ETHICS

CODE OF ETHICS

AECI and all its businesses are committed to a policy of fair dealing and integrity in the conduct of their businesses. In support of the above, the Company has adopted a formal Code of Ethics with which all directors and employees are required to comply. New employees also receive copies of the Code and, to maximise the updated Code's accessibility, it has been made available on AECI's intranet and on the intranets of operating businesses, where available. The Code can only be amended by the Board which reviews the Code periodically to ensure that it remains current and relevant to AECI's businesses.

The Code addresses the following:

• compliance with laws and regulations;
• conflict of interest: outside activities, employment and directorships; relationships with clients, customers and suppliers;
• business practices: gifts, hospitality and favours; remuneration; anti-competitive behaviour;
• Group funds and property;
• accounting standards;
• competition law matters; and
• security of information: obtaining and safeguarding information; access to information; insider trading.

WHISTLE BLOWING PROGRAMME

A service known as the EthicsLine is in place. It is aimed at enabling employees, customers, suppliers and managers or other stakeholders, on a confidential basis, to raise concern in cases where conduct is deemed to be contrary to ethical behaviour and the Code of Ethics. The EthicsLine is administered by Deloitte & Touche. Therefore, the service is totally independent of AECI and the anonymity of individuals reporting fraud or dishonest and inappropriate behaviour is protected. Legitimate issues and concerns reported are forwarded for appropriate action to the Group legal advisor, the financial director and the head of internal audit.

CONFLICTS OF INTEREST

The Company has adopted a formal Conflicts of Interest policy and all employees with the ability to bind the Company (contractually or otherwise) are required to complete and submit a Conflict of Interest declaration.

FRAUD AND ILLEGAL ACTS

The Group does not engage in or accept or condone engaging in any illegal acts in the conduct of its business. The Group's policy is to actively pursue and encourage prosecution of perpetrators of fraudulent or other illegal activities should it become aware of any such acts. A zero tolerance approach has been adopted.

Formal training for all employees on the Company's Code of Ethics, the EthicsLine as well as other applicable policies commenced during 2008 and continued in 2009.