| Respect | We will respect each other and company property |
| Integrity | We will stand by our word ensuring a reputation as a highly professional team delivering on commitments to all stakeholders |
| Honesty | We will be open, honest and fair in our dealings with people based on a clear set of ethical standards |
| Personal Commitment | We will be personally responsible for acting in accordance with the law, Alumina’s Values, Code of Conduct and company policies, and be accountable for expected results |
| High Performance | We will be energised by the excitement and fulfilment of raising the bar in everything we do |
| 1. | We will be honest and ethical in all of our actions and relationships and act in the interests of the shareholders. |
| 2. | As a minimum, we will observe the rule and intent of all relevant governmental laws, regulatory and professional rules and guidelines. |
| 3. | We will maintain an appropriate level of confidentiality at all times with respect to company, employees and business associates information. |
| 4. | We will act fairly, be honest, open, and accountable in all dealings with internal and external parties. |
| 5. | We will avoid situations in which individual personal interest may conflict with the interest of the company and communicate any real or potential conflict of interest to the Board. |
| 6. | We will maintain all records of the company to be accurate, in accordance with applicable procedures and accounting standards and that financial information is complete, fair, timely and understandable. |
| 7. | Where commercially prudent, financial information is openly available to internal and external users. |
| 8. | We will maintain systems of sound internal controls and procedures, and act in a manner to protect the Company's assets, appropriately manage risk and ensure financial information is complete and accurate. |
| 9. | We will uphold the Company's values and principles as reflected in this Code, the Company's policies, standards and charters. |
| 10. | We will not use the corporate privilege of information, position or property for the purposes of personal gain or competing with the company. |
| 11. | In fostering ethical, fair and legal behaviour, we encourage officers and employees to report any questionable practice. Reprisals against people for reports made in good faith will not be tolerated. |
| 12. | Any request for a waiver of the provisions of this Code may only be considered by the Company's Board of Directors. Any waiver granted will be promptly disclosed on the Company's website. |
| 13. | Any suspected violations of this Code should be reported promptly to the Chairman of the Company's Board of Directors. Violations will be investigated by the Board or by a person or persons designated by the Board and appropriate action will be taken in the event of any violations of the Code. |