disclosures. This capability is the result of a long-held vision, now realised through years of system integration and technological advancement.

Expanded Answer

Netstrata’s commitment to providing information to Owners Corporations is not new – it has been decades in the making. For more than ten years, our leadership team has held a clear vision: that every owner should be able to see exactly how their money is spent, who is doing the work, and how decisions are made. That vision was ambitious; however, the technology wasn’t there yet – it required alignment of myriad systems and upgrades to accounting software that have been underway for years.

In 2025, that changed. After years of investment in system integration, data architecture and digital infrastructure, Netstrata launched the Netstrata Owners Portal – a secure, real-time platform that gives owners access to:

  • Invoices and payments: Every invoice paid by the scheme is visible, including supplier details, work descriptions and costs. Owners can click on any expense line to view the actual invoice.
  • Levy history: Owners can view a complete ledger of their levy contributions, including payment dates and outstanding balances.
  • Scheme financials: Budget summaries, expenditure breakdowns and financial reports are available in real time.
  • Compliance records: Section 55 and Section 60 reports are accessible on demand, with enhanced formatting for clarity.
  • Meeting records: AGM minutes, notices and resolutions are stored and searchable.
  • Maintenance tracking: Owners can report issues, track progress, and (soon) view who lodged the request and when it was resolved.
  • Notifications: Real-time alerts for levy notices, meeting updates and compliance documents are built into the system.

This portal is supported by redesigned AGM packs, which now include:

  • Trade compliance summaries
  • Contractor attestations
  • Strata Manager remuneration declarations
  • Insurance broker service explanations
  • Complaints and feedback guidance

These materials are underpinned by our updated Management Agency Agreement, which clearly sets out all fees, inclusions and optional services – with no hidden charges. Owners can choose between a bundled monthly fee or a pay-as-you-go model, and all electronic services are itemised.

Together, these tools represent the most advanced transparency system in Australian strata – and, based on our research, potentially the most comprehensive globally. They are not just technical achievements; they are the fulfilment of a promise made to our owners years ago.

How can owners view disclosures relating to their scheme?

In Progress

Netstrata discloses potential conflicts related to owners’ strata schemes in the Section 60 disclosure included in each AGM notice, which is issued annually based on the scheme’s financial year end. This document outlines Netstrata’s subsidiary businesses and sets out any potential conflicts of interest relevant to the scheme during the preceding 12 months.

Expanded Answer

Owners can view their most recent AGM notice by logging into the Netstrata Owners Portal. Once logged in:

  1. Navigate to ‘Building Documents’
  2. Select ‘Meeting Minutes & Notices’
  3. Open the most recent document beginning with ‘AGM Notice’

The disclosures will appear toward the end of the document in sections titled ‘Report Pursuant to Section 55’ and ‘Report Pursuant to Section 60’ (owners can use the search function to locate these quickly).

Netstrata recognises that these details can sometimes be difficult for owners to locate or interpret. To address this, the team is currently developing a new Disclosures tool. This will be an industry first and far surpass current legislative requirements, by providing owners the ability to easily log in and access a real-time Section 60 disclosure tailored to them and their scheme, without waiting for the next AGM or scrolling through lengthy documents.

Developing this requires significant reorganisation of systems across all schemes under Netstrata’s care, however work on this feature is underway, and Netstrata is proud to invest the time and resources needed to deliver something that genuinely supports owners’ peace of mind. Netstrata is committed to exceeding the status quo and setting the benchmark for transparency in the Australian strata sector.

What is Netstrata’s commitment to its owners?

In Progress

Netstrata’s commitment is to deliver fair, transparent, and accountable strata management that puts owners first. We recognise that strata is not just about buildings – it’s about homes, communities, and trust. In a sector still maturing in its governance and standards, we are committed to leading by example: disclosing clearly and acting ethically. Our reforms are not just a response to scrutiny – they reflect who we are and the standards we believe every owner deserves –and our long-held attitude to continuous improvement.

