broader stakeholder constituency
of shareholders, employees,
customers and the community,
are also recorded in separate
guidelines and policies relating
to dealing in securities (refer 
to the next section), the
environment, occupational health
and safety and human resources.
Further, a Code of Conduct,
based on that developed by 
the Group of 100 (an association
of senior finance executives 
from Australia’s business
enterprises) applies to the 
CFO and all other officers and
employees within the finance
function of the Company who
have the opportunity to
influence the integrity, direction
and operation of the Company
and its financial performance.
Where applicable, the guidelines
and policies are incorporated by
reference in individual contracts
of employment or expressly set
out in those contracts, including
provisions relating to: conflicts
of interest; confidentiality and
restrictions against use and
dissemination of information;
use of Company assets;
perquisites, tender processes,
benefits and contact with
suppliers; employment
opportunity practices; privacy;
training and further education
support; and smoking, alcohol
and drugs.
10. GUIDELINES FOR DEALING
IN SECURITIES
The Company has developed
specific written guidelines that
prohibit Directors and executives
(and their respective associates)
from acquiring, selling or
otherwise trading in the
Company’s shares if they possess
material price-sensitive
information which is not in the
public domain.
Pursuant to these guidelines, 
no person may deal in securities
while they are in the possession
of price sensitive information. 
In other circumstances, Directors
must inform and receive
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