Company Code of Conduct Policy

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Company Code of Conduct Policy

This Code of Conduct has been established by the Board of Directors of the Company and sets out the principals, practices and standards of personal conduct expected from all directors, executives and employees of the Company. The Company is committed to complying with all applicable laws and regulations and to delivering strong returns whilst acting ethically and responsibly when dealing with third parties.

The objectives of this Code of Conduct are to ensure that:

The Company is committed to complying with this Code of Conduct and requires all personnel to comply with it. Personnel should always use care and diligence when fulfilling their role or representing the Company and should not engage in any conduct likely to bring discredit upon the Company.


A conflict of interest occurs when a person’s interests interfere, or appear to interfere, with the Company’s interests. The Company expects all personnel to act honestly with high standards or personal integrity and in good faith at all times and in a manner which is in the best interests of the Company as a whole and that would not negatively impact the Company’s reputation.

Personnel will conduct their personal activities in a manner that is lawful and avoids possible, actual or perceived conflict between their personal interests and those of the Company. Where an actual or potential conflict of interest is identified this must be promptly disclosed and bought to the attention of the Chairperson in the case of a Board member or the Managing Director in the case of an employee so that it may be considered and dealt with in an appropriate manner.


Personnel will not:


Personnel will maintain and protect the confidentiality of the Company’s information, except where disclosure is allowed by the Board or is required by law.

Personnel will not make improper use of any information acquired by virtue of being an employee of the Company, including the use of that information for personal gain or the gain of another party or in breach of a person’s privacy.


Personnel will always deal with shareholders, customers, suppliers, competitors and other personnel in a manner that is lawful, diligent and fair and with honesty, integrity and respect.


Personnel will always act in a manner that is compliant with all rules and regulations that apply to the Company and its operations.

Personnel will act in compliance with this Code of Conduct and the Company’s other policies.

Personnel will not knowingly participate in any illegal or unethical activity.

Personnel shall report any actual of potential breaches of the law, this Code of Conduct or the Company’s other policies to the Company’s Audit Committee.



The Company aims to provide a work environment in which all personnel can excel regardless of race, religion, age, disability, gender, sexual preference or marital status. The Company will maintain various policies relating to the workplace including a Diversity Policy.


The Company will monitor compliance with the Code of Conduct periodically by liaising with the Board, management and personnel in relation to any areas of difficulty which arise from the Code of Conduct and any other ideas of suggestions for improvement of the Code.