APN NEWS & MEDIA LIMITED (the “Company”)
CODE OF CONDUCT
The Company’s Code of Conduct (“Code”) governs the Company and its
subsidiaries’ commercial operations and the conduct of Directors, employees,
consultants and all other people when they represent the Company and its
subsidiaries (together with the Company, the “APN Group”).
The Board of the Company has certain expectations of the APN Group in relation
to its interactions with customers, shareholders, staff and the broader community.
This Code comprises certain fundamental principles and demonstrates the high
standards of conduct expected of the APN Group.
Separate polices within the APN Group are also relevant to the conduct of the
APN Group including policies dealing with inside information, market disclosures,
human resources and other matters.
Compliance with laws The APN Group, their Directors, employees, consultants and all other people
when they represent the APN Group are expected to comply, at all times, with all
laws governing its operations. They are also expected to conduct APN Group
operations in keeping with the highest legal, moral and ethical standards. All
Directors and employees of the APN Group (“APN Employees”) must conduct
the business of the APN Group with the highest level of ethics and integrity in
relation to customers, suppliers, competitors, each other and all others with
whom they deal. APN Employees must act:
ethically, honestly, responsibility and diligently;
in full compliance with the letter and spirit of the law and this Code; and
in the best interest of the Company (or relevant APN Group entity).
The requirements contained in this Code apply in addition to the legal obligations
and duties imposed on APN Employees.
Breach of the Code
Any breach of applicable laws or of this Code will result in disciplinary action.
Such disciplinary action may include (depending on the severity of the breach)
reprimand, formal warning, or termination of empl