Ethics and conduct

Anti-bribery and corruption

Iluka has zero tolerance for bribery or corruption. The Anti-bribery and Corruption Policy, supported by the Anti-bribery and Corruption Procedure, sets out the standards and behaviour Iluka requires of its Directors, officers, employees, agents, contractors and representatives, and links with the Whistleblower Policy for the reporting of any actual or suspected breaches of the policy. Anti-bribery and corruption training is provided to all employees; and all reported incidents of non-compliance or potential non-compliance are taken seriously, reviewed and investigated. Serious incidents are reported to the Managing Director within 24 hours and to the Audit and Risk Committee at its regular meetings.

Sierra Rutile has a location specific Anti-bribery and Corruption Policy tailored to reflect operating conditions and local laws in Sierra Leone. It contains the key elements of Iluka’s Group policy, including zero tolerance for bribery and corruption.

Iluka maintains a Gift, Entertainment and Other Benefits Register as a record for the receiving or giving of gifts, entertainment or other benefits from or to external parties.

A copy of Iluka’s Anti-bribery and Corruption Policy can be found in the Governance section of our website www.iluka.com.

 Code of Conduct

Iluka seeks to maintain the highest standards of conduct and has a Code of Conduct that identifies the standard of ethical conduct expected of all Iluka employees and contractors.

The Code of Conduct describes the objectives, values and standards of behaviour that employees and contractors must apply to all business practices. In addition, the Board has specifically adopted a Directors' Code of Conduct which establishes standards for appropriate ethical and professional behaviour for Directors.

Iluka treats actual or suspected breaches of its Codes of Conduct and policies seriously and has adopted mechanisms to ensure that suspected breaches are reported and acted upon fairly and effectively. The Code of Conduct is supported by Iluka's Antibribery and Corruption Policy and Whistleblower Policy.

We encourage all employees, Directors, contractors and consultants to raise concerns regarding any misconduct that they believe constitutes a breach of the Code of Conduct, Iluka’s policies or the law. Our Whistleblower Policy outlines the mechanism by which our people can confidently, and anonymously if they wish, raise concerns in a responsible manner without fear of discriminatory treatment, recrimination or reprisal, and with Iluka’s commitment to properly investigate any issues.

Copies of the Code of Conduct, Directors’ Code of Conduct and Whistleblower Policy can be found in the Governance section of Iluka’s website www.iluka.com.

In relation to our Securities Trading Policy and our Continuous Disclosure and Market Communications Policy, all employees must complete training, with additional training required for selected key personnel.