Updated:             11 August 2009

Reporting Improper Activities

Ethics and Compliance at Goughs

Goughs policy is to be ethical, lawful, principled and socially responsible in all of its business practices.  We will treat all stakeholders associated with our organisation with respect and honesty. 

Goughs expects its employees to learn and comply with all Company policies and laws applicable to their job responsibilities and to adhere to the Company’s Code of Conduct as outlined in the Employee Handbook.

Improper Activities

Improper Activities are activities/serious wrong-doing involving Goughs or Goughs employees that violate any law or regulation, that are contrary to the Gough Group Code of Conduct, or which could pose a significant threat to the health and safety of employees or the public.

Examples include:

Duty to Report Improper Activities

Any improper activities involving Goughs or Goughs employees must be reported to the Chairman of the Audit Committee of the Gough Group Board of Directors.

The direct contact details for the Chairman of the Audit Committee are as follows:

Chairman:           David  Brown

Mobile +64 29 222 8200

You can choose to remain anonymous if you wish, and your confidentiality will be strictly maintained.  However, disclosing appropriate details will assist the Company in effectively investigating the allegations.

You may also elect to discuss any “improper activities” with the Group Chief Executive Officer on +64 21 332 174 if you believe the matter is less significant or severe, which clearly does not involve the Executive Management of the Gough Group, but needs to be brought to the Company’s attention.

If the nature of the call is such that you wish to speak to a female about the subject matter, please indicate this to the Chairman of the Audit Committee or the Group CEO, who may refer you to the Gough Group Human Resources.

What Will Happen After the Call is Made

After contact is made, the Chairman of the Audit Committee or the Group CEO will institute appropriate investigations to properly address your concerns, and you will be kept informed of the progress being made if you so wish.

It is our undertaking that every call made will be properly investigated in a timely manner and that you will be protected from any repercussions in coming forward with the information, in accordance with the Protected Disclosures Act 2000.

(Details of the Notification of Serious wrong-doing is also set out in the Employee Handbook.)

David Brown                                                                                                      Karl Smith

Chairman of the Audit Committee                                                           Group Chief Executive Officer