Principle 3

Act ethically and responsibly

Code of Conduct

The Group’s objective is to conduct its business with the highest standards of personal and corporate integrity.  To assist employees in achieving this objective, the Group has developed a comprehensive Code of Conduct which guides the behaviour of directors, officers and employees (including senior executives) and demonstrates the commitment of the Group to ethical practices.  The Code of Conduct is incorporated as part of new employees’ induction training and an acceptance form is signed by new employees acknowledging their understanding and on-going compliance with the Code of Conduct and the Group’s policies and procedures.

The Code of Conduct states the values and policies of the Group and complements the Group’s risk management and internal control practices.  The Code of Conduct is reviewed annually and updated to ensure that it reflects current good practice and to promote the ethical behaviour of all employees.  Refer to the Group’s website at www.gwagroup.com.au under Corporate Governance Policies for a copy of the Code of Conduct.

Share Trading Policy

The Board has approved a Share Trading Policy which complies with the ASX Listing Rules.  The policy limits the trading periods for directors and senior executives in the Group’s securities to 30 days after each yearly/half yearly results announcement and Annual General Meeting, and provided they are not in the possession of unpublished insider information.

Outside of these trading periods, the directors, senior executives and other ‘potential insiders’ are prohibited from trading in the Group’s securities unless ‘exceptional circumstances’ exist and prior written approval has been obtained.  ‘Exceptional circumstances’ mean severe financial hardship or other circumstances considered to be exceptional, including a court order or court enforceable undertaking in a bona fide family settlement or some other overriding legal or regulatory requirement to transfer the Group’s securities.

The Share Trading Policy requires the directors to notify the Company Secretary within two business days after trading, to enable the Company Secretary to lodge the required disclosures with the Australian Securities Exchange.  Refer to the Group’s website at www.gwagroup.com.au under Corporate Governance Policies for a copy of the Share Trading Policy.