Code of Conduct and Ethics - Bradken

CODE OF CONDUCTAND ETHICSPROUD TOBELONG1

Continuous ImprovementCustomer FocusTo be successful in our markets, Bradken must create increasedvalue for our customers. We recognise that this success canonly be achieved through ongoing development of:Our customers are an integral part of our business.We value employees who strive at all times to workwith our customers to understand their needsand expectations and to build positive businessrelationships by delivering on their commitments.12345ProductsPeopleProcessesPlantPerformanceCommitment of our employees to continuous improvement andinnovation is critical to our ongoing success.10 10 11 11

LoyaltyThe dedication of our employees through their service ishighly valued at Bradken. Our employees’ contributionsof ideas, skills, energy and experience allow us to growand prosper. The diversity in age also provides for thementoring of the next generation of Bradken employeesand secures Bradkens knowledge capital into the future.CourageWe need to challenge our boundaries and our currentknowledge to progress. It’s not always easy to do this assometimes hard decisions need to be made. Sometimes itcould also be as simple as challenging a fellow workmate ona safety matter or speaking up about issues or improvementopportunities.Bradken encourages its employees to explore alternativeoptions, to take risks and to go the extra mile when exploringnew avenues for success.12 1213

Work Together for Common GoalsBradken acknowledges that teamwork is the cornerstone toour future success. Only when our employees pool their skills,talent and knowledge can we achieve our ambitious goals. Werecognise the whole is more than the sum of its parts.High MotivationBradken values employees who are self motivatedand committed to success. We strive to foster a workenvironment which empowers all employeesto achieve outstanding results.14 1415

Our Business DealingsIn our business dealings, we set the highest standards by:• Striving to be good corporate citizens;• Respecting the law;• Respecting confidentiality and privacy;• Avoiding conflicts of interest;• Acting with honesty and integrity;• Maintaining personal and professional values; and• Accepting the consequences of our actions.1 We strive to be good corporate citizensWe uphold Bradken’s Values and are committed to thebusiness objectives of the Company while striving to begood corporate citizens.RespectAt Bradken, we not only respect and appreciateeach other’s differences, we endeavour to learnand grow through the experience.In all dealings, we consider the effects of our actions on ourcolleagues, customers and the wider community. We believethat good corporate citizenship is more than an occasionalgesture, but an ideal that is integrated into every decisionmakingprocess.16 1617 17

2 We respect the law and act accordinglyWe understand that violation of laws and regulations can haveserious consequences for Bradken and ourselves, therefore,we comply with the laws and regulations in all countries inwhich the company operates or transacts business.We follow and obey the policies and procedures prescribedby Bradken so as to ensure that our actions comply with goodbusiness practices, ethical behaviours and expectations.Throughout the course of our employment and in compliancewith corporate policy, we notify the appropriate peopleresponsible for taking action when we observe or becomeaware of any breach of the law.4We avoid conflicts of interestWe avoid participating in activities that involve a conflict withour duties and responsibilities to Bradken or which may beperceived as prejudicial to Bradken’s business interests.We do not become involved in any business activities outsideour employment that could adversely affect our ability orcommitment to perform our duties and responsibilities toBradken.We do not solicit, accept or offer inducements or favours,which might influence or adversely affect our businessjudgement, professionalism or relationships with others.3 We respect confidentiality and privacyAt all times, we treat as confidential the business affairsof Bradken and those of our customers, colleagues andbusiness associates, maintaining compliance with theprivacy laws governing the use and disclosure of information.We respect the privacy of others and keep confidential thedisclosure of all sensitive, personal or privileged informationof others.We do not use confidential information for personal gain orfor the benefit of others such as friends, relatives or businessassociates.If at any time we are in doubt or uncertain whether an actionwe have taken has been or resulted in a breach of this Code,we can raise the matter, in confidence, with our Supervisor orManager and be assured that we will receive a fair hearing.5 We act with honesty and integrityWe are judged by our actions, therefore, if we act with honestyand integrity in all dealings and strive to always do the rightthing, we will earn the respect and admiration of others.We do not tolerate dishonest behaviour by our colleagues orcustomers and always endeavour to avoid conflict or activities,which may harm the good reputation of Bradken and ourself.We do not use information provided by others for personal gainor betterment and in all things, endeavour to provide accurateand honest information to our customers and colleagues.18 1819 19

