1. Maintain an internal management structure for environmental issues which includes clearly defined responsibilities.

We are committed to:

1. Develop a work space where there is mutual trust and respect, free from bullying and harassment, where every person feels responsible for the performance and reputation of our company.

2. Recruit, employ and promote employees on the basis of objective criteria and the qualifications and abilities needed for the job to be performed in line with our Equal Opportunities Policy.

3. Maintain good communications with employees through our information and consultation procedures.

4. Provide our employees with suitable training and assisting them in realizing their potential.

5. Ensure the privacy and confidentiality of our employees’ personal information is respected.

6. Suitably reward our employees for their contribution to the success of the business.

7. Provide mechanisms whereby employees can raise legitimate concerns confidentially regarding malpractice and ensuring no one will be victimized for a report made in good faith.

8. Provide employees with the appropriate information and training to comply with this Code and the associated policies.

9. Seek to protect our employees from third party abuse that might be injurious to their safety, health or well-being.

B.2  HEALTH and SAFETY

Employees recognize that in addition to minimizing the incidence of work-related injury and illness, a safe and healthy work environment enhances the quality of products and services, consistency of production and worker retention and morale. Employees also recognize that ongoing worker input and education is essential to identifying and solving health and safety issues in the workplace.

B.2.1  Occupational Safety of employees

Employee exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicles, and fall hazards) are to be controlled through proper design, engineering and administrative controls, preventive maintenance and safe work procedures (including lockout/tagout), and ongoing safety training. Where hazards cannot be adequately controlled by these means, employees are to be provided with appropriate, well-maintained, personal protective equipment. Employees shall not be disciplined for raising safety concerns.

We are committed to creating and maintaining a safe and healthy working environment for our employees, customers and the community. Our commitment to ensuring the safety and security of our employees is set out in our internal management.
We strive to avoid emergency situations but recognize the need to be prepared. We are committed to having effective emergency response procedures in place.

B.2.2  Pollution Prevention and Resource Reduction

Waste of all types, including water and energy, are to be reduced or eliminated at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials.

B.2.3  Hazardous Substances

Chemical and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

B.3  Ethical conduct in business relationship

This Code of Business Ethics sets out the standards we expect from our employees in their internal and external dealings with colleagues, customers, stakeholders and third parties.

B.3.1  Basic Standards of Conduct

We will conduct every aspect of our business with honesty, integrity and openness, respecting human rights and the interests of our employees, customers and third parties.
We will respect the legitimate interests of third parties with whom we have dealings in the course of our business.
We will maintain the highest standards of integrity – for example, we will not promise more than we can reasonably deliver or make commitments we cannot or do not intend to keep.

B.3.2  Personal Conduct

All employees are expected to behave in accordance with the principles set out in this Code of Business Ethics.
Employees are expected to protect and not misuse company assets such as buildings, vehicles, equipment, cash and procurement cards.
Employees are expected to use e-mail, internet, IT and telephones in a manner appropriate for business purposes in line with the principles contained in this Code and any applicable IT policies.

B.4  Prevention of corruption

B.4.1  Bribery

No Group employee or individual or business working on our behalf must accept or give a bribe, facilitation payment or other improper payment for any reason.
This applies to transactions with government officials, any private company or person anywhere in the world. It also applies whether the payment is made or received directly or through a third party.
The Group shall ensure that adequate procedures are in place to prevent the risk of bribery and that these are effectively communicated and implemented across the Group in line with the requirements.

B.4.2  Gifts, Entertainment and Improper Payments

Accepting or giving any entertainment or gift that is designed to, or may be seen to influence business decisions, is not acceptable. No Group company or employee shall offer, give, seek or receive, either directly or indirectly, inducements or other improper advantages for business or financial gain. If an employee is in any doubt as to whether he or she may accept an offer, that employee should discuss the issue with his or her manager.

B.4.3  Conflicts of Interest

While we respect the privacy of our employees, all Group employees are expected to avoid personal relations, activities and financial interests which could conflict with their responsibilities to the Group.
Group employees and consultants must not seek gain for themselves or others through misuse of their positions or company property.
All actual and potential conflicts (including those arising from the activities or interests of close relatives or partners) should be disclosed to and discussed with an employee’s manager.
Employees who have access to price sensitive information are prohibited from being involved in dealings in the Group securities unless given clearance by the Chief Executive Officer. There should be no unauthorized disclosure of price sensitive information to third parties.

B.5  Competition rules

B.5.1  Business Integrity

We aim to develop strong relationships with our suppliers, stakeholders and others with whom we have dealings, based on mutual trust, understanding and respect. In those dealings, we expect those with whom we do business to adhere to business principles consistent with our own. We will conduct our operations in accordance with the principles of fair competition and applicable regulations.
The Group’s accounting and other records and supporting documents must accurately describe and reflect the nature of the underlying transactions. No unrecorded account, fund or asset will be established or maintained.
We will comply with the laws and regulations applicable wherever we do business. We will obtain legal advice where felt necessary to comply with this commitment.
We will review and track our business risks including social and environmental risks.
The Group will not facilitate, support, tolerate or condone any form of money laundering.
To ensure that our business is run in an ethical and effective manner we will maintain internal controls.

B.5.2  National and International Trade

We will seek to compete fairly and ethically within the framework of applicable competition and anti-trust laws and we will not prevent others from competing fairly with us. We will comply with all applicable export control laws and sanctions when conducting business around the world.