Governance, Ethics & Transparency

Governance, Ethics & Transparency

Our Approach

Effective corporate governance is essential to ensuring Northern Star achieves its Purpose to generate superior returns for our shareholders, while providing positive benefits for our stakeholders, through operational effectiveness, exploration and active portfolio management. The Board and Management are committed to the highest standards of corporate governance including compliance with the ASX Corporate Governance Council’s Corporate Governance Principles and Recommendations (ASX Recommendations). Our principles and processes are periodically reviewed to ensure we maintain the highest standards of corporate governance.

Corporate Governance

Northern Star is fully aligned with all 35 ASX Recommendations of the ASX Corporate Governance Council Principles and Recommendations. The Board supports the view that its Directors having diversity in gender, age, skillset, background and tenure helps ensure more perspectives contribute to decision-making.

Northern Star’s Corporate Governance Framework 

For full details of the Company’s corporate governance practices and Board skill sets, see our FY23 Corporate Governance Statement released on the ASX and available, along with previously released statements, below.

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Internal Audit & Risk Management

Northern Star has a mature risk management capability and management system. Northern Star prioritises hazard and risk assessments, mitigation and management of risks across every aspect of our operations. ESG risks and control measures are embedded in the corporate risk register, and operational risk registers.

Northern Star’s operations are guided by Northern Star’s Risk Management Policy and Risk Management Standard, which apply to the management of all types of risks within the business, document our internal control systems and provide the processes for risk assessment and management.  The Company’s Risk Management Standard outlines accountabilities, processes for risk reporting and the control mechanisms designed to ensure that our workers adequately identity, assess and manage risks at all our operations.

The annual Internal Audit Plan is designed to improve the Company’s approach to risk management and ensure operational and corporate risk reviews are completed to a high and consistent standard.

Northern Star’s internal Audit and Risk resources are focused on supporting the Board to meet its corporate governance responsibilities and apply a risk-based approach to providing assurance over business areas and processes relevant to people, financial, operations, growth, ESG and technology.

Ethical Business Practices

Northern Star actively promotes a corporate culture committed to ethical business practices, compliance with the law and exercising integrity in decision making by our people and in our operations through our STARR Core Values, Code of Conduct and other key core corporate governance policies on our Corporate Governance page. All inductions completed by our workers cover these key documents. Northern Star's policy commitments for responsible business conduct apply to all of the Company's activities and business relationships equally.

Employees and other stakeholders who suspect or see unethical, illegal or improper behaviour within the Company are encouraged to report and are protected under our Whistleblower Policy which provides for a confidential, anonymous and retaliation-free process for people to report their concerns, free of fears of retaliation, with confidence the Board will be made aware of material breaches of the Code of Conduct. Whistleblower reports are standing items for discussion on all Audit & Risk Committee and Board agendas.

Modern Slavery

‘Modern slavery’ is an umbrella term used to describe serious exploitation and human rights violations. Northern Star condemns all human rights abuses, including modern slavery practices in all its forms, which include:

  • human trafficking;
  • slavery;
  • servitude;
  • forced labour;
  • deceptive recruiting for labour or services;
  • debt bondage;
  • forced marriage; and
  • child labour.

Modern slavery is a business risk for every industry and sector, which can have severe consequences for victims and human rights violations. It is also an investment issue, given its potential to undermine shareholder value.  Notwithstanding Northern Star operates exclusively in jurisdictions ranked in the top 10 lowest for rates of modern slavery, we recognise our role in protecting the human rights of all people involved in, or impacted by, the Company’s business practices.

We take meaningful steps to identify and address our modern slavery risks and maintain responsible and transparent supply chains, including by:

  • human rights-focused policies and procedures that apply to all workers and suppliers;
  • modern slavery training and awareness programs for all workers and suppliers;
  • inclusion of modern slavery in the corporate risk management framework, with Audit & Risk Committee oversight;
  • due diligence conducted on both new and existing suppliers;
  • in-person / on-site audits undertaken on suppliers to investigate potential modern slavery incidences;
  • modern slavery response protocol and corrective action plans put in place where audits reveal issues; and
  • collaboration with our suppliers and industry peers.

Northern Star publishes annual Modern Slavery Statements under the Modern Slavery Act 2018 (Cth), which provide detailed disclosures on how we are continuing to address the risks of modern slavery in our supply chain, including planned actions for future years.

The FY23 Modern Slavery Statement, along with previously released statements, are available below.

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Transparency in Disclosure

Northern Star understands that stakeholder trust and investor confidence is built and maintained on foundations of transparent disclosure. We prioritise being clear and unambiguous about our corporate structure, operations and performance, and governance practices in our disclosure practices for the benefit of, and maintaining a genuine dialogue with, our shareholders and stakeholders.

Our public disclosures are guided by Northern Star’s Continuous Disclosure Policy and Shareholder Communication Policy. Northern Star regularly reviews and enhances its periodic disclosures to ensure openness, fairness and accountability in all our external communications. As part of our commitment to transparency, we regularly pursue meetings with proxy advisors and prior to the Annual General Meeting each year we invite shareholders to ask questions of our Board and Auditor either in advance or at the meeting (whether in person or virtually using hybrid meeting technology).

Also as part of our commitment to transparency, under the Australian Voluntary Tax Transparency Code, Northern Star continues to voluntarily publish the Company’s annual Tax Corporate Governance Statements on our Corporate Governance page.