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Ethical Standards

Promotion of Ethical and Responsible Decision-Making

Directors, officers, employees and consultants to the Company are required to observe high standards of behaviour and business ethics in conducting business on behalf of the Company and they are required to maintain a reputation of integrity on the part of both the Company and themselves.  The Company does not contract with or otherwise engage any person or party where it considers integrity may be compromised.

Directors are required to disclose to the board actual or potential conflicts of interest that may or might reasonably be thought to exist between the interests of the director or the interests of any other party in so far as it affects the activities of the Company and to act in accordance with the Corporations Act if conflict cannot be removed or if it persists.  That involves taking no part in the decision making process or discussions where that conflict does arise.

The board intends to formalise this code of conduct, and thereby comply with CGC Recommendation 3.1, as the scale of the Company’s operating activities increase. 

Securities Trading Policy

Directors are required to make disclosure of any share trading.  The Company policy in relation to share trading is that officers are prohibited to trade whilst in possession of unpublished price sensitive information concerning the Company.  That is information which a reasonable person would expect to have a material affect on the price or value of the Company’s shares.  The policy requires that an officer discuss the proposal to acquire or sell shares with the chairman or the company secretary prior to doing so to ensure that there is no price sensitive information of which that officer might not be aware.  The undertaking of any trading in shares must be notified to the company secretary who makes disclosure to ASX. 

Recognising the Legitimate Interests of Stakeholders

The Board recognises that its responsibilities extend beyond its shareholders to wider stakeholders including customers, suppliers, consumers, communities and regulators.  The Company is committed to providing an adequate level of detail for the benefit of all stakeholders, the accuracy in that detail, and to meeting principles of equity and fairness in all of its dealings.  

Given the Company’s recent formation and the scale of its operations to date a formal “code of conduct” has not been warranted.  Accordingly, the Company has not met CGC 10.1.