1 Purpose

This Code of Conduct promotes practices that foster Colorpak’s key values of:

• maintaining good corporate governance standards;
• acting with fairness, honesty and integrity;
• ensuring compliance with legal and other obligations in respect of Colorpak’s key shareholders, to ensure that Colorpak is dedicated to the broader community and ensuring its role in the community is an honest, legal and ethical one;
• maintaining the highest standards of professional behaviour;
• avoiding or managing conflicts of interest; and
• striving to be a good corporate citizen, and to achieve community respect.

Colorpak is committed to ensuring that the highest standards of honesty, integrity, ethics and legality are upheld and enforced. You are expected to be honest and ethical in dealing with each other, with clients and all other third parties.

This Code of Conduct applies to all employees of Colorpak including all directors of Colorpak and senior management of the Colorpak Group (Senior Executives).

Note: This Code of Conduct is not an employment contract. Colorpak does not create any contractual rights by issuing this Code of Conduct.

2 Responsibilities under the Code

Each of us is responsible for conducting ourselves in accordance with the Code of Conduct whatever our position and role. If you have any doubts about an issue or situation you should notify the Company Secretary.

If you are aware of, or suspect a breach of this Code of Conduct, please report the matter by following the steps outlined in the section dealing with "Reporting unethical or unlawful behaviour" (below). You are expected to comply with any investigations into concerns about breach of the Code or Colorpak’s policies and procedures. Retribution against a person for reporting or supplying information about a Code or policy concern will not be tolerated.

Any person who breaches the Code of Conduct (including by failing to report a suspected breach, or by victimising another for reporting a concern) may be subject to corrective disciplinary action, including, in extreme circumstances, termination of employment for misconduct.

3 Compliance with laws and regulations

Colorpak and the directors and officers of Colorpak are subject to various legal requirements in relation to the conduct of Colorpak’s operations, and their role and responsibilities. These might relate to financial, corporate, disclosure, fair trading and other requirements. Directors and officers also owe a number of duties as a fiduciary of Colorpak. These duties arise at law, and are also preserved in the Corporations Act.

Each of us, whatever our role and position, should be aware of, and comply with, the duties and obligations which apply to us under any laws, legislation or regulations relevant to our work. Employees are encouraged to attend seminars presented by Colorpak or other external service providers to ensure that their knowledge remains up to date and that they remain abreast of relevant legal and industry developments. Assistance is also available to clarify whether particular laws apply and how they may be interpreted.

4 Fair dealing

Colorpak aims to maintain the highest standard of ethical behaviour in ethical business dealings to behave with integrity in all its dealings with customers, shareholders, government, employees, suppliers and the community.

Directors, Senior Executives, employees and contractors are expected to perform their duties in a professional manner and act with the utmost integrity and objectivity, striving at all times to enhance the reputation and performance of Colorpak. Each of us must ensure that our actions, and the actions of those who report to us, deal fairly with Colorpak’s clients, competitors and employees.

You are encouraged to familiarise yourself with the legal requirements applying to fair dealing and to undertake training or attend seminars to develop and maintain your knowledge, so that you can act in accordance with these requirements.

5 Colorpak policies

Colorpak has implemented policies in relation to various matters. You are encouraged to be familiar with and adhere to the requirements of each of the following policies and guidelines at all times:

• continuous disclosure policy
• guidelines for dealing in securities
• OH&S policy
• EEO policy

Copies of these policies are available on the Colorpak website at www.colorpak.com.au.

The Board of Colorpak continually assesses and upgrades its policies and procedures, to ensure compliance with corporate governance requirements and best practice procedures from time to time. You will be notified of any changes to the policies and procedures. You should ensure you regularly make yourself aware of the current policies and compliance requirements.

If you have any questions regarding this Code of Conduct or any of the Colorpak policies at any time, you should contact the Company Secretary.

6 Conflicts of interest

A conflict of interest exists where loyalties are divided. A person can have a potential conflict of interest if, in the course of their employment or engagement with Colorpak, any decision they make provides for an improper gain or benefit to themselves or an associate. A conflict of interest can be defined as an issue that may occur when personal interests, the interests of an associate, or relative, or a duty or obligation to some other person or entity, conflict with a person’s duty or responsibility to Colorpak.

Potential direct or indirect conflicts of interest of employees or those acting on behalf of Colorpak (or their family, relatives, friends or agents) should be avoided. If you are concerned that you have a potential conflict of interest you should disclose and discuss the matter with, and seek direction from, your supervisor or manager, the Company Secretary or the Managing Director.

