Company Policies

Man and woman in suits walking

Cochlear's business practices are governed by a series of codes and policies. It is the intention of Cochlear's board that these codes and policies are understood and strictly adhered to by all relevant parties and that they are reviewed and updated on a regular basis. Codes and policies include:

Global Code of Conduct

Cochlear Limited is committed to conducting its global business fairly, honestly and legally. Our Global Code of Conduct sets a high standard of conduct, business ethics and integrity required of all our people around the world in driving our business forward, to ensure we are "Hear now. And always".

Whistleblower Protection Policy

Cochlear Limited's Whistleblower Protection Policy aims to promote a culture of acting lawfully, ethically and responsibly, by enabling Eligible Protected Persons to report confidentially, and anonymously if they wish (subject to local laws and regulations), any suspected or actual misconduct in relation to Cochlear.

Continuous Disclosure Policy

Cochlear Limited has obligations under the Corporations Act and ASX Listing Rules to keep the market fully informed of information which may have a material effect on the price or value of its securities. Cochlear's policy is to strictly comply with these requirements, and Cochlear discharges these obligations by releasing information to the ASX in the form of an ASX release or disclosure of other relevant documents. View the Continuous Disclosure Policy.

Trading Policy

The ASX Listing Rules require Cochlear to have a trading policy which applies to its key management personnel. This is in addition to the insider trading prohibitions of the Corporations Act which apply to all of Cochlear’s directors, officers and employees (and their associates). The insider trading prohibitions apply to dealings in securities, including Cochlear securities. Substantial criminal and civil penalties may apply if the insider trading prohibitions are not complied with. The Trading Policy is an important tool in managing the risks associated with dealings in securities. View the Trading Policy.

Performance Evaluation of the Board and Key Executives Policy

The Board of Directors of Cochlear Limited has established a Performance Evaluation Process for evaluation of the performance of the board, board Committees, individual directors and key Executives.

Risk Management Policy

Cochlear Limited is accountable to its shareholders for the management of company assets and maximisation of shareholder value. Cochlear provides the framework to manage the risks associated with all the activities of Cochlear Limited's Risk Management Policy

Shareholder Communications Policy

Cochlear Limited's communication to shareholders is based on openness and honesty. These principles are set out in the company's Shareholder Communications Policy.

Diversity & Inclusion Policy

As a global business, Cochlear Limited is committed to an inclusive workplace that attracts the best employees to support our growth business; we therefore need people with a diverse range of skills expertise and diversity in terms of gender, age and ethnicity. These principles are set out in the company's Diversity & Inclusion Policy.

Share Ownership Policy

The purpose of the Cochlear Share Ownership Policy is to ensure appropriate alignment of the interests of Cochlear’s Executives with the financial interests of Cochlear’s shareholders. The guidelines aim to create a share ownership focus and culture and to build long-term commitment to the Company by providing direction to KMP as to minimum levels of share ownership.

Clawback Policy

Executive Clawback Policy aims to provide the Board with the ability to claw back the remuneration outcomes of Cochlear’s Executives in relation to a material misstatement or misrepresentation.

Environmental Policy

Cochlear Limited makes its best effort to minimise its impacts on the environment. The company’s Environmental Policy sets out how this is done.

Supplier Code of Conduct

Cochlear Limited works with our suppliers to encourage standards on labour practices, safety and wellbeing, environment and sustainability and ethical trading outlined in our Supplier Code of Conduct.