1. In all the Company’s operations, it is important to retain a set of core values and approaches to the process of doing business. The Company demands and maintains the highest ethical standards in carrying out its business activities. Corrupt practices of any sort will not be tolerated. The Company will monitor ethical performance regularly.

2. The Company will provide products and services giving good value and consistent quality, reliability and safety.

3. Public statements, whether advertising/investor relations or other, will not contain untruths, concealment or overstatement.

4. The Company will avoid practices which seek to increase sales by any means other than legitimate merchandising efforts. Such other means include, but are not limited to, acts that could be construed as bribery.

5. Where information is provided to Company executives on a confidential basis, the confidentiality of such information will be maintained.

6. Relations with employees are based on respect for the dignity of the individual. Accordingly:

• the Company will recruit and promote employees on the basis of their suitability for the job without discrimination in terms of race, religion, national origin, colour, gender, age, marital status or disability unrelated to the task in hand;
• the Company will seek to provide a clean, healthy and safe work environment in line with best industrial practice;
• the Company will seek to maintain a framework of fair and just remuneration policies and structures;
• the Company will not tolerate any sexual, physical or mental harassment of its employees.

7. Any personal interest or that of a member of one’s immediate family in relation to the Company’s business must be disclosed. This conflict of interest could include directorships, significant shareholdings and employment of family members. Employees should not act for personal gain.

8. The Company undertakes to maintain good relationships with its suppliers including:

• pay its suppliers in line with accepted business practice and according to agreed terms of trade;
• whilst taking proper advantage of the Company’s purchasing volumes, not to abuse the purchasing power of the Company;

9. The receipt of gifts or favours by employees can give rise to embarrassing situations and may be seen as an improper inducement to grant some concession in return to the donor. The following principles should be observed:

• gifts or favours must not be solicited;
• gifts of money must never be accepted;
• reasonable small tokens and hospitality may be accepted provided they do not place the recipient under any obligation, are not capable of being misconstrued and can be reciprocated at the same level;
• as a guideline, the value of the token/hospitality should not exceed USD$250 (or such higher level as might be approved by the Chief Executive).

10. The Company will take into account the concerns of the wider community including both national and local interest, including:

• environmental;
• charitable.

11. The Company will compete vigorously but fairly.

12. The Company will respect the traditions and cultures of each country in which it operates. It will not knowingly break the law. Where business practices differ in different countries in which the Company operates, it will favour consistent procedures among subsidiaries and associates. It will work for multilateral action aimed at achieving a high common standard.

13. It is unlawful for any officer or director (or anyone acting under their direction) to take action to fraudulently coerce, manipulate or mislead the Company’s auditors for the purpose of rendering its financial statements materially misleading.

September 2002
(revised October 2003)