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or staff-related information. We must never attempt to gain access to information for which we do
not have a business/job role requirement.

7.2.5 Discussions with media
We should not discuss Company business with the media unless specifically authorised to do so by
Phil Reddin.
7.2.6 Conflicts of Interests
Conflicts of interests arise when there is a difference or clash between the interests of two parties in
a transaction. A conflict of interests is the result of any activities, interests or relationships that might
interfere with (or appear to interfere with) our ability to act in the best interests of the Company and
or its customers. Conflicts of interests can arise between the Company as a business and our
customers, between staff and the Company or staff and customers, or between customers.
We never knowingly create a situation which may give rise to a business conflict of interests. We must
always take all reasonable steps to identify potential business conflicts of interests and avoid them.

Where a conflict of interests arises, directly or indirectly, we must disclose it to the customer. We may
undertake business with or on behalf of such a customer only where the customer has acknowledged
(in writing) their awareness of that conflict and their wish to proceed.

Certain Company businesses, which have been identified as requiring the operation of information
barriers due to the type of customer information they have access to, must ensure the ongoing
effectiveness of such arrangements.

In situations where senior management of a business deem that existing conflicts of interests
arrangements may not be sufficient to resolve a conflict situation when dealing with transactions with
listed companies, additional inter-and intra-business unit procedures to address those conflicts may
be required.

This Code can only provide high level guidance and examples.

7.3 OUR CUSTOMERS
Our customers are the heart of our business. Their interests are central to everything we do. Our job
is to provide them with the right products and services at the right time and in the right way.

We strive to treat our customers and stakeholders with fairness, respect and understanding at all
times. We avoid situations where conflicts of interests may arise or appear to arise between the
personal interests of our employees and the interests of our customers or of the Company itself.
Where a conflict of interests arises we ensure it is disclosed to the relevant parties and we require
written confirmation from them that they're aware of the conflict and still wish to proceed.

We maintain the highest standards of confidentiality in safeguarding information about our
customers, their business and their accounts.
Our individual responsibilities include:

• We treat customers fairly
• Authorised representations made on behalf of customers are addressed appropriately and
professionally
• We provide professional advice to a customer only if appropriately qualified and specifically
authorised to do so on behalf of the Company

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