CODE OF CONDUCT
Au Traders and Refiners (Pty) Ltd
PREAMBLE
AU Traders and Refiners have a zero tolerance policy on bribery and any unethical
payments to clients or business associates which will result in disciplinary action.
Efforts to manipulate the markets in which the company is active, including collusion
with competitors, will be dealt with similarly.
LEGISLATION
The law will not be violated when conducting business for or on behalf of the company
RESPONSIBILITY

Any possible conflict of interest in handling company affairs will be avoided and
employees will perform their duties conscientiously, honestly and in accordance
with the best interests of the company and its shareholders.

Employees will not derive personal advantage from their position in the
company, nor will they acquire any business interest which could divert their
energy from company responsibilities. They will not participate in an activity that
is potentially in conflict with company interests or which could be perceived to
impair their independence. Employees will not accept gifts, hospitality, or other
favors from clients or potential clients of goods or services which, in the view of
their immediate line superior or colleagues would be unwise, potentially sending
the wrong message to subordinates and/or placing the recipient or the company
under perceived obligation.
CONFIDENTIALITY
Each investor and employee shall maintain as confidential any legitimate business
information provided in confidence until and unless given permission to disclose it by
the disclosing party or for the length of time that confidentiality is legally required.
ASSET CONTROL
Company funds, property and assets will be used only for legitimate business
purposes. Strict internal controls and governance procedures of the highest order will
be introduced and enforced to discourage fraud and safeguard the company.
RECORD KEEPING
Accurate and reliable records will be kept which fairly reflect all business transactions
in terms of statements of Public Management Finance Act, for the company to properly
manage its affairs and meet its legal, financial, and reporting obligations. Personal and
business information gained in the course of business dealings will be safeguarded and
its privacy respected.
EMPLOYMENT EQUITY

The company will uphold its employment equity policy which requires that equal
opportunity be offered to all employees. The individuality of each person, their
right to freedom of association and to absolute privacy in this regard will be
respected. Harassment of any form, including sexual harassment, will be viewed
in a very serious light and appropriate disciplinary action taken.

People employed by Au Traders and Refiners are unquestionably its most
important asset. Through careful selection, ongoing development, performance
based management and fair reward, every person in our company will be
encouraged to realize their full potential. Exceptional commitment to the
company’s core values of integrity, quality and entrepreneurship will be
appropriately rewarded.

Au Traders and Refiners will strive to be a leading corporate citizen, working
with employees, their families, local communities and society at large to improve
the overall quality of life and to achieve sustainable economic development at all
levels.
POLICIES AND OPERATIONAL PROCEDURE
The company will promote policies and operating procedures that conserve resources
and minimize the environmental impact of its business activities, building an
atmosphere of openness and trust through regular, timely and courteous
communication with all stakeholders.
PROPOSALS ON NEW AND EXISTING BUSINESS
Where business is conducted solely telephonically, investors and employees must
ensure that all calls are disclosed. Members must inform clients that documents should
be read carefully.
DISCIPLINARY PROCESSES
Any complaints against a member of Au Traders and Refiners for breaching any of the
provisions of the Code of Conduct shall be lodged in writing to Management
Management will be instituted to investigate the complaints made against the members
and need be to conduct disciplinary hearings and to make decisions on the corrective
action to be taken.
Management must receive complaints within 24 hours of the incident occurring.
Decisions and penalties imposed by Management are binding on Members. The
affected Member may appeal against a decision in writing within fourteen working days.
If an appeal is received, an executive member from the company will act as arbitrator in
the matter.
The final binding decision and reasons for that decision will kept on record