If you know of a potential or actual conflict of interest, you should report the matter to the Company Secretary for decision and direction.

The following are some common examples that illustrate actual or apparent conflicts of interest that should be avoided, but this is not intended to be an exhaustive list. They are not intended to authorise any of us to act in a particular way as each situation will be different. If you have any doubt about whether a conflict of interest exists, please consult with your supervisor or manager or the Company Secretary.

6.1 Improper personal benefits from Colorpak

You should not exploit your position or relationship with Colorpak for personal gain. For example, conflicts of interest can arise when you or a member of your family receives improper personal benefits as a result of your position. Neither you or your relatives should give unreasonable gifts to, or receive unreasonable gifts from, Colorpak’s clients. We encourage you not to accept a gift in circumstances in which it would appear to others that your business judgement has been compromised, nor put yourself or Colorpak in a position that would be embarrassing if the gift was made public.

6.2 Financial interests in other businesses

You should avoid having a significant ownership interest in any other enterprise if that interest compromises or appears to compromise your loyalty to Colorpak. This will not normally apply to interests in listed entities. However, if you have any doubt about such an investment, you should consult with the Company Secretary.

6.3 Corporate opportunities

You should advance Colorpak’s legitimate interests when the opportunity to do so arises and should not take advantage of property, information, your position or other opportunities arising from your position in Colorpak. (You should also ensure that Colorpak property is used in accordance with ethical standards of conduct - outlined below in the section dealing with "Improper use or theft of Colorpak property").

For example, if you learn of a business or investment opportunity through the use of corporate property or information or your position at Colorpak, you should not participate in the business or make the investment without approval from the Company Secretary or Managing Director. As a general principle, you should not participate in a joint venture, partnership or other business arrangement with Colorpak without approval from the Company Secretary or Managing Director.

6.4 Conflicts with competitors, clients and family members

You must ensure that your actions, and those employees who report to you, deal fairly with Colorpak’s clients, competitors and employees (see also Fair Dealing above).

If you feel a conflict may arise between Colorpak or you and a competitor, client or family member, you should disclose the situation to your supervisor or manager or the Company Secretary so that Colorpak may assess the nature and extent of any concern and how it can be resolved.

7 Improper use or theft of Colorpak property and assets

You are expected to be responsible for protecting any Colorpak property and assets that are under your control and you should safeguard them from loss, theft and unauthorised use. Colorpak property and assets includes cash, securities, business plans, third party information, intellectual property (computer programs, software, models and other items), confidential information, office equipment and supplies.

As a general rule, Colorpak property and documents should not be removed from official premises without a good and proper reason. If removed, they should be stored in a secure manner and covered by appropriate insurances.

You are encouraged to use common sense and observe standards of good taste regarding content and language when creating documents that may be retained by Colorpak or a third party. You should not use Colorpak’s electronic communications systems to access or post material that is pornographic, obscene, sexually-related, profane or which is otherwise offensive or violates Colorpak policies or any laws or regulations. In addition, any use of Colorpak’s electronic communications systems for non-business purposes should:

• be occasional;
• not interfere with your professional responsibilities;
• not diminish productivity; and
• not violate this Code of Conduct or any other Colorpak policies.

8 Privacy

Colorpak respects the privacy of others. We ask you to familiarise yourself with and comply with privacy laws and Colorpak’s procedures in relation to privacy to ensure that you are aware of and discharge your obligations under relevant privacy laws.

9 Continuous Disclosure and public communications

Colorpak has adopted a Continuous Disclosure policy relating to its obligations under the Corporations Act and the ASX Listing Rules to keep the market fully informed of information which may have a material effect on the price or value of Colorpak’s securities and to correct any material mistake or misinformation in the market. You should ensure you are aware of the requirements of the policy, and if it applies to you, you must act in accordance with the policy.

You are responsible for the integrity of the information, reports and records under your control and are expected to exercise the highest standard of care in preparing materials for public communications.

Documents should:

• comply with any applicable legal requirements
• fairly and accurately reflect the transactions or occurrences to which they relate and be supported by accurate documentation;
• not contain any false or intentionally misleading information, nor intentionally misclassify information; and
• be in reasonable detail and recorded in the proper account and in the proper accounting period.

Colorpak has adopted a policy regarding retention of documents and corporate records. You should familiarise yourself with this policy and retain documents in accordance with it.

10 Employment practices

10.1 Equal opportunity and anti-discrimination

Colorpak is committed to:

• equal employment opportunity;
• compliance with the letter and spirit of a full range of fair employment practices and non-discrimination laws; and
• a workplace free from any kind of discrimination, harassment or intimidation of employees.

