Policy Statement:

The Company is committed to the principles of professional conduct and believes that the application of these principles will create and maintain a positive working environment and enhance the reputation of the Company. To this end the Company has developed a Code of Conduct to reflect of the company's values and standards.

All staff are required to observe the standards identified in the Code of Conduct as a condition of employment. In acknowledging this, all employees are required to read the Code of Conduct and sign and return the declaration contained in the procedural documents section of this policy to the Human Resources Manager to retain on personal files. The Company fully expects that all employees will be able to give complete commitment and wholehearted support to the standards and values contained within the Code of Conduct.

In practical terms, all employees will demonstrate continuous commitment to:

• Behave ethically in dealings with all stakeholders
• Treat all stakeholders courteously, and without harassment or discrimination on grounds recognised in law
• Maintain the Company's property with respect and care
• Provide and maintain a safe and healthy environment within Company premises for stakeholders
• Ensure all work practices are created and conducted legally and with strict observance of the highest standard of propriety
• Comply with all laws

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The purpose of this policy document is to set out the Company's position and minimum standards, but it is by no means exhaustive as every possibility and eventuality can never be anticipated.
Though the Code the Company can do no more than attempt to address the fundamental principles, and highlight some of the more sensitive issues. In reality, the Company is depending on everyone to understand and behave in line with the "spirit" of the Code.
Violations of the Code of Conduct will result in disciplinary action appropriate to the offence, the severity of the discipline will be determined by: the actual or possible impact of the offence on the Company; the extent of any actual or possible damage inflicted on the Company; the circumstances of the offence; and any other considerations appropriate to the particular violation.

Key Principles:

• This Code of Conduct is available to all employees of the Company, so that all persons know what is expected of them.
• Failure to observe the standard of behaviour may attract disciplinary action. Such action ranges from counselling to dismissal.
• All employees are required to provide full, factual and timely disclosure of any situation that would appear to be in conflict with the interest of the Company.
• In performing their duties employees should keep uppermost in their mind the need to use commonsense. If employees always act honestly, exercise commonsense and ask for help when unsure of how to act, they will not encounter any problem in observing the principles of the Code of Conduct.
• Consent for an employee to engage in a specific situation may, at times, be granted by Senior Management when: no law or Company agreement is being breached; circumstances are clearly understood; full disclosure is made by the employee prior to engaging in the activity; and the Company is not and is not likely to become adversely affected by the situation. Such consent must be given in writing.

Procedures

1. General

It is not practical to specify acceptable behaviour that is prescriptive for all possible circumstances. This Code should be taken as a guide to the standard of integrity and conduct necessary to satisfy the Company’s requirements.

1. Employees are expected to apply themselves earnestly to the interests of the Company.
2. Among other things, employees are expected to foster the business of the Company through courtesy, promptness and helpfulness in dealings with customers, suppliers, the public, shareholders and others on the Company's behalf.
3. Employees are expected to resolve enquiries and issues etc, expeditiously through exercise of their own responsibility or, where appropriate, through reference to others.
4. Employees should act in the performance of their duties in the capacity and manner authorised by the Company and with regard to the Company’s responsibilities to its customers and shareholders. (e.g. a duty of care).
5. This Code of Conduct is available to all employees of the Company, so that all persons know what is expected of them. However, failure to observe the standards of behaviour may attract disciplinary action. Such action ranges from counseling to dismissal.
6. If employees are unsure of any aspect of the Code they can discuss the issue with their supervisor. If they believe another person is breaching the standards of conduct they should discuss the matter without risk or fear of reprisal with their manager/supervisor or the CEO.

2. Laws and instructions

1. Employees shall observe all relevant communications and written instructions of the Company and shall obey every applicable instruction given by a person having authority to give an order or instruction.
2. The laws of Australia and those countries, in which the Company operates, shall be observed.
3. Employees shall not knowingly participate in or allow the company to become involved, directly or indirectly, in any illegal activity or transaction. If in doubt, advice should be sought from the employees Manager/Supervisor or from a Senior Executive.
4. Employees shall not seek or accept any bribe, commission or procurement fee, or share commission with an agent or any other person in connection with a sale, purchase, or any other activity or transaction arising in the course of the business of the Company, or concerning a service rendered by the Company.

3. Agent's Fees and Commissions

1. Commission or fee arrangements on behalf of the Company should only be made with companies, firms or individuals serving as bona fide commercial representatives, agents or consultants.
2. Enquiries should be made to ensure that such arrangements are not entered into with any company or firm in which an employee of the Company is known to have an interest.
3. Entering into such arrangements is not permitted unless the arrangement is permitted by law and has been specifically approved by the CEO.
4. All commission and fee arrangements should be by written contract.
5. Fees are to be reasonable and consistent with normal practice for the industry, the merchandise or product involved and the services rendered.
6. Payments must not be made in cash.

