The Company is committed to conducting business in accordance with the highest standards of business integrity and complying with the applicable laws, rules and regulations. The Board establishes a code of conduct and ethics for the Company and together with Management implements its policies and procedures, which include managing conflicts of interest, preventing the abuse of power, corruption, insider trading and money laundering.

Core Areas of Conduct

a)    General Conduct

1. Upholding the Law: The Company is committed to conducting its business affairs with honesty and integrity and in compliance with all applicable laws, rules and regulations. The Company requires all its Directors to strictly comply with all the applicable laws, rules and regulations and exercise honesty, objectivity and diligence when conducting business for the Company.
2. Honesty and Integrity: Directors must act with integrity, including being honest and  candid, and adhere to a high standard of business ethics. Involvement or even attempted involvement in dishonest activity is unacceptable and may result in being removed from the Board.
3. Full and Fair Disclosure: The Company is committed to making timely and accurate disclosure of all material information in a fair and timely manner in accordance with applicable laws, rules and regulations.

If a Director becomes aware of a materially inaccurate or misleading  statement in any reports or documents or any public communication made by the Company, the Director must report it immediately to the Chairman of the Board and Audit Committee.  

b)    Conflict of Interest

Directors are required to act in good faith and in a manner which is responsible and in accordance with high standards of honesty, transparency and accountability.

A conflict of interest occurs when a Director’s private or personal interest interferes, or may appear to interfere with the interests of the Company. A conflict of interest may also rise when a Director acts or has interests that may make it difficult to perform his or her duties and responsibilities objectivity and effectively. Directors must not use their positions in the Company or misuse information gained in the course of their duties or employment for personal benefits or for private gain.

A Director should seek the advice of the Board Chairman or Audit Committee Chairman with any questions or concerns and must promptly disclose any material transaction or relationship that reasonably could be expected to give rise to an apparent or actual conflict. Nevertheless, any Director involved in any conflict of interest or potential situations should withdraw from any decision relating thereto.
   
The following are examples of situations which may constitute a conflict of interest

1. Corporate Business Opportunities: Directors owe a duty to the Company to advance its business interests when the opportunity to do so arises. Directors are prohibited from appropriating corporate business opportunities for themselves that are discovered through the use of the resources or information of the Company or their position as Directors.  
2. Business Activities Outside of the Company: as a general rule, the Company expects its Directors to avoid any outside activity, employment, position, association or investment that might interfere or appear to interfere with the independent exercise of a Director’s judgment regarding the best interests of the Company.
3. Gifts, Benefits, Entertainment and Services: Directors may not offer or receive gifts, benefits, entertainment or services, in cash or kind, to or from persons or entities who deal with the Company in those cases where such gift, benefit, entertainment or service is being made to influence Directors’ actions as members of the Board, or where acceptance of the gifts could create the appearance of a conflict of interest.

c)    Confidentially

1. Propriety and Confidential Information: Directors must maintain the confidentially of information entrusted to them, from whatever source, in their capacity as a Director, except where disclosure is approved by the Company or if such information is already in the public domain. No Director shall use the proprietary and confidential information of the Company for his or her own personal benefit or to benefit persons or entities outside the Company nor disclose proprietary and confidential information outside the Company, either during or after his or her service as a Director of the of the Company, except with the authorisation of the Board or as may be otherwise required by law.
2. Trading on Inside Information: It is the personal responsibility of each Director to adhere to the standards and restrictions imposed by the laws, rules and regulations relating to insider trading. It is against the Company’s policy for a Director to profit from undisclosed information relating to the Company. Directors are prohibited to trade in securities or to provide information to others to trade in securities of the Company on price sensitive non-public information until the inside information is publicly released. Any Director who is uncertain about the rules involving a purchase or sale or other dealings in securities of the Company should consult the Company Secretary before making any personal transaction.
3. Business Records and Control: Directors must exercise care and diligence in record keeping policies and procedures relating to the records of the Company, never make or knowingly permit the making of false or misleading entries in the books and records of the Company, never destroy, alter or falsify or knowingly permit the destruction, alteration or  falsification of any records relating to the Company, that are potentially relevant to a violation of law or any litigation or pending threatened or foreseeable government or judicial investigation or proceeding.

d)    Protection of Assets

All Directors are expected to exercise their business judgment in a manner that protects the assets of the Company and promotes their efficient use. All assets of the Company are to used for legitimate business purposes.

This Code of Conduct and Ethics had been reviewed and adopted by the Directors on 29 March 2018.