SUMMARY OF CODE OF CONDUCT
ASX’s Code of Conduct (the “Code”) is summarised as follows:
1 The Code applies to ASX employees who include both part time and full time employees,
consultants, contractors, secondees and directors of ASX group companies.
2 Adherence to the Code is a term of employment with ASX. A breach of the Code by any
employee may be subject to disciplinary action including termination of employment.
3 ASX acknowledges that it has responsibilities to shareholders, participants, issuers, employees,
customers, suppliers, creditors, consumers and the broader community. By maintaining
compliance with the Code of Conduct ASX will maintain a high standard of integrity and investor
4 ASX employees must:
(a) act with high standards of honesty, integrity, fairness and equity in all aspects of their
employment with ASX;
(b) comply with all laws and regulations which govern the operation of ASX, its business
environment, and its employment practices;
(c) not knowingly participate in any illegal or unethical activity;
(d) not enter into any arrangement or participate in any activity that would conflict with the
interests of ASX or prejudice the performance of professional duties and comply with
relevant Conflict of Interest policy(s) available to employees on the ASX intranet;
(e) actively promote compliance with laws, rules, regulations and the Code;
(f) not do anything which would be likely to negatively affect ASX’s reputation;
(g) not take advantage of property, information or their position (or opportunities arising from
these) for personal gain or to compete with ASX.
5 It is Management’s task to achieve and the Board’s role to oversee the delivery of shareholder
value through the sustainable and efficient operation of the company and sound reporting and
risk management practices. A statement on ASX’s policy regarding Shareholder Communication
and Shareholder Meetings can be located on www.asx.com.au.
6 ASX seeks to understand the expectations of its stakeholders and to respond appropriately to our
economic, social and governance responsibilities. Details of current community programs that
ASX supports are outlined on www.asx.com.au.
7 Employees must not breach ASX’s confidentiality obligations. Employees must also protect the
confidentiality of information by complying with any policy regarding Clear Desk and Information
Handling and ASX will respect the confidentiality of its employees in accordance with any
relevant policy regarding Surveillance (available to employees on the ASX intranet).
8 ASX and its employees must comply with all relevant laws and regulations concerning
employment as set out in any relevant policy regarding Workplace Diversity and Equal
Employment Opportunity (available to employees on the ASX intranet). Employees must also
comply with any relevant policy regarding Occupational Health and Safety (available to
employees on the ASX intranet). ASX will endeavour to ensure that all employees are treated in a
fair, equitable and honest way.
Australian Securities Exchange Code of Conduct
9 Employees must comply with any policy regarding the Dealing Rules as amended from time to
time and which is available to employees on the ASX intranet and a summary is available on
10 Employee’s must comply with any relevant policy regarding Privacy that regulates the handling of
any personal information that ASX collects (available at www.asx.com.au).
11 ASX also requires employees to comply with other relevant policies located on the ASX intranet
as amended from time to time and which include but are not limited to the following policies
(a) Internal & External Directorships and Company Secretary roles
(b) Electronic Mail
(c) Internet Use
(d) Acceptance of Business Courtesies
(f) Drug and Alcohol
(g) Dress Code
(h) Media Communications
(i) Employee Physical Security
(j) Procurement and Purchasing
12 Employees are required to report violations of the Code using conflict escalation procedures set
out in the relevant policy relating to Whistleblower Protection available to employees on the ASX
intranet. The procedures provide for a staged escalation and involvement of the Managing
Director and the Chairman of the Audit and Risk Committee. The policy underlying the
procedures is to ensure employees are not disadvantaged in any way for reporting violations of
the Code and that the matter is dealt with promptly and fairly.
February 2009 Page 2 of 2