Code of Ethics

Code of Business Conduct and Ethics

The Company and its employees are committed to a culture of honesty, integrity, open communication and accountability through a spirit of teamwork and high standards of professional and ethical conduct.

Acting Responsibly

Employees shall act responsibly, in accordance with the standards established by the Company, abiding by the laws and accepted practices of the business environment in which the Company operates.

Drinking and driving shall be avoided.

Operating Fairly

Employees will act with integrity and honour the Company’s contractual obligations. They will compete vigorously in the Company’s best interests, and will engage only in practices which are legal and ethical.

Maintaining Objectivity

Employees will avoid personal conflicts of interest. Judgments made in the Company’s business dealings will be consistent with the Company’s best interests and will be independent of all personal interests. Employees shall not enter into any activities that will compete with, undermine or discredit the Company, or other employees of the Company.

Nepotism shall be avoided.

Maintaining Confidentially

Employees shall work to protect the Company’s assets and ensure their efficient and appropriate use. Employees shall maintain all sensitive information in a confidential manner during and subsequent to their employment. Proprietary information shall remain the property of the Company.

Respecting Others

The work environment shall be free from discrimination and harassment and employees shall treat colleagues and those with whom they interact with respect, dignity, fairness and courtesy.

The Company will not condone inappropriate conduct and shall develop procedures to enable employees to report such irregularities or wrongdoings without repercussion.

Employee behaviour at staff functions shall be professional and respectful.

Acting with Corporate and Social Responsibility

Employees shall act in a responsible manner, utilizing the Company’s assets for business purposes only and shall provide for a safe workplace with respect for the environment.

Employee theft shall be immediate grounds for dismissal.

The Company will operate to earn a profit for its shareholders and partners while at the same time adding value to society. It will support the communities in which it operates and encourages the same of its employees.

Observing Good Governance

The Company shall respect good corporate governance practices so as to provide for adequate Board oversight and control. Strategies of the organization and the risks associated with these strategies should be understood, and appropriate reporting and control systems should be in place to disseminate information on a timely basis so as to enable employees and Directors to make informed decisions.

Communications with the media shall be made only by the CEO or his designate.