SHARE DEALING POLICY
The Company has a share dealing policy requiring all Directors and senior executives to obtain prior written clearance from either the Chairman or the Chief Executive Officer to deal in the Company’s shares. The Chairman requires prior written clearance from the Chairman of the Audit Committee. Close periods (as defined in the share dealing policy) are observed as required by MAR and other rules that apply to the Company. During these periods, the Company’s directors, executives and inside employees are not permitted to deal in the Company’s securities. Additional close periods are enforced when the Company or its applicable employees are in possession of inside information.
The Company has adopted an Anti-Bribery Policy and procedures, which apply to the Group, its officers and staff anywhere in the world. The policy and procedures have been developed following an assessment of the risks applicable to the Group’s business and include a process for reporting suspicious conduct, financial limits on gifts and hospitality, procedures for financial record-keeping and for dealing with contracts with third parties, and a prohibition on charitable or political donations without Board approval.
CFO, Pete Gardner is the Group’s Anti-Bribery Officer and oversees the day-to-day operation of the Anti-Bribery Policy and procedures. The Board will also regularly reviews the operation of the Anti-Bribery Policy and procedures and the Anti-Bribery Officer will report to the Board on any specific issues that may arise.
All personnel are required to receive guidance and training in relation to the Group’s Anti-Bribery Policy and procedures. Senior staff have already received this training, and training for junior staff continues as an ongoing process.
The Anti-Bribery Officer also undertakes due diligence on third parties as appropriate that are to be engaged by the Group to do business on its behalf. The Group will expect such third parties to take account of the Anti-Bribery Policy and to act in accordance with its provisions.
The company has a Whistleblowing Procedure, which is applicable to all officers, employees, consultants, third-party agents, subsidiaries, JV Partners and Directors, and aims to create a communication and reporting system that allows employees and others to raise serious concerns about possible fraud, crime or other serious risk to the Company or its stakeholders.