A Message from the Chairman & CEO

2. Basic Principles

2.1 General
2.2 Responsibility to Customers
2.3 Management's Responsibility to Staff
2.4 Employees' Responsibility to the Company

3. Honesty and Fair Dealing

3.1 General
3.2 Unethical Behaviour: Relationships with Competitors
3.3 Dealings with Customers and Business Associates
3.3.1 Gifts, Entertainment, Gratuities and Other Payments
3.4 Dealings with the Company
3.4.1 Records
3.4.2 Improper Use of Records
3.4.3 Improper Expense Claims
3.4.4 Using Company facilities or Opportunities for Personal Transactions

4. Conflicts of Interest

4.1 General
4.2 Directorships
4.3 Other Employment or Outside Business Interest

5. Confidentiality

5.1 Customer Confidentiality
5.2 Company Confidentiality

8. Compliance with Laws and the Code of Ethics & Guidelines For Business Conduct

8.1 Compliance
8.2 Reporting of Breaches or Irregularities & "Whistle Blowing"

9. Safeguarding Company Assets including Intellectual Property

9.1 Protect all Company Assets
9.2 Intellectual Property
9.3 Property Entrusted to Third Parties
9.4 Use of Company's Property Off Premises
9.5 Computer Systems