6We maintain our personal and professional valuesIn all ways, to foster and preserve our personal reputation and thatof Bradken, we conduct ourselves in a professional and ethicalmanner and strive for excellence in our pursuit of the highestpossible quality of work.We maintain and strive to improve the skills, knowledge andcompetencies required to fulfil our role in the company and alwayswork as an effective team member, striving for a safe, harmoniousand effective work environment.We do not tolerate harassment or unlawful discrimination and arecommitted to diversity, equal opportunity and a “fair go” for all.7We accept the consequences of our actionsWe understand that our actions can have a dramatic effect onthe performance of our duties and the reputation of Bradken andtherefore the responsibilities we have to Bradken.We accept as a consequence of our actions in violating this Codeof Conduct and Ethics that disciplinary action may be an outcomeand in extreme cases such action may result in the termination ofour employment contract.20 2021 21

Business PracticesBusiness LawBradken employees will comply with the law at all times.As trade practices principles affect the Company’s dailybusiness operations, it is essential that all Companybusiness activities compete in conformity with prescribedlegislation.Employees will comply with legislation established toprovide, maintain and protect competition for the benefitof all customers. No employees shall make any untruthfulremarks about any of the Company’s competitors, theirproducts or services.The basic principles underlying these rules are that:••all companies must act independently of each otherin their business activities and maintain healthyrivalry;••all companies must be considerate to theircustomers; and••large companies must not use their size to manipulatesmaller ones.The following conduct is prohibited, no matter what thecircumstances.••Resale price maintenance i.e. requiring distributors tosell products at certain prices or set a minimum price.••Forcing anothers’ product i.e. placing a condition onthe supply of goods or services where a customer mustacquire goods or services from a nominated supplier.••Price fixing i.e. making an agreement which wouldhave the purpose or effect of fixing, controlling ormaintaining the price of goods or services.••Arrangements to exclude i.e. an arrangementbetween parties to exclude another.••Exclusive dealing i.e. where one entity in a businessrelationship places restrictions on the freedom ofthe other to deal with outsiders – that is, to tradecompetitively.••Anti-competitive arrangements i.e. arrangementsbetween businesses which prevent, restrict or distortcompetition.••Secondary boycott i.e. an attempt to influence theactions of one business by exerting pressure onanother business.••Misuse of market power i.e. preventing the entry of acompetitor into a market, or deterring or preventinga competitor from engaging in competitive conductin a market.••Unconscionable conduct i.e. the use of a superiorbargaining position to enforce harsh contractualconditions against another party.In addition to the above prohibitions, there are high risksituations, which employees should be cognisant of.These include:••Pricing arrangements;••Dealing with competitors;••Dealing with trade associations;••Refusal to supply, and••Following or being a market leader.2223

Travelling on Behalf of BradkenTravelling, particularly to overseas countries, means that wemust be conscious of any cultural differences which may exist.Whilst we endeavour to respect these differences, we mustuphold the values that are core to Bradken.Bradken is responsible for an employee’s safety 24 hours a daywhen travelling. To this end, Bradken provides travel insurancefor all employees throughout the duration of their travel. Thismeans that employees are representatives of Bradken bothduring and outside normal working hours.It is expected that travellers will make appropriate enquiriesprior to visiting unfamiliar destinations including seekingrecommendations for vaccinations or other specificmedications, to ensure that they are aware of potential healthrisks, regional issues and differing laws and customs. Whentravelling in foreign countries, engaging an experienced guideor consulting local Bradken senior management may be thebest way of avoiding any potentially unsafe situations.Bradken will not tolerate any activities that may lead toinvolvement in excessive consumption of alcohol, taking of illicitdrugs, prostitution, illegal activities or any behaviour that maybring into disrepute either the Company or an employee.Bradken is developing new overseas businesses and theCompany’s reputation and culture are critical to its continuingsuccess. When overseas, all employees need to be cognisantof the fact that they are ambassadors of both Bradken andtheir country.Whilst overseas, employees should be aware of the following.••You may find yourself in a situation in which you do notwish to participate. It is important that you say “no” in away that will not offend.••You may be seen as having more authority than yourposition holds. You need to be careful to act within yourauthority limits and ensure that your behaviour is notmisleading.••You may need to take public transport from alocation where English signage is poor. It is oftenbetter to have a local person take you to these areas.••You may be required to take a taxi to your destination.Look at the condition of the vehicle and ensure that it iswith a reputable company.••You may be invited to accept a gift. Look at theappropriateness of the gift. Gifts should not beaccepted during any negotiation period.••You may be offered an inducement. Bradken does notparticipate in or condone the practice of acceptinggratuities, bribes or inducements by its employeesor business partners. Such conduct could result indismissal.2425

