Code of Conduct

The Company seeks to ensure that all actions it takes and all business dealings into which it enters are undertaken with the highest standards of honesty, integrity, professionalism, fair play, ethical behaviour and respect for individuals. As a minimum, the Company seeks to comply with all laws in the countries in which it operates. In practice, it aims to achieve nothing less than the highest possible standards.

As the actions of the Company are, by necessity, actions of its employees, this policy binds every employee to its principles.

This Policy requires that all employees apply commonsense and responsible behaviour at all times while acting for the Company. Each person has a varying chance to affect the Company’s reputation through their actions, depending on the role they occupy.

Nevertheless, to the extent possible, they must ensure the Company is always acting ethically.

It is not possible to list all possible actions that constitute unethical bahaviour, but the following examples of improper behaviour will serve to demonstrate the need for ethical conduct by all employees:

• Making false entries in books of account
• Accepting benefits from suppliers in return for issuing Company purchase orders
• Removing Company property for personal use without permission
• Asking suppliers for favourable terms for purchases of a personal nature
• Providing information about the Company to outside parties without proper authority
• Providing assay results from exploration or grade control drilling to outside parties
• Using knowledge gained from employment with the Company for personal gain
• Unfairly taking advantage of another’s misfortune to gain benefit for the Company or self
• Using Company Funds for personal use or gain.
• Offering benefits of money or gifts to suppliers to influence an action or decision or in return for better service.

Confidential and Proprietary Information

Unless previously published, the Company’s records, reports, papers, processes, plans and methods are proprietary and confidential. Employees are prohibited from revealing information concerning such matters without proper authorization.

Proprietary information developed or acquired by Company including trade secrets and other technical, financial and business information, is a valuable asset that must be kept confidential and protected against theft, loss or misuse. Confidential information must be used for authorized purposes only. Information that is not generally available to the public concerning the activities, results, or plans of Company must also only be used for authorized purposes. Confidential or proprietary information must never be used for personal gain.

Company retains the exclusive proprietary right to any information developed by employees in the course of their employement with Company. Examples may include onventions, designs, discoveries or software programs.

Copyright of Employee’s Work

As for the copyright, it shall be deemed that research, experiment, innovation, development of computer program, or others as specified in the Copyright Act B.E.2537, or as maybe amended in the future, if undertaken in the course of employment, during work hours, work place, using resources of the company, the copy shall belong to the company. Addition, Employee shall not, under false pretexts bring in works of other people in disguise as his/her own, for use in the company which may implicate the company in breach of copyright.

It is a condition of employement that no information relating to the affair of the Company may be divulged to any other business, company, representative of the press and/or any person whomsoever, without appropritate authority having been given. This condition extends to the conditions of your employement, which are to be kept in strict confidence between the employee and the Company.

There are some specific behaviours demanded of expatriate personnel, because of their positions as guests in Thailand. These are detailed in Appendix A and, for expatriate personnel, are to be considered an integral part of this Code of Conduct

All Management personnel, Senior Staff, employees of the Accounting Department and other employees considered necessary by the a Head of Department, will be required to acknowledge receipt and understanding of this Policy when issued, when commencing employment and in January of each subsequent year. The Human Resources Manager will be responsible for obtaining these acknowledgements.

This Code of Conduct will be provided to each new employee with his Letter of Offer.

It is a requirement for all employees to declare any potential conflicts of interest such as interests in companies that may supply or wish to supply services to Company or associated companies.

Any member of staff who becomes aware of possible unethical behaviour, or of fraudulent or illegal behaviour by another staff member which is likely to affect the Company’s reputation, must report such an event to his Head of Department or to the General Manager/Chief Executive Officer. The Company undertakes that any such report, made in good faith, will be treated confidentially and the reporting employee protected from adverse effects.

Each reported action will be thoroughly investigated by the General Manager or the Chief Executive Officer. The employee who brought the event to the Company’s attention will be kept informed of the progress of the investigation as far as is practical.

Any employee found to have breached this Policy will be disciplined appropriately without severance pay.