The Company expects all Directors, employees and third parties representing the Company to follow the Company’s principals and uphold the highest moral, legal and ethical standards. The Board have set the following general principles:

3.1 Honesty, integrity and fairness
Honesty, integrity and fairness are integral to the way the Company operates and should guide all decision making. Directors, employees and any other party representing the Company must, at all times:

(a)  act in the best interests of the Company;
(b)  act honestly and with high standards of personal integrity;
(c)  comply with the laws and regulations that apply to the Company and its operations;
(d)  act ethically and not enter into any arrangement which may negatively impact the Company’s operations;
(e)  act in a way which does not take advantage of their position within the Company;
(f)  act positively to protect and preserve the assets, including intellectual property, of the Company; and
(g)  comply with this Code.

Disciplinary and/or legal action will be taken where an individual or group of individuals do not comply with relevant laws, regulations or engage in behaviour which is either unethical or dishonest or represents other breaches of this code.

3.2 Compliance with Laws
The Company’s business activities will be conducted in accordance with the laws and regulations of the countries in which the Company operates.

The Company operates in a highly regulated business environment and its activities are subject to numerous laws, regulations and licensing conditions. The Company requires its employees to familiarise themselves with the laws, regulations and licence conditions applicable to their activities. If in doubt, employees are required to seek advice.

3.3 Fair Dealing
The Company will compete effectively and fairly in markets in which it operates. It will be honest, ethical and responsible in the way it presents products and services to its business partners and customers, uses its market power and its pricing practices.

The Company will be fair and honest in its relationship with suppliers and contractors from selection through to payment and termination of the relationship.

The Company will not engage in unlawful anti-competitive business practices or conduct, nor will it enter into any unlawful anti-competitive agreements.

Corrupt practices are unacceptable and will not be tolerated.

3.4 Confidentiality and Protection of Company Assets
The Company will maintain the confidentiality and privacy of all information that would reasonably be considered to be confidential and private including, but not limited to, employee details, intellectual property, performance and financial details.

Misappropriation of property, including intellectual property of all kinds, owned by the Company, employees, business partners, customers or suppliers will not be tolerated. Any misappropriation is required to be immediately reported and properly investigated. Appropriate disciplinary and/or legal action will be taken.

3.5 Conflicts of Interest
Directors and employees are required to act in the best interests of the Company.

Directors and employees are not permitted to engage in activities that involve, or could appear to involve, a conflict between their personal interests and the interests of the Company. Areas where conflicts may arise include share ownership, direct or indirect personal interest in contracts, dual employment or seeking or accepting gifts or entertainment beyond levels considered reasonable in the Company’s business environment.

Any actual or potential conflicts of interest are required to be fully disclosed to appropriate management.

3.6 Shareholders and the Financial Community
The Company is committed to increasing shareholder value in conjunction with its responsibilities to act as a good corporate citizen.

The Company is committed to making sure that accurate information about its affairs is made available to its stakeholders in a timely way.

3.7 Fair and safe workplace
The Company is committed to providing a fair and safe workplace that is free of bias and discrimination. Directors and employees are not permitted to engage in, condone, or fail to act against activities that place the physical or mental safety of others at risk or that amount to bias, prejudice or discrimination against others on the basis of beliefs or background.

Directors and employees should expect honest, fact based, objective performance feedback and management against appropriately defined performance goals and expectations and nothing in this policy shall be taken to prevent or discourage this.

3.8 Equal Opportunity
The Company aims to:
(a)  make human resource decisions on the basis of merit with the information available to it; that is, employment decisions will be made on the basis of the possession of skills, experience, qualifications and characteristics relevant to the performance of work;
(b)  ensure unlawful discrimination does not occur in the workplace, in the provision of goods and services within its venues or in circumstances arising out of an employment relationship; and
(c)  maintain a workplace and public environment free from sexual and other unlawful harassment, unlawful discrimination, victimisation and vilification and other offensive conduct.

The Company will comply with relevant and applicable equal opportunity, anti-discrimination and affirmative action laws and regulations.

The Company requires all employees to follow all reasonable directions of their direct supervisor and to comply with all applicable policies and laws and reasonable standards of behaviour.

3.9 Health, Safety and Environment
The Company aims to provide a safe environment in which to work and for customers and suppliers to visit.

The Company requires all employees to follow all reasonable directions from their direct supervisor; to comply with all applicable occupational, health, safety and risk management policies of the Company and laws; and to work safely and apply appropriate practices to endeavour to protect the health, safety and wellbeing of themselves, other employees, customers and suppliers.

The Company endeavours to reduce the environmental impact of its business activities and will seek to do this through continual improvement of environmental performance, protection and safety.

The Company is committed to providing effective support and training for its employees to assist them in their responsibilities of ensuring a safe workplace and to reduce the environmental impact of their activities.

3.10 Bribes and Financial Inducements
The Company will not directly or indirectly offer, pay, solicit or accept bribes.

Directors and employees of the Company must not receive personal financial rewards or inducements in return for making particular business decisions. Directors or employees must not accept gifts or other benefits where doing so may influence, or be seen as influencing, the exercise of objective business judgement in decision making.

3.11 Political Donations
The Company does not affiliate itself with any political party and does not make payments to political parties.