Scope
This code of ethics brings together the corporate practices applied by KCM in the conduct of business. It provides a code of conduct for contractors engaged in KCM business as well as giving a clear guide to the behaviour of employees and contractors.

Responsibility
It is the responsibility of all employees and contractors to ensure that they comply with this code and develop strong personal integrity and fair play, to uphold the principles of this policy at all times.

Policy
Code Of Ethics For Employees

General
KCM is committed to a policy of fair dealing and integrity in the conduct of its business. This commitment, which is actively endorsed by the KCM Board of Directors, is based on a fundamental belief that business should be conducted honestly, fairly and legally, The Company expects all employees to share its commitment to high moral ethical and legal standards.

Understanding the Code
This policy outlines the Company's Code of Ethics, which applies equally to all employees and other representatives of the Company. The Code is designed to inform all employees of the Company policies in various areas. Please study the code carefully so that you understand the Company's expectations and your obligations.

Compliance with the Code by all employees and certain other representatives is mandatory. If employees become aware of, or suspect a Contravention of the Code, the matter should be reported to a senior official of the company.

If employees are in doubt about the application of the Code, they should discuss the matter with the person to whom they report or a person at management level who will answer the query or direct them further to the HR or Legal Department.

Compliance With Laws And Regulations
Employees must comply with all applicable laws and regulations, which relate to their activities for and on behalf of the Company. The Company will not condone any violation of the law or unethical business dealing by any employee, including the receipt of payments or favors from suppliers, engaging in business transactions for personal gain, and participation in illegal acts such as bribery or money laundering. Employees must ensure that their conduct cannot be interpreted as being in any way in contravention of applicable laws and regulations governing the operations of the Company.

Conflict Of Interest
The Company expects employees to perform their duties conscientiously, honestly and in accordance with the best interests of the Company.

Employees must not use their positions or knowledge gained through their employment with the company, for private or personal advantage or in such a manner that a conflict or an appearance of conflict arises between the company's interest and their personal interest. A conflict could arise where an employee, a member of an employee's family, or a business with which the employee or family is associated obtains a gain, advantage or profit by virtue of the employee ‘s position with the Company or knowledge gained through that position.

If employees feel that a course of action which they have pursued, are pursuing or are contemplating pursuing, may involve them in a conflict of interest situation, they should immediately make all the facts known to the person to whom they report or to the Vice President – Human Resources or the Company Secretary.

Outside Activities Employment and Directorship
We all share a very real responsibility to contribute to our local communities and the Company encourages employees to participate in religious, charitable, educational and civic activities.

Employees should, however, avoid acquiring any business or participating in an activity outside the Company, which would create, or appear to create:

1. An excessive demand upon their time attention and energy which would deprive the Company of their best efforts on the job; or

2. A conflict of interest that is, an obligation, interest or distraction which would interfere with the independent exercise of judgment in the Company's best interest.

Employees may not take up outside employment without the prior approval of the Manager Human Resources

Employees who hold, or have been invited to hold, outside directorships should take particular care to ensure compliance with all provisions of this code. Special care should be taken if employees intend to become involved in any business, which supplies goods and services to KCM.

When outside business directorships, partnership or consultants are being considered, prior approval must be obtained from the Chief Executive Officer.

Relationships with Clients, Customers and Suppliers
The Company recognizes that relationships with clients, customers and suppliers give rise to many potential situations where conflict of interest, real or perceived, may arise. Employees should ensure that they are independent from any business organization having a contractual relationship with the company or providing goods and services to the company, if such a relationship might influence or create the impression of influencing their decisions in the performance of their duties on behalf of the Company. In such circumstances, employees should not invest in, nor acquire a financial interest, directly or indirectly, in such an organization.

Gifts, Hospitality and Favors
Conflicts of interest can arise where employees are offered gifts hospitality or other favors, which might, or could be perceived to, influence their judgment in relation to business transactions such as the placing of orders and contracts.

An employee should not accept gifts, hospitality or other supplies or goods or services. However, acceptance of the following would not be considered contrary to such policy:

(a) Advertising matter of limited commercial value;
(b) Occasional business entertaining such as lunches, cocktail parties or dinners and;
(c) Occasional personal hospitality such as tickets to local sporting events or theatres, provided that the cost of any accommodation is borne by the recipient.

In addition, no personal favors or other preferential treatment should be accepted by any employee when they are offered because of the employee's position with the Company, and therefore, might tend to place the recipient under obligation.

Personal Investments
The Company respects the right of all employees to make personal investment decisions as they see fit, as long as these decisions do not contravene the conflict of interest provisions of this Code, any applicable legislation, or any policies or procedures established by the various operating areas of the company, and provided these decisions are not made on basis of material non-public information acquired by reason of an employee's connection with the Company. Employees should not permit their personal investment transactions to have priority over transactions for the Company and its clients.

When considering the application of this section, employees should ensure that no investment decision made for their own account could reasonably be expected to influence adversely their judgment or decisions in the performance on their duties on behalf of the Company. In addition, employees who are in possession of material non-public information shall not use this information themselves nor pass such information on to others for their use.

Employees involved in performing investment activities on behalf of the company and those who by the nature of their duties or positions are exposed to price sensitive information relating to the Company are subject to additional rules governing personal investments.

