Alumina Limited

Compliance with the Law

1. Overview

Alumina Limited and our Employees are affected by numerous Laws and Regulations.

Compliance with the letter and intent of all laws and relevant regulations is a fundamental requirement that the Company demands of its Employee’s and representatives.

Alumina Limited’s Code of Conduct and Values, to which Employees make a commitment to uphold, clearly refer to the Employee’s obligation to: “observe the rule and intent of all relevant governmental laws, regulatory and professional rules and guidelines”.

2. Guidelines

A detailed knowledge of the application/workings of the various Laws that impact Alumina Limited and Employees may not be possible by individuals. However, ignorance of the Law is not considered an acceptable excuse for non-compliance.

Employees with concerns or doubts regarding the application of a Law in respect of their work should initially seek advice from the General Counsel/Company Secretary.

Due to the diverse nature of Laws, it may require consulting with an external expert in the appropriate field of Law or Regulation to determine what is acceptable and compliant behaviour. Again, the General Counsel/Company Secretary will make a decision in regards
to assessing whether external advice should be sought.

In the absence of the General Counsel/Company Secretary, Employees must make a request to the Chief Executive Officer (CEO) regarding further assistance.

3. Responsibilities

An Employee or representative is obliged to make an informed enquiry if they are unclear in regards to the application or impact of specific governing matters effecting, or potentially impacting their work or area of responsibility.