Expanded Answer

Strata management affects millions of Australians, yet the way it works is not always well understood. The industry has grown rapidly, but consistent standards have not always kept pace. Many owners have experienced frustration – unclear fees, limited visibility, and a lack of confidence in how decisions are made.

Netstrata understands this. We know that trust is earned through transparency, and that our role is not just administrative – it is custodial. We are entrusted with the care of people’s homes, and that responsibility demands the highest standards of ethics, professionalism and accountability.

Our commitment to owners is built on three pillars:

1. Transparency

We believe owners should be able to see exactly how their money is spent, who is doing the work, and what decisions are being made. That’s why we’ve upgraded the Netstrata Owners Portal – with real-time access to every invoice, payment, and report relating to their scheme. We’ve redesigned our AGM packs, upgraded our Section 55 and 60 disclosures, and introduced contractor attestations and trade compliance summaries. These tools give owners full visibility and control.

2. Governance and Ethics

We’ve implemented a formal Code of Conduct Policy that sets clear expectations for every staff member, contractor and subsidiary. It prioritises client interests, mandates conflict-of-interest training, and enforces professional behaviour. Our governance reforms – including the appointment of a Group Compliance Manager, quarterly audits, and performance reviews – ensure that our standards are not just written, but lived.

We disclose all relationships with related entities, and owners approve every appointment. Our pricing is benchmarked against market rates, and our services are monitored for quality and compliance. These safeguards ensure that every decision is made transparently and on merit.

3. Industry Leadership

We recognise that some challenges – like insurance commissions – are systemic. Netstrata has already adopted a fee-for-service model through our brokerage subsidiary, SIS. But we also acknowledge that broader reform requires industry-wide action. That’s why we support the direction set by SCA NSW, which has announced a phase-out of commissions from 1 January 2026. We will continue to comply with all regulatory changes and contribute constructively to industry improvement.

Our commitment is not reactive – it is proactive. Many of the reforms we’ve implemented were already underway before the ABC report aired. The scrutiny accelerated our efforts, but the direction was already clear. We are building a business that owners can trust – and are committed to leading the sector in fair strata management, trust and transparency.

How does Netstrata operate – and what are its ethics?

In Progress

Netstrata operates under a formal Code of Conduct that sets clear expectations for professionalism, ethics, transparency and client-first decision-making. This Code of Conduct has been recently reviewed and simplified. Every staff member is accountable to these standards, and if any breach were to occur, it would be taken seriously. Our culture is built on integrity, transparency and continuous improvement.

Expanded Answer

Netstrata’s Code of Conduct outlines the expected behaviours of all staff, contractors, consultants and subsidiaries. It is built around six core values:

  • Teamwork – We collaborate respectfully and inclusively.
  • Client Centred – We put client interests first, always.
  • Innovation – We welcome new ideas and challenge ourselves to improve.
  • Accountability – We own our mistakes and learn from them.
  • Integrity – We keep our word and act in our clients’ best interests.
  • Transparency – We proactively disclose conflicts and ensure decisions are visible.

The Code also includes:

  • A commitment to risk and compliance culture, requiring staff to understand their regulatory obligations and escalate concerns promptly.
  • A clear process for speaking up, including whistleblower protections and multiple reporting pathways.
  • Expectations for professional behaviour, both in and out of the workplace. Staff are ambassadors for the business and must act with honesty, transparency and respect.
  • Strict rules around conflicts of interest, including family relationships, supplier arrangements and outside business activities. Staff must prioritise client interests above their own and above Netstrata’s commercial interests.
  • Guidance on ethical decision-making, including a framework for evaluating choices based on client impact, legal compliance, values alignment and long-term sustainability.

Every staff member is required to understand and apply the Code. Breaches may result in disciplinary action, up to and including termination. The Code is reviewed regularly and updated to reflect evolving standards and expectations.