PRINCIPLE 3 PROMOTE ETHICAL AND RESPONSIBLE DECISION-MAKING

Code of Conduct

The Company’s objective is to conduct its business with the highest standards of personal and corporate integrity.  To assist employees in achieving this objective, the Company has developed a comprehensive Code of Conduct which guides the behaviour of directors, officers and employees and demonstrates the commitment of the Company to ethical practices.  The Code of Conduct is incorporated as part of new employees’ induction training and an acceptance form is signed by new employees acknowledging their understanding and on-going compliance with the Code of Conduct and the Company’s policies and procedures.

The Code of Conduct states the values and policies of the Company and complements the Company’s risk management and internal control practices.  The Code of Conduct is reviewed annually and updated to ensure that it reflects current good practice and to promote the ethical behaviour of all employees.  Refer to the Company’s website for a copy of the Code of Conduct.

Share Trading Policy

The Company has developed a share trading policy which prohibits directors, officers and other “potential insiders” from trading in GWA shares during designated periods unless exceptional circumstances exist.  The designated periods are 30 June until the release of the Company’s full year results to the Australian Securities Exchange and 31 December until the release of the Company’s half year results to the Australian Securities Exchange, unless otherwise determined by the Board.

Outside of these designated periods, there are no trading restrictions where the directors, officers and other “potential insiders” are not in the possession of unpublished insider information.  At all times, if an employee possesses unpublished insider information about the Company, that person is prohibited from trading in GWA shares.  In addition, employees must not engage in any active short term trading in GWA shares.

As an additional restriction, the directors must advise the Chairman prior to trading outside the designated periods and confirm to the Chairman that they do not possess unpublished insider information.  The policy also requires the directors to notify the Executive Director within two business days after trading, to enable the Executive Director to lodge the required disclosures with the Australian Securities Exchange.

Diversity in the Workforce

The Company is committed to the promotion of diversity in the organisation through the implementation of targeted employment policies and initiatives to achieve a diverse workforce.  The Board understands the significant benefits that can arise from increasing the pool of talent from which the Company can draw high quality employees and the different perspectives that can be brought to the organisation from a diverse workforce.

The Company’s current employment policies encourage diversity within the workforce and the Board proposes to strengthen its diversity focus through the development and implementation of a specific Diversity Policy containing measurable objectives for the Board to assess.  The policy will be approved by the Board during the 2011/12 year and will be made available on the Company’s website.

In recent years, the Company has introduced a number of diversity related policies and initiatives with the specific aim of increasing the number of women within the workforce, particularly in management positions.  The new policies were implemented to promote ‘Work Life Balance’, assist in attracting more females to apply for positions advertised and retaining the current female employees.  The policies covered flexible work arrangements, phased retirement, career breaks, unpaid leave and paid parental leave.

As outlined in the Company’s 2011 Equal Opportunity for Women in the Workplace Report, the overall workforce consists of 29% women and 71% male.  Of those employees in leadership or management positions, 19% are women.  There are currently no women on the Board or holding an executive position.  However, over a 12 month period the Company has seen an increase in the number of women in senior management positions and they now comprise 18% of senior managers in the organisation which is an increase of 5% on the prior year.

The following table outlines the Company’s workplace profile at 31 March 2011: 

The Company is an active equal opportunity employer which is highlighted in the employee recruitment process, and is compliant with the Equal Opportunity for Women in the Workplace Act 1999.