(adopted by the Board 19 September 2008)

1. Commitment to the Code of Conduct
The Company is dedicated to operating professionally and honestly when dealing with third parties including government authorities, creditors, joint venture partners and the community as a whole as well as other employees.

The Company is dedicated to delivering outstanding performance for investors and employees. The Company aspires to a leader in its field while operating openly, with honesty, integrity and responsibly and maintaining a strong sense of corporate social responsibility. The Company will consider the environment and ensure a safe workplace.

2. Responsibilities to Shareholders and the Financial Community Generally
The Company is committed to delivering value to its shareholders. The Board has instituted a policy to provide financial and non-financial information to its shareholders in a timely, truthful and accurate manner. The Board has a charter which states that the company complies with the spirit of the law as well as the letters of the law and regulations that govern shareholders’ rights.
The Company will report to the market and to shareholders financial information that is fair and accurate and in accordance with generally accepted guidelines, principles, standards laws and regulations of Australia.

3. Responsibilities to Third Parties
Each employee and each Director has an obligation to use their best efforts to deal in an honest manner with each other and with every third party. The Directors acknowledge that the reputation of the Company is to be built on acting honestly ethically and with a clear communication.

4. Employment Practices
The company will:
• Provide a safe workplace for its employees, compliant with all workplace health and safety laws.
• Promote equal opportunities for all employees.
• Provide equal opportunities for all employees.
• Not tolerate the offering or acceptance of bribes, inducements or unauthorised commissions by any of its employees or officers.
• Not tolerate the misuse of company assets or resources and employees will not use such assets or resources for their own benefit.
• Be aware of potential conflict of interest between employees and the company’s business.
• Not tolerate employees being under the influence of illegal drugs or alcohol while on the Company’s premises, property or on Company business.

The Directors at the time of the adoption of this policy are aware that the Company only employs four employees and consults with five consultants. As a result more issues concerning employment practices will be addresses while the company grows.

5. Responsibilities to the Community
The Company is committed to respecting and abiding by all applicable environmental laws and regulations. The Company encourages all employees to have regard for the environment when carrying out their duties.

6. Responsibility to the Individual
The Company receives private information from its employees. Unless required by law, such personal information will not be shared with a third party without the consent of the employee.

All employees must maintain the confidentiality of business information and protect this information from disclosure. This obligation of confidentiality applies while an employee as well as after ceasing to be an employee of the company. Information that is to be kept confidential includes:
• Internal documents
• Confidential or proprietary information relating to the Company’s business
• Technological and other knowledge
• Processes
• Computer passwords
• Computer software
• Business strategies and plans
• Information concerning the Company’s operations, suppliers and employees.

Employees and Directors must avoid conflict between personal interest and the interests of the Company. Where an employee is concerned that there may be a conflict of interest it should be discussed with the Managing Director as soon as possible.