You must ensure that your actions do not breach these policies.

Colorpak will promptly investigate all allegations of harassment, bullying, victimisation or discrimination and will take appropriate corrective action. Retaliation against individuals for raising claims of harassment or discrimination will not be tolerated.

10.2 Occupational health and safety

Colorpak is committed to maintaining a healthy and safe working environment for its employees. All appropriate laws and internal regulations (including occupational health and safety laws) should be fully complied with. All people have obligations to assist in ensuring that this situation is maintained at all times.

Misusing controlled substances or alcohol or selling, manufacturing, distributing, possessing, using or being under the influence of illegal drugs on the job will not be tolerated.

You should be aware of Colorpak’s OH&S policy and all relevant procedures to ensure the workplace is safe and without risk to the health of others and yourself and follow any lawful and reasonable instructions consistent with that policy and those procedures.

10.3 Securities trading

Colorpak has adopted specific guidelines for dealing in Colorpak’s securities by Directors, officers and employees of Colorpak. You should review that policy and ensure you act in accordance with it.

10.4 Bribes, inducements and commissions

In accordance with the key values set out in this Code of Conduct, Colorpak does not condone the giving or receiving of any bribe, commission or inducement, whether through an intermediary or otherwise, in any circumstance, even if it might be culturally acceptable.

You should not pay or receive any bribes, inducements or commissions (this includes any item intended to improperly obtain favourable treatment). Also, you should not give or receive any unreasonable gifts (see "Conflicts of Interests" above) or otherwise act in an unethical way.

The giving and receiving of bribes, inducements and commissions is against Colorpak’s policy and the laws of many countries where Colorpak conducts business. You are encouraged to familiarise yourself with the relevant legal requirements and you are reminded that breach of these requirements may attract penalties.

11 Community

Colorpak is committed to do business in an environmentally responsible manner and identifying environmental risks that may arise out of our operations. Colorpak has risk management programs in place to address the Group’s obligations under various environmental regulations.

If you are aware of, or suspect, an action that is not environmentally responsible and in breach of the applicable laws and regulations, you should report the matter in accordance with the section dealing with "Reporting of unlawful or unethical behaviour" (below).

You may voluntarily participate in the political process as an individual. We ask that you refer to the Colorpak Continuous Disclosure Policy and comply with the policy in relation to making public announcements and that you do not engage in actions which could cause someone to believe that your actions reflect the views or position of Colorpak if that it not the case.

Colorpak is a responsible corporate citizen and actively supports the communities in which we live and work. We provide information about Colorpak in response to reasonable and responsible requests. We abide by all local laws and regulations. We respect and care for the environments in which we operate. We support and encourage our employees to actively contribute to the needs of the community.

12 Reporting unlawful and unethical behaviour

The Code of Conduct applies to all employees, agents or people associated with Colorpak. It is recognised that breaches may occur from time to time. It is expected that any such breaches will be inadvertent and without intent, however it should be clearly understood that any such breaches may result in disciplinary action or other penalty including, in extreme circumstances, dismissal or termination of the contract or engagement.

If it is considered that a potential breach has occurred it should be reported to the Company Secretary. You will never be penalised for reporting your discoveries or suspicions. Wherever possible, your calls, detailed notes and/or emails will be dealt with confidentially. You have the commitment from Colorpak and the Audit & Risk Management Committee of Colorpak’s Board that wherever possible your privacy will be protected where you make a report under this Code of Conduct.

If you wish to contact management anonymously, you may provide a detailed report to either the Managing Director or Company Secretary.

When it is considered that a breach of the Code of Conduct has occurred, the handling of the process is to be administered by the Company Secretary in consultation with the supervisor or manager of the offending person. Where breaches are considered to be of a serious nature, penalties may be imposed ranging from counselling to dismissal (in extreme circumstances). In such instances Colorpak will act objectively, fairly and equitably and consistent with any applicable provisions or requirements in an employment contract.

Colorpak reserves the right to inform the appropriate authorities where it is considered that there has been criminal activity or an apparent breach of the law.

13 Conclusion

Whilst this Code of Conduct endeavours to address a wide range of business practices and procedures, it cannot anticipate every issue that may arise. You are responsible to ensure that you act ethically and lawfully at all times.

14 Disclaimer

This Code of Conduct is a statement of certain fundamental principles, policies and procedures that govern actions in the conduct of Colorpak’s business. It is not intended to, and does not create any rights in any employee, client, customer, supplier, competitor, security holder or any other person or entity.

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