WhistleblowingIn keeping with Bradken’s goal of creating a climate in thecompany where the truth can be heard, all employees areactively encouraged to challenge any behaviour whichthey believe to be inconsistent with any of our Values orour Code of Conduct and Ethics. All such challenges,including those concerning acting with integrity, willbe handled constructively, with the objective of eitherremedying the issue or explaining why the behaviouris considered consistent with our business culture.We encourage all of our employees to report anybehaviour which they, acting in good faith, believe to be:••Dishonest;••Fraudulent;••Corrupt;••Illegal (including theft, drug sales/use, prostitution,violence or threatened violence and criminal damageagainst property);••In breach of government legislation;••Unethical;••Seriously improper (including harassment andbullying);••Unsafe work practice; or••Behaviour which may cause financial and nonfinancialloss to Bradken or would be otherwisedetrimental to the interests of Bradken.Individuals who report or seek to report unlawful or unethicalbehaviour will be given a guarantee of anonymity (if anonymityis desired by them), subject to any legal requirements whichmay require disclosure of the identity of the individual.Bradken will ensure that any individual who makesa report is kept informed about the outcomes of theinvestigation of his or her report, subject to considerationsof the privacy of those against whom the allegations aremade and our customary practices of confidentiality.Bradken has in place internal reporting arrangements toensure that all verifiable, unlawful or unethical behaviour isdealt with appropriately, and commits to rectify the wrongdoing verified by the investigation to the extent practicable in allthe circumstances, and ensure that systematic and recurringproblems of unlawful or unethical behaviour are reported tothose with sufficient authority to correct them.Equal Opportunity and DiversityBradken is committed to providing a work environment inwhich the principles of equal opportunity are incorporatedinto all business decisions. Bradken, as an employer hasa strong commitment to equal opportunity and diversity inemployment and recognises the right of all employees tobe treated fairly and with respect at all times and work inan environment free from harassment and discrimination.Bradken will not tolerate discrimination in any form andwill take disciplinary action against any person or personsdiscriminating against another individual or group.2627

EuropeNorth AmericaChinaAfricaSouth AmericaFoundryWorkshopAustraliaMetal RecyclingRegional Head OfficesAFRICAUnit G1 The Palisades39 Kelly RoadJet Park South AfricaT +27 11 025 5403F +27 86 515 1792E africa@bradken.comNORTH AMERICASuite 647, 12200 NWAmbassador DriveKansas City MO 64163 USAT +1 816 270 0700F +1 816 270 0799E northamerica@bradken.comSOUTH AMERICAAv. Alonso de Córdova 5670,oficina 401, Las Condes,Santiago 7560875, ChileT +56 2 656 7409E southamerica@bradken.comASIANo.26, XuHai Road SouthEconomic Development ZoneXuzhou P.R. China 221131T + 86 516 8355 3958F + 86 516 8355 3959E asia@bradken.comPACIFIC20 McIntosh Drive,Mayfield West,NSW 2304 AustraliaT +61 2 4926 8200F +61 2 4926 8201E pacific@bradken.comEUROPE2 Vantage DriveSheffield S9 1RGUnited KingdomT +44 1142 841 000F +44 1142 841 001E europe@bradken.comPROUD TOBELONG28© 2013 - Bradken ®