Code of Conduct

Philosophy

The Board will operate in a manner that promotes ethical and responsible decision making by all Directors and employees.

Procedures and Guidelines

The Board has adopted a Code of Conduct for Directors to promote ethical and responsible decision making by the Directors. The code is based on a code of conduct for Directors prepared by the Australian Institute of Company Directors.

The principles of the code are:

• A Director must act honestly, in good faith and in the best interests of Neon as a whole.
• A Director has a duty to use due care and diligence in fulfilling the functions of office and exercising the powers attached to that office.
• A Director must use the powers of office for a proper purpose, in the best interests of the Company as a whole.
• A Director must recognise that the primary responsibility is to Neon's shareholders as a whole but should, where appropriate, have regard for the interest of all stakeholders of the Group.
• A Director must not make improper use of information acquired as a Director.
• A Director must not take improper advantage of the position of Director.
• A Director must not allow personal interests, or the interests of any associated person, to conflict with the interests of the Company.
• A Director has an obligation to be independent in judgment and actions and to take all reasonable steps to be satisfied as to the soundness of all decisions taken as a Board.
• Confidential information received by a Director in the course of the exercise of directorial duties remains the property of the Company and it is improper to disclose it, or allow it to be disclosed, unless that disclosure has been authorised by the Company, or the person from whom the information is provided, or is required by law.
• A Director should not engage in conduct likely to bring discredit upon the Company.
• A Director has an obligation at all times, to comply with the spirit, as well as the letter of the law and with the principles of the Code.

Business Ethics

Philosophy

The Board and employees of Neon will abide by all the laws of the jurisdictions the Company works within and seek mutually beneficial relationships in all our dealings with business partners, suppliers and other stakeholders.

Procedures and Guidelines

Neon has implemented a Code of Ethics and Conduct, which provides guidelines aimed at maintaining high ethical standards, corporate behaviour and accountability within the Company. The policy seeks also to help establish a Code of Ethics and Conduct that will attract directors and employees who have similar personal codes of ethics and conduct.

Neon Directors and employees are expected to:

• Respect the law and act in accordance with it;
• Respect confidentiality and not misuse Company information, assets or facilities;
• Value and maintain professionalism;
• Avoid real or perceived conflicts of interest;
• Act in the best interests of shareholders;
• By their actions contribute to Neon's reputation as a good corporate citizen which seeks the respect of the community and environment in which it operates;
• Perform their duties in ways that minimise environmental impacts and maximise workplace safety;
• Exercise fairness, courtesy, respect, consideration and sensitivity in all dealings within their workplace and with customers, suppliers and the public generally; and
• Act with honesty, integrity, decency and responsibility at all times.

An employee that breaches the Code of Ethics and Conduct may face disciplinary action. If an employee suspects that a breach of the Code of Ethics and Conduct has occurred or will occur, he or she must notify management of that breach. No employee will be disadvantaged or prejudiced if he or she reports in good faith a suspected breach. All such reports will be acted upon and kept confidential.