These may be imposed by the Companies Act, Stock Exchanges, Securities Regulation Panel and other regulatory bodies, industry associations and management. The rules include requirements for employees to:

a) Obtain prior approval for, and to report on, their personal investment activity and the investment activity of those persons with whom they have a close relationship; and

b) Refrain from dealing in the shares of the company during certain restricted periods

Remuneration
Employees receive remuneration as determined by their contracts of employment. Employees are not entitled to extra payments outside the regular remuneration system.

No employee may receive commissions or other remuneration related to the sale of any product of the Company, except as specifically provided under an individual ‘s terms of employment.

Employees may not receive any money or thing of value (other than the Company's regular remuneration or other incentives), either directly or indirectly, for negotiating, procuring, recommending or aiding in any transaction made by or on behalf of the Company, nor have any direct or indirect financial interest in such a transaction.

Employment
All employees have the right to work in an environment, which is free from any form of harassment or unlawful discrimination with respect to race, colour, sex, sexual orientation, place of origin, citizenship, creed, political persuasion, age, marital, or family status or disability. An employee should report any cases of actual or suspected discrimination or harassment as set out in the contravention of the Code section of this policy. Employees with illness or disabilities may continue to work, provided that they are able to continue to perform satisfactorily, the essential duties of their jobs, and do not present a safety or health hazard to themselves or others.

Environmental Responsibility
Health and Safety
The Company is committed to taking every reasonable precaution to ensure a safe working environment for all employees

Employees who become aware of circumstances relating to the Company's operations or activities, which pose a real or potential health or safety risk, should report the matter as set out in the contravention of the Code section of this policy.

Use of Resources
The Company is committed to conserving resources used in its business operations. All employees should use their best efforts to make efficient use of resources and eliminate waste

Environmental Management
The Company is committed to developing operating policies to address the environmental impact of its business activities by integrating pollution control, waste management and rehabilitation activities. Employees should give appropriate and timely attention to environmental issues.

Political Support
The company encourages the personal participation of its employees in the political process and respects their right to absolute privacy with regard to personal political activity. The Company will not attempt to influence such activity provided there is no disruption to work place activities and it does not contribute to industrial unrest. Company funds, goods, or services, however, must not be used as contributions to political parties or their candidates, and Company facilities must not be made available to candidates or campaigns.

Company Funds And Property
The Company has developed a number of internal controls to safeguard its assets and demands full compliance with these to prevent fraud and dishonesty. All employees who have access to the Company ‘s funds in any form must at all times follow prescribed procedures for recording, handling, and protecting such funds. Operating areas may implement policies and procedures relating to the safeguarding of Company property, including computer software.

Employees must at all times, ensure that the company's funds and property are used only for legitimate Company business purposes. Where an Employee's position requires Company funds to be spent, it is the individual ‘s responsibility to use good judgment on the Company's behalf and to ensure that the Company receives appropriate value for such expenditure.

If employees become aware of any evidence that the Company's funds or property may have been used in fraudulent or improper manner, they should immediately and confidentially advise the Company as set out in the contravention of the Code section of this policy.  

Company Records
Accurate and reliable records of many kinds are necessary to meet the Company's legal and financial obligation and to manage affairs of the Company.

The Company's books and records should reflect all business transactions in an accurate and timely manner

Undisclosed or unrecorded revenues, expenses, assets or liabilities are not permissible, and the employees responsible for accounting and record-keeping functions are expected to be diligent in enforcing proper practices.

Dealing With Outside Persons And Organisations

Prompt Communications
The Company strives to achieve complete, accurate and timely communications with all parties as well as government authorities and the public with whom it conducts business.
A prompt, courteous and accurate response should be made to all reasonable requests for information and other client communications.
Any complaints should be dealt with in accordance with internal procedures established by various operating areas of the Company and applicable laws.

Media Relations
In addition to every day communications with outside persons and organizations, the Company will, on occasion be asked to express its views to the media on certain issues.
When communicating publicly on matters that involve Company business, employees must not presume to speak for the Company on any matter, unless they are certain that the views they express are those of the Company, and it is the Company's desire that such views be publicly disseminated

Employees approached by the media should immediately contact the Vice presiden-Corprate Relations in the Corprate Relations Dept.
An employee, when dealing with anyone outside the Company including public officials, must take care not to compromise the integrity or damage the reputation of the outside individual, business, or government body, or that of the Company. As a general rule, the Company's position on public policy or industry issues will be dealt with by senior management of the Company.

The text of articles for publications, public speeches and address about the company and its business should be reviewed in advance with the employee's supervisor and the Corporate Relations Dept.

Employees should separate their personal roles from the Company's position when communicating on matters not involving the Company business.
They should be especially careful to ensure that they are not identified with the Company when pursuing personal or political activities, unless this identification has been specifically authorized in advance by the Company.

Privacy And Confidentiality
In the regular course of business, the Company accumulates a considerable amount of information. The following principles are to be observed.

Obtaining and Safeguarding Information
Only such information as is necessary to the Company's business should be collected, used and retained. When personal information is needed, wherever possible it should be obtained directly from the person concerned. Only reputable and reliable sources should be used to supplement this information.