4. Conflict of Interest

1. Employees who are required to deal with external suppliers of goods and services to the Company, must avoid placing themselves in situations of potential conflict of interest. Suppliers include, but are not restricted to those from whom the company buys: merchandise for sale; equipment; maintenance and services; and consultancies.
2. A conflict of interest exists where an employee's loyalties are divided between personal interests and those of the Company. Employees shall give preference to the interests of the Company over their own, and therefore shall present and support the policies of the Company in dealing with a customer or supplier irrespective of their own views or interests.
3. An employee shall not place themselves in a position where their interest in a customer, supplier or any other party having dealings with the Company may conflict with their duty as an employee, without first making full disclosure to the Company.
4. An employee is generally not permitted to obtain money or any other reward from, or lend money or give any other reward to, a customer or supplier of the Company, or to place him or herself in the position where they may come under obligation to a customer or supplier. Employees may, however, accept small gifts or hospitality from customers or suppliers, but should use common sense in making decisions as to whether or not to accept these gifts or hospitality.
5. Where an employee or member of an employee's immediate family is a director of or has a pecuniary interest in a customer or supplier, unless the written consent of the CEO of the Company is obtained after full disclosure of the facts, the employee shall not be involved in the management of the customer or supplier's dealings with the Company or in making recommendations to or decisions on behalf of the Company in respect of that customer or supplier. For the purposes of this Code, the following are considered to be a "member of an employee's immediate family": spouse, de facto spouse, partner, child, parent, parent-in-law, brother, sister, and brother or sister-in-law".
6. Employees shall not guarantee or otherwise become surety for debts, or the performance of any obligation, of any other person (except a spouse or dependant) in relation to that person's dealings with the Company without written consent from the CEO.
7. All employees should ensure that their personal relationships with customers and/or suppliers do not influence or prejudice their obligations to the Company. They must not accept gratuities, and should use commonsense regarding gifts or hospitality.
8. All employees are required to complete and return to the Company a Code of Conduct declaration as periodically required by the Company.
9. If an employee's circumstances change at any time, a new Code of Conduct declaration is required to be submitted; this can be obtained from and returned to the Human Resources Manager.
10. Employees who may be aware of a potential or actual conflict of interest have a duty to raise the matter with their immediate supervisor or to communicate their concerns to the CEO.

5. Competitors

1. If employees have knowledge of commercially sensitive information about, or if they or a member of their immediate family has a financial interest in, a competitor of the Company or any of that competitor's businesses, he or she must disclose that interest.
2. Where the interest constitutes a conflict of interest, the employee should divest himself or herself of that other interest or, as the case may be, procure that the member of his or her immediate family does so.
3. An employee shall not make any disparaging, inappropriate or untruthful remarks about any of the Company's competitors, their products or services.

6. Confidentiality and Fidelity

1. It is a condition of employment that all Company employees agree to devote the whole of their energies and skills to the furtherance of the Company's interests during the usual business hours and whilst performing any work for the Company.
2. Employees are not permitted to divulge confidential information, sensitive data, programs, plans or objectives about the Company, any of its employees or customers and suppliers without appropriate authorisation from, as the case may be, a Company Executive, the customer or supplier, or by compulsion of law.
3. Employees shall not use for their own purpose confidential information, or intellectual property belonging to the Company gained in the course of their employment, including dealings between the Company and its customers or suppliers, or between the Company and, where applicable, any of its subsidiaries. This information always remains the property of the company.
4. Company employees are required to surrender any company property including memoranda, notes, files, sketches, records or plans relating to the business upon completion of employment with the Company.

7. Company Assets

1. Company assets including goods, money, equipment, corporate cards, intellectual property or the services of the Company must not be used for personal gain. This includes personal use of the Internet whilst at work.
2. Theft, pilferage or unauthorised removal of Company assets or of another employee's property from the premises and/or for personal use is strictly prohibited.
3. It is prohibited to transcribe or copy computer software programs regardless of whether or not they are copyrighted. No employee may install computer software without the express permission of the IT administrator.

8. Record Keeping

1. All entries and transactions of the company shall be brought to account in the records of the Company in an accurate and timely manner.
2. Employees must not destroy business documents and records that are required by law to be maintained for a statutory period, nor must any records be falsified or manipulated.

9. Professional (Personal) Behaviour

1. Employees shall act in a professional manner, consistent with their position. This requires them to take care in the discharge of duties and to adopt personal standards (including those in relation to the use of alcohol, drugs and gambling ) that do not in any way reflect adversely on the Company, or detrimentally affect their ability to perform their duties.
2. Employees are required to adhere to the Company Equal Employment Opportunity policy, ensuring the workplace is free from unlawful discrimination. Sexual harassment will not be tolerated within the Company.
3. Discrimination or harassment based on any ground recognised in the law of the State or country in which particular employees are engaged to work will not be tolerated. This includes discrimination or harassment based on race, colour, religion, gender, age, marital status, or disability.
4. In all matters pertaining to recruitment, promotion, transfer and personnel administration generally, patronage and favouritism are deemed unacceptable.

10. Dishonesty

1. The Company will not tolerate dishonesty on the part of any employee.
2. Employees shall be honest in all personal dealings involving the Company, its customers and suppliers.
3. An employee shall not knowingly conceal any fact he/she is aware of as an employee, which, if disclosed, may have an effect on any decision by, or course of conduct of, the Company.
4. Employees should be alert to prevent fraudulent activity against the Company, its customers or suppliers.
5. Employees shall report any knowledge of fraud, error, breach of law, or of a concealed practice against the interest of the Company. Suspicion of any such activity should be similarly reported. In the normal course, the report should be made to an immediate supervisor, or line manager, but may be made to any senior executive of the Company. If in doubt, the employee can report directly to the CEO.

11. Outside Employment

1. Employees are permitted to obtain supplementary employment outside the Company, or to engage in other occupations, providing the performance of their Company duties is not affected adversely; there is no conflict of interest; and such employment or occupation does not in any way reflect adversely on the Company.
2. An employee who participates in business activity for an outside company may not render service to the Company on that company's behalf.

12. Environment

1. All employees are responsible for maintaining and protecting the environment in which the Company conducts its business.
2. Employees should consider the impact of their workplace activities on the environment and the local community, including the way in which waste is disposed and natural resources utilised.