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1. A Conflict of Interest as described by the PAL code states that ‘while the Company respects the rights of employees to manage their personal affairs and investments employees must also act in the best interests of the company and avoid situations that present a potential or actual conflict between their interests and the interests of the company. A ‘conflict of interest’ exists when a person’s personal interests conflicts or interferes in any way with interests of the company. A conflict situation can arise when an employee takes actions or has interests that may make it difficult to perform his or her work objectively and efficiently. Conflicts of interest may not always be clear-cut, so if you are unsure about a situation or have a question, you should consult the Senior Ethics Advisor. Any employee who becomes aware of a conflict or potential conflict should bring it to the attention of the Senior Ethics Advisor as soon as possible’ (facts). a. Business Time: Employees shall devote their full business-related time and best efforts to accomplishing their assigned duties. Employees shall not simultaneously engage in business actives for any other business enterprise. 2. Matthew Graham is a junior accountant helping to prepare PAL’s audit. Matthew identifies an issue relating to the Company’s compliance with Australian Corporations Law and ASIC reporting requirements. It appears that the ‘manager of the internal auditing group has been recording the total amount of Cost of Goods Sold relating to their ‘Active wear’ range of clothing as 15% higher than they appear to be from the invoices’ (facts). I trust that PAL is disregarding section 1 of Code of Business Conduct and Ethics, ‘Compliance with Laws, Rules and Regulations’. This section outlines that all employees must respect and obey all Government Laws, Rules and Regulations. Matthew is obeying this law by identifying a breach of the conduct and seeking advice from supervisors, managers or other…

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