Ethical Standards

All Directors and employees are expected to act with the utmost integrity and objectivity and to comply at all times with the existing laws governing its operations. In addition, they are also expected to conduct the Company's activities in keeping with the highest legal, moral and ethical standards.

Conflict of interest

In accordance with the Corporations Act 2001 and the Company's Constitution, Directors must keep the Board advised, on an ongoing basis, of any interest that could potentially conflict with those of the Company.

Where the Board believes that a significant conflict exists for a Director on a Board matter, the Director concerned does not receive the relevant Board papers and is not present at the meeting whilst the item is considered.

Details of Director related entity transactions with the Company and Consolidated Entity are set out in the annual financial statements.

Code of conduct

All employees and Directors are required at all times to act in accordance with the Consolidated Entity's Code of Conduct, which prescribes standards of behaviour to be maintained in relation to:
  • compliance with laws and regulations;
  • political contributions; 
  • unacceptable payments;
  • giving and/or receiving gifts;
  • protection of assets;
  • proper accounting;
  • dealing with auditors;
  • conflicts of interest;
  • the use of inside information;
  • share trading;
  • alcohol and drug abuse;
  • equal opportunity and discrimination;
  • environmental responsibilities;
  • occupational health and safety; and
  • economy and efficiency. 

Share trading

Whilst the Board encourages its Directors and employees to own securities in the Company, it is also mindful of its responsibility that the Company comply with the Corporations Act 2001 pertaining to “insider trading” and “its proper duties in relation to the use of inside information”.

To ensure compliance with the relevant requirements of the Corporations Act 2001, the Company has established a policy on share trading in the Company's securities by Directors and employees which requires that:  

  • Directors and employees must notify the CEO of their intent to trade the Company's shares and confirm that they are not in possession of any material inside information;
  • trading in the Company's shares is prohibited at the following times:
    • 10 days prior to the release of any quarterly report by the Company, which is normally one month following the end of each calendar quarter; and
    • when in possession of unpublished price sensitive information (“inside information”) which might or might not be generally available, that may materially affect the price or value of the Company's shares; and
  • active trading in the Company's shares, with a view to derive profit related income, is prohibited at all times.