AGT Principle 3

Ethical Standards
All directors, managers and employees are expected to act with complete integrity and objectivity in all their activities related to the Company, striving at all times to enhance the reputation and performance of the Company. Every employee has a nominated supervisor to whom they may refer any issues or complaints arising from their employment. To further promote a culture within the Company where ethical standards are maintained in accordance with Company policy, the Company has established a Whistleblower Policy which ensures protection of individuals reporting any incidents of misconduct or unethical behaviour.

Conflict of Interest
Directors must keep the Board advised, on an ongoing basis, of any interest that could potentially conflict with those of the Company. The Board has developed procedures to ensure that directors disclose any potential conflicts of interest.

Where the Board believes that a significant conflict exists for a director on a Board matter, the director concerned does not participate in any discussion and voting on the applicable matter and, if considered appropriate, the director is requested not to be present whilst the matter is considered. Details of director related transactions with the Company are set out in Note 35 in the 2009 Annual Report.

Code of Conduct
The Company has established a Code of Conduct that embraces high standards of personal and corporate conduct. Each director, manager and employee has been advised that they must comply with this Code. The full Code may be viewed on the Company's website and it requires all directors and officers to:

A copy of the Code of Conduct is made available to all staff. The Code is reviewed regularly by the Board and processes are in place to communicate any amendments to the Code to all staff. New employees are issued with an employee handbook containing the Code of Conduct and prior to commencing their respective employment, they are required to certify that they have read and understood the requirements contained within it. The Company has established procedures to monitor compliance with the Code of Conduct.

In addition to the Code of Conduct and the Whistleblower policy, the Company also has policies which govern:

All employees are required to complete the harassment, discrimination and compliance training conducted by the Company.

Trading in Company Securities by Directors and Employees
The Company has in place a policy which outlines the rules that directors, senior executives and all employees must follow when dealing in the Company's securities. The policy also details the insider trading provision of the Corporations Act 2001 and is available on the website of the Company.

that directors, senior executives and employees may acquire shares in the Company, but are prohibited from dealing in Company shares or exercising options:
- whilst in possession of information, which if disclosed publicly, would be likely to materially affect the market price or value of those securities; and
- at any time outside a Window Period*, unless there are exceptional circumstances and in accordance with the procedure as laid down in the policy.
to raise the awareness of legal prohibitions on trading, including transactions involving associates, colleagues and external advisers;
to require details to be provided of any intended trading in the Company's shares as well as subsequent confirmation of the trade; and
to identify the process for unusual circumstances where discretions may be exercised in cases such as financial hardship.

* Window Period:
(a) commence on the day following the release of the Company's Half-Yearly and Preliminary Final Results and Dividend announcements for a 30 day period;
(b) commence on the day following the Annual General Meeting for a 30 day period; and
(c) during the offer or application period specified in a prospectus or supplementary prospectus issued for a new share issue.

The policy stipulates a number of notification and approval procedures that must be carried out before any director or employee can deal in securities of the Company. The Company has in place internal mechanisms to review compliance with the policy. An amendment to the Trading Policy was recently made in September 2009 which resulted in the window period commencing on the first trading day after the release of the Company's Half-Yearly and Preliminary Final Results and Dividend announcements. Further to this the Company Secretary is to notify each director when the ASX has received the relevant announcement and confirm that the window period will commence the following trading day.

• Complies with ASX Corporate Governance Council's Recommendations 3.1,3.2,3.3