Code of Conduct

1. Introduction

   1. The Company is committed to being a responsible corporate citizen am dos committed to the following principles:
      1. the creation of an environment of trust and mutual respect;
      2. demonstrating the twin principles of honesty and integrity through communications and actions in all the Company's business dealings;
      3. championing a culture of safety and environmental excellence;
      4. demonstrating a strong bias toward continuous improvement in operations and personal standards; and
      5. increasing shareholder value through the delivery of superior business results.
   2. Implicit in the core principle of trust and mutual respect is an absolute requirement to comply with the laws and legal obligations of each country in which the Company operates.
   3. These principles extend to all employees, officers, contractors, sub contractors and agents.
   4. All employees, officers, contractors, sub contractors and agents should become familiar with the specific Company policies published on the Company's internet site.

2. Business Integrity

   1. The Company (which includes Directors, senior executives, employees, agents and contractors) is committed to the following principles:
      1. to comply with the laws and legal obligations of each country in which the Company operates;
      2. to increasing shareholder value and to ensure shareholders are fully informed as to the true position and performance of the Company through, timely and accurate disclosure of information;
      3. to the disclosure and management of any direct, indirect, actual, potential or perceived conflict of interest which occurs internally or externally;
      4. to not directly or indirectly offer, pay, solicit or accept bribes, secret commissions or other similar payments or benefits in the course of conducting business;
      5. to not divulge any information about the Company without appropriate authorisation;
      6. to not participate in insider trading by using knowledge not generally available to the market to gain an unfair advantage in the buying or selling of securities;
      7. to provide appropriate means by which employees may raise concerns regarding illegal conduct or unethical behaviour and will support employees who report violations in good faith. The Company will thoroughly investigate all such reports and take any necessary action; and
      8. to act as a responsible corporate citizen and actively support the communities in which the Company operates and to actively contribute to the needs of those communities.

3. Environment

   1. The Company undertakes to minimize its impact on the environment and to achieve a high standard of care for the natural environment in all of the activities in which it engages.
   2. The Company will:
      1. seek continuous improvement in environmental processes, waste management and the use of resources, performance and production; and
      2. communicate with shareholders, the community and governments about the environmental performance of the Company, and contribute to the development of laws and regulations that may affect the business.

4. Safety and health

   1. The Company's aim is to achieve:
      1. an incident free workplace by ensuring all duties are performed correctly from the outset; and
      2. the highest standard of safety and health in all the activities in which the Company is engaged and to comply with all appropriate laws and regulations.
   2. The Company will provide a safe and healthy working environment for all employees, contractors and visitors and seek continuous improvement in all aspects of work processes and procedures. The Company will not tolerate any risk to the health and safety of employees caused by employees presenting to work while under the influence of drugs or alcohol.

5. Fair trading and dealing

   1. The Company aims to maintain the highest standard of ethical behaviour in its business dealings.
   2. All Directors, senior executives, employees, agents and contractors are expected to:
      1. behave with integrity in their dealings with customers, competitors, shareholders, government, employees, suppliers and the community; and
      2. perform their duties in a professional manner and act fairly, honestly and objectively, striving at all times to enhance the Company's reputation and performance.

6. Employment

   1. The Company is committed to the following employment practices:
      1. equal employment opportunity and decisions on hiring, salary, benefits, advancement, termination or retirement will be based solely on the employee's ability to do the job. There will be no unfair or unlawful discrimination;
      2. each employee will work in an environment free from harassing behaviour;
      3. the Company will promptly investigate all allegations of harassment, bullying, victimisation, or discrimination and will take appropriate corrective action;
      4. the Company will comply with all labour awards, collective agreements and individual employment contracts; and
      5. the Company will adopt best practice job evaluation methodology and generally position its remuneration structures at the average of the market. The Company will reward for exceptional performance through the use of appropriate incentives.

7. Compliance with laws and regulations

   1. The Company is subject to various legal requirements in relation to the conduct of the Company's operations. These might relate to financial, disclosure, fair trading, environmental, occupational health and safety, trade practices, and other requirements.
   2. The Company is committed to the compliance with the duties and obligations which apply to it under any laws, legislation or regulations of any jurisdiction relevant to the business of the Company.
   3. Directors and officers will comply with the duties they owe as a fiduciary of the Company.

8. Improper use or theft of Company property

   1. The Directors, officers, senior executives, employees, agents and contractors are responsible for protecting the Company's property and assets and will safeguard them from loss, theft and unauthorised use.
   2. The Company's property and assets include but are not limited to, cash, securities, business plans, third party information, intellectual property (computer programs, software, models and other items), confidential information, office equipment and supplies.

9. Anti-bribery and foreign corruption practices

   1. The Company will ensure that all of its representatives are informed of all laws, legislation, regulations and customs relevant to each country in which the Company operates.
   2. When conducting business in other countries, the Company will be sensitive to foreign laws and customs that apply to the Company's operations and dealings with employees, contractors, agents, customers, suppliers, business associates, competitors, financiers, governments and other officials.
   3. The Company commits to upholding the integrity of the Company in the Company's dealings in all other countries as diligently as the Company would in Australia.
   4. The Company, (its employees, agents, contractors and third parties employed or appointed by the Company to represent its interests), will not make or accept bribes, pay-offs, kick-backs or anything of value in business dealings.
   5. Bribes, pay-offs and kickbacks occur when a person offers, makes, authorises, requests or accepts payment of money or anything of value, either directly or indirectly, to:
      1. illegally influence the judgement or conduct to ensure a desired outcome from a customer, supplier or competitor;
      2. influence a decision of, or gain a benefit from, any government official, political party or candidate for public office; or
      3. gain an improper advantage.

10. Compliance with the Code

    1. Each Director, officer, senior executive, employee, agent and contractor is responsible for their actions and accountable for their consequences. Each Director, officer, senior executive, employee, agent and contractor must understand the intent of this Code in order to support the core principles and requirements of the Company.
    2. All employees and officers will be notified of any changes made to the Code. Any changes to the Code are to be authorised by the Board and will be released through the Company's usual communication channels.