Code of Conduct

Commitment

The Talent2 Board and management team are firmly committed to ensuring that all officers and staff of Talent2, including themselves, observe the highest standards of honesty, integrity, care, fair dealing and excellence in the conduct of Talent2’s business activities. This code sets out the standards of ethical behaviour expected of all officers and staff, including directors.

Responsibilities to shareholders and the financial community

• Talent2 is committed to the delivery of good financial returns to its shareholders. Whilst its focus is commercial, Talent2 pursues its commercial and financial objectives in accordance with principles of good governance and social responsibility.
• In accordance with its core values of honesty and integrity, Talent2 is committed to transparency, diligence, good faith, accuracy and timeliness in the preparation and delivery of financial information.
• Information will be disclosed in a manner that is fair and respectful of the interests of shareholders and the financial community.

Responsibilities to clients’ customers and consumers

All dealings with clients’ customers and consumers will be conducted in accordance with core principles of honesty, integrity and service excellence.

Responsibilities to employees

Talent2 recognises and values the contribution made by its employees. The following values guide its employment practices:

• Fairness
• Absence of discrimination and harassment
• Safe work systems
• Privacy
• Respect of environmental obligations and practices

Privacy

The privacy of all shareholders, employees and other stakeholders of Talent2 are of the utmost importance. Any personal information in the possession of Talent2 will only be released according to the Law.

Conflicts of interest

Conflicts of interest are to be avoided and any actual or potential conflicts are to be reported to the Chairman or Company Secretary.

Corporate opportunities

• Directors officers and staff are not to exploit their position within Talent2 for personal gain
• Directors officers and staff are obliged to bring business opportunities identified through the use of Company property, information or position to the attention of Talent2.
• Directors officers and staff are to behave in a manner that promotes the good reputation of Talent2

Gifts and entertainment

• All business entertainment received or provided is to be reasonable and properly authorised
• Gifts may only be accepted which are not in cash, of small value and appropriate to a business relationship
• The giving or receiving of bribes or other improper payments is prohibited

Confidentiality

• Confidential or commercially sensitive information is not to be disclosed without proper authorisation.
• Continuous disclosure obligations are to be met according to the Disclosure Policy
• Securities trading is to be conducted in accordance with the Employee Share Trading Policy

Fair dealing

All dealings with shareholders, clients, customers, suppliers, competitors, employees and other stakeholders are to be conducted in a way that is fair and reasonable.

Protection of and proper use of company assets

All Talent2 assets are to be used in the best interests of the company and protected from loss and misuse.

Compliance with laws and regulations

All officers and staff are expected to understand the laws relevant to their work and comply with the spirit and letter of all applicable laws, rules and regulations.

Reporting of unlawful or unethical behaviour and compliance with the code

• Any circumstance which is in good faith believed to be a breach of this code or of the law is to be reported:
  • by employees to their immediate supervisor and then by the supervisor to the Company Secretary
  • by executive officers to the Company Secretary
  • by directors to the Chairman.
• Any person reporting such breaches will be protected from retribution
• If reporting does not result in satisfactory action, a further report can be made to the Managing Director or Chairman of the Audit Committee.
• The Managing Director is responsible for periodic reports to the Board on the operation and effectiveness of this code.