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Disclosure of Information
It is the Company's policy to make full, timely and complete disclosure of important information concerning the activities of the Company.

Except as required by law, the Company will not disclose confidential information, which includes all non-public information that might be of use to competitors or harmful to the Company or its customers, if disclosed. Confidential information is not to be disclosed by any director, officer or employee unless such disclosure is properly authorized or legally mandated. Questions regarding the appropriateness of disclosing particular information should be discussed with the Secretary.
 
Accounting Records and Practices
The Company's books and records will reflect, in an accurate and timely manner, all Company transactions. In particular, all funds and assets will be properly recorded.
 
Prohibited Payments
Directors, officers and employees are prohibited from paying or accepting any bribe, kickback or any other unlawful payment or benefit to secure any concession, contract or any other favourable treatment.
 
Fair Dealing
Each director, officer and employee shall endeavour to deal fairly with the Company's customers, suppliers, competitors and employees. No director, officer and employee is permitted to take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice.
 
Conflicts of Interest
A conflict of interest occurs when an individual's private interest interferes in any way - or even appears to interfere - with the interests of the Company as a whole. A conflict situation can arise when a director, officer or employee takes actions or has interests that may make it difficult to perform his / her Company work objectively and effectively. Conflicts of interest also arise when a director, officer or employee, or a member of his / her family, receives improper personal benefits as a result of his / her position in the Company. Loans to, or guarantees of obligations of, such persons are of special concern.

Conflicts of interest are prohibited. Every director, officer and employee must avoid any conflict of interest. Every director, officer and employee shall disclose all circumstances that constitute an actual or apparent conflict of interest. Disclosure shall be made, in the case of directors and officers, to the board of directors, and in the case of employees, to the CEO.
 
Corporate Opportunities
Directors, officers and employees are prohibited from: (a) taking for themselves personally opportunities that are discovered through the use of corporate property, information or position; (b) using corporate property, information of position for personal gain; and (c) competing with the Company. Directors, officers and employees owe a duty to the Company to advance its legitimate interests when the opportunity to do so arises.
 
Use of Company Property
The Company assets must not be misappropriated for personal use by directors, officers or employees.

Directors, officers and employees shall protect the Company's assets and ensure their efficient use. Theft, carelessness and waste have a direct impact on the Company's profitability. All Company assets should be used for legitimate business purposes.
 
Safety and Environmental Protection
Safety and environmental protection are fundamental values of the Company and every director, officer and employee has a role in ensuring the Company's operations comply with safety and environmental legislation and standards.

Each director, officer and employee is responsible for taking all prudent precautions in every activity to ensure both personal safety and the safety of others.
 
Fundamental Rights
The Company is committed to providing all employees a workplace that respects their basic human rights. Each director, officer and employee at the Company has the right to work in an environment that is free from discrimination and harassment, including sexual harassment. Every director, officer and employee is responsible for taking all reasonable precautions not to demonstrate behaviour that can be reasonably construed as discrimination or harassment.

The Company will take every incident of harassment or discrimination very seriously and any director, officer or employee that is found to have engaged in conduct constituting discrimination or harassment will be disciplined and, in appropriate circumstances, dismissed or removed from office.

The Company encourages reporting of all incidents of discrimination and harassment. Every employee has the right to pursue a complaint without reprisal, retaliation or threat of either, for doing so.
 
Responsibility

Each director, officer and employee must be familiar with and adhere to the provisions of this Code and to the standards set out in the applicable policies of the Company.

Failure to adhere to this Code may lead to disciplinary action, including dismissal or removal from office in appropriate circumstances.