Code of Business Conduct

1. Purpose

The purpose of this 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 stakeholders. 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



    1. setting the tone of legal, ethical and moral conduct to ensure that the Company is considered reputable by the industry and other outside entities; and
    2. ensuring that all employees are aware of the Code of Conduct.



    1. undertaking their duties and behaving in a manner that is consistent with the provisions of the Code of Conduct;
    2. the effective implementation, promotion and support of the Code of Conduct in their areas of responsibility; and
    3. ensuring employees under their control understand and follow the provisions outlined in the Code of Conduct.



    1. undertaking their duties in a manner that is consistent with the provisions of the Code of Conduct;
    2. reporting suspected corrupt conduct; and
    3. reporting any departure from the Code of Conduct by themselves or others.

3. Personal and Professional Behaviour

When carrying out your duties, you should:

    1. behave honestly and with integrity and report other employees who are behaving dishonestly;
    2. carry out your work with integrity and to a high standard;
    3. operate within the law at all times;
    4. follow the policies of the Company; and
    5. 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.

    1. 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;
      7. and offer of an inducement.
    2. 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.
    3. 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.
    4. 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.

    1. Employees must not make official comment on matters relating to the Company unless they are:
      1. authorised to do so by the Chair and/or Chief Executive Officer; or
      2. giving evidence in court; or
      3. otherwise authorised or required to by law.
    2. Employees must not release unpublished or privileged information unless they have the authority to do so from the Chair and Chief Executive Officer.

6. Intellectual Property/Copyright

Intellectual property includes the rights relating to scientific discoveries, industrial designs, trademarks, service marks, commercial names and 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 or Chief Executive Officer before making any use of that property for purposes other than as required in their role as employee.

7. 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.

8. 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:

    1. official misconduct;
    2. bribery and blackmail;
    3. unauthorised use of confidential information;
    4. fraud; and
    5. 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.

9. Health, Safety, Environment and Community

It is the responsibility of all employees to act in accordance with the applicable occupational health and safety legislation, regulations and policies and to use security and safety equipment provided.

Specifically all employees are responsible for safety in their work area by:

    1. following the safety and security directives of management;
    2. advising management of areas where there is potential problem in safety and reporting suspicious occurrences; and
    3. minimising risks in the workplace.

It is the responsibility of all employees to act in accordance with applicable environmental legislation, regulations and policies.

Our approach is to ensure that the health, safety, environment and community (HSEC) impacts associated with operations related to our business are minimised and managed. In meeting this, we identify, assess and manage our environmental risks, and set and seek to achieve targets that promote the efficient use of resources. We seek to engage regularly, openly and honestly with our stakeholders, and particularly with those people affected by our operations.


      • Take responsibility for ensuring that our operations meet applicable legal standards;
      • Engage with our stakeholders and take their views into account in our decision‐making;
      • Handle, transport and arrange for the disposal of materials in a safe, environmentally and socially responsible manner;
      • Stop any work that may contribute to a significant environmental or community incident;
      • Report to your manager any accident, incident, spill or release of material so that appropriate action can be taken to prevent, correct and/or control those conditions;
      • Encourage our suppliers, joint venture partners and customers to engage in responsible stewardship practices to minimise the potential for harm in the lifecycle of our products.


      • Ignore a potential or actual environmental incident or assume someone else will report it;
      • Undertake work that has the potential to significantly impact on the environment unless you are trained and competent to do so;
      • Engage contractors, suppliers or joint venture partners without an assessment that takes account of their HSEC risks, processes and performance.

10. 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.

11. 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.

12. Insider Trading

All employees must observe the Company's "Trading Policy".

13. Responsibilities to Investors

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

14. 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 and possibly dismissal.

15. Reporting Matters of Concern

Employees are encouraged to raise any matters of concern in good faith with the Company Secretary or Chief Executive Officer, without fear of retribution.


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