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Corporate Code of Conduct

1. PURPOSE

The purpose of this Corporate Code of Conduct is to provide a framework for decisions and actions in relation to ethical conduct in employment. It underpins the Company’s commitment to integrity and fair dealing in its business affairs and to a duty of care to all employees, clients and takeholders. The document sets out the principles covering appropriate conduct in a variety of contexts and outlines the minimum standard of behaviour expected from employees.

2. ACCOUNTABILITIES

2.1 Managers and Supervisors
Managers and supervisors are responsible and accountable for:
  • undertaking their duties and behaving in a manner that is consistent with the provisions of the Code of Conduct;
  • the effective implementation, promotion and support of the Code of Conduct in their areas of responsibility; and
  • ensuring employees under their control understand and follow theprovisions outlined in the Code of Conduct.
2.2 Employees
All employees are responsible for:
  • undertaking their duties in a manner that is consistent with the provisions of the Code of Conduct;
  • reporting suspected corrupt conduct; and
  • reporting any departure from the Code of Conduct by themselves or others.

3. PERSONAL AND PROFESSIONAL BEHAVIOUR

When carrying out your duties, you should:
  • behave honestly and with integrity and report other employees who are behaving dishonestly;
  • carry out your work with integrity and to a high standard and in particular, commit to the Company’s policy of producing quality goods and services;
  • operate within the law at all times;
  • follow the policies of the Company; and
  • act in an appropriate business-like manner when representing the Company in public forums.

4. CONFLICT OF INTEREST

Potential for conflict of interest arises when it is likely that you could be influenced, or it could be perceived that you are influenced by a personal interest when carrying out your duties. Conflicts of interest that lead to biased decision making may constitute corrupt conduct.
  • Some situations that may give rise to a conflict of interest include situations where you have:
  1. financial interests in a matter the Company deals with or you are aware that your friends or relatives have a financial interest in the matter;
  2. directorships/management of outside organisations;
  3. membership of boards of outside organisations;
  4. personal relationships with people the Company is dealing with which go beyond the level of a professional working relationship;
  5. secondary employment, business, commercial, or other activities outside of the workplace which impacts on your duty and obligations to the Company;
  6. access to information that can be used for personal gain; and
  7. offer of an inducement.
  • You may often be the only person aware of the potential for conflict. It is your responsibility to avoid any conflict from arising that could compromise your ability to perform your duties impartially. You must report any potential or actual conflicts of interest to your manager.
  • If you are uncertain whether a conflict exists, you should discuss that matter with your manager and attempt to resolve any conflicts that may exist.
  • You must not submit or accept any bribe, or other improper inducement. Any such inducements are to be reported to your manager.

5. PUBLIC AND MEDIA COMMENT

  • Individuals have a right to give their opinions on political and social issues in their private capacity as members of the community.
  • Employees must not make official comment on matters relating to the Company unless they are:
  1. authorised to do so by the Managing Director and Chief Executive Officer; or
  2. giving evidence in court; or
  3. otherwise authorised or required to by law.
  • Employees must not release unpublished or privileged information unless they have the authority to do so from the Managing Director and Chief Executive Officer.

6. USE OF COMPANY RESOURCES

Requests to use Company resources outside core business time should be referred to management for approval. If employees are authorised to use Company resources outside core business times they must take responsibility for maintaining, replacing, and safeguarding the property and following any special directions or conditions that apply. Employees using Company resources without obtaining prior approval could face
disciplinary and/or criminal action. Company resources are not to be used for any private commercial purposes.

7. SECURITY OF INFORMATION

Employees are to make sure that confidential and sensitive information cannot be accessed by unauthorised persons. Sensitive material should be securely stored overnight or when unattended. Employees must ensure that confidential information is only disclosed or discussed with people who are authorised to have access to it. It is considered a serious act of misconduct to deliberately release confidential documents or information to unauthorised persons, and may incur disciplinary action.

8. INTELLECTUAL PROPERTY/COPYRIGHT

Intellectual property includes the rights relating to scientific discoveries, industrial designs, trademarks, service marks, commercial names ad designations, and inventions and is valuable to the Company. The Company is the owner of intellectual property created by employees in the
course of their employment unless a specific prior agreement has been made. Employees must obtain written permission to use any such intellectual property from the Company Secretary/Group Legal Counsel before making any use of that property for purposes other than as required in their role as employee.

9. DISCRIMINATION AND HARASSMENT

Employees must not harass, discriminate, or support others who harass and discriminate against colleagues or members of the public on the grounds of sex, pregnancy, marital status, age, race (including their colour, nationality, descent, ethnic or religious background), physical or intellectual impairment, homosexuality or transgender.Such harassment or discrimination may constitute an offence under legislation. Managers should understand and apply the principles of Equal Employment Opportunity.

10. CORRUPT CONDUCT

Corrupt conduct involves the dishonest or partial use of power or position which results in one person/group being advantaged over another. Corruption can
take many forms including, but not limited to:
  • official misconduct;
  • bribery and blackmail;
  • unauthorised use of confidential information;
  • fraud; and
  • theft.
Corrupt conduct will not be tolerated by the Company. Disciplinary action up to
and including dismissal will be taken in the event of any employee participating in
corrupt conduct.

11. OCCUPATIONAL HEALTH AND SAFETY

It is the responsibility of all employees to act in accordance with occupational health and safety legislation, regulations and policies applicable to their respective organisations and to use security and safety equipment provided.
Specifically all employees are responsible for safety in their work area by:
  • following the safety and security directives of management;
  • advising management of areas where there is potential problem in safety and reporting suspicious occurrences; and
  • minimising risks in the workplace.

12. LEGISLATION

It is essential that all employees comply with the laws and regulations of the countries in which we operate. Violations of such laws may have serious consequences for the Company and any individuals concerned. Any known violation must be reported immediately to management.

13. FAIR DEALING

The Company aims to succeed through fair and honest competition and not
through unethical or illegal business practices. Each employee should endeavour
to deal fairly with the Company’s suppliers, customers and other employees.

14. INSIDER TRADING

All employees must observe the Company’s “Guidelines for buying and selling securities”. In conjunction with the legal prohibition on dealing in the Company’s securities when in possession of unpublished price sensitive information, the Company has established specific time periods when Directors, management and employees are permitted to buy and sell the Company’s securities.

15. RESPONSIBILITIES TO INVESTORS

The Company strives for full, fair and accurate disclosure of financial and other
information on a timely basis.

16. BREACHES OF THE CODE OF CONDUCT

Employees should note that breaches of certain sections of this Code of Conduct may be punishable under legislation.
Breaches of this Code of Conduct may lead to disciplinary action. The process for disciplinary action is outlined in Company policies and guidelines, relevant industrial awards and agreements.

17. REPORTING MATTERS OF CONCERN

Employees are encouraged to raise any matters of concern in good faith with the head of their business unit or with the Company Secretary/Group Legal Counsel, without fear of retribution.