SAPAN CHEMICALS LIMITED

CODE OF CONDUCT

Corporate Governance

The company is committed to sound corporate governance that will ensure the company operates as efficiently as possible while providing for the appropriate level of accountability and transparency.

The primary objective of the Board is to build long term shareholder value with due regard to other stakeholder interest. It does this by guiding strategic direction and context and focusing on issues critical for its successful execution.

The board delegates the management of the day-to-day affairs of the company to the Executive Team under the leadership of the Director to deliver the strategic direction and goals determined by the Board.

The company seeks to follow the best practice recommendations for listed companies to the extent that it is appropriate to the size and nature of the operations.




Code of Ethics

The Code has been adopted by the company and, amongst other things, provides that all persons must avoid conflicts of interest between their private financial activities and their part in the conduct of company business.

This Code is applicable to all the members. Member shall act in accordance with the highest standards of honesty, integrity and fairness and expect the same in their relationships with others while maintaining a work and business climate fostering such standards; and avoid having any financial interest in works of or contracts awarded by a company forming part of or associated with, the company, or in supplies effected or services rendered to or by such a company and where this is unavoidable or immediate family members have such a financial interest, such interest shall be disclosed.