ALEX STEWART INTERNATIONAL’S CODE OF PROFESSIONAL CONDUCT

PRINCIPLES OF PROFESSIONAL CONDUCT Integrity Conflicts of interest Confidentiality Anti-bribery Fair marketing

WHO DOES IT APPLY TO? ASIC Group Commitment to IFIA Compliance Code Group partners and senior management Employees Subcontractors Suppliers Consultants COMPLIANCE CODE

IMPLEMENTATION OF CODE IFIA Compliance Programme Principles, policies, guidelines Compliance officer, Management Committee, Training Management declarations

AUDIT MANAGEMENT ASIC Compliance Officer Internal integration with ISO procedures Independent external audit – HQ and selected offices

INTEGRITY Confidentiality in reporting Tolerances must be within parameters Methods to be proven, applicable and auditable Reports must reflect actual findings Client abuse or pressure to be reported to management

CONFIDENTIALITY All information is business confidential All employees to sign non disclosure agreement

CONFLICTS OF INTEREST All business should be free of conflict of interest No partner, manager or employee should hold outside interests e.g. Client, supplier, competitor that could damage Company’s performance or reputation Employees should not conduct business with family members Client abuse or pressure to be reported to management

Non critical of competitors/fellow IFIA members Marketing must not mislead clients Marketing must be fair Marketing must be representative and truthful Marketing promotional materials must be accurate Gifts and hospitality should be made for the right reasons and without obligation FAIR MARKETING

ANTI-BRIBERY All partners, management and staff are prohibited from offering, soliciting, giving and receiving bribes All knowledge of any bribes must be reported to ASIC/IFIA Compliance Officer Any client applying pressure through bribes must be reported to the compliance officer

ACCOUNTING Accounts and financial records must be accurate Off books accounting is not permitted Accounts should be audited annually

SUMMARY Do not do anything which you believe to be illegal or unethical Do not use any company property for your own benefit Do not engage in any transaction, which does not have a genuine, legitimate business purpose Ask yourself whether any contemplated transaction or business practice would withstand investigation Do not do anything, which could require you to be untruthful Report any breaches or abuse of IFIA Code to ASIC Compliance Officer Reported breaches will be investigated, disciplinary action will prevail if breached proven and substantiated

Alex Stewart International Corporation Sefton Business Park Netherton Liverpool Merseyside L30 1RD T: F: E: W: THANK YOU FOR YOUR ATTENTION