RENAISSANCE CODE OF ETHICS

1. Introduction

The Renaissance Code of Ethics governs the conduct expected of the employees of
Renaissance Corporation Limited and its subsidiaries (“Renaissance”). It has been approved
by the Board of Directors.

The Code exists to support Renaissance’s vision, values, corporate goals, and behaviour,
through the establishment of compliance standards and procedures for reporting unethical
conduct.

2. Renaissance’s Values

Renaissance adheres to three fundamental values in all of its business dealings:

• Commitment to our customers and to providing them outstanding service;

• Commitment to our staff and to providing them opportunity to grow and develop; and

• Meeting reasonable shareholder expectations and delivering competitive, sustainable

and profitable growth.

3. Conflicts of Interest

A conflict of interest is a situation where an individual faces competing professional and/or

personal interests that compromise or appear to compromise their ability to act in the best
interests of their employer. Renaissance employees are expected to resolve such conflicts by
acting in Renaissance’s best interests at all times.

Renaissance employees will not, without prior consent from Renaissance:

• Engage in business or commercial activities that might impair, or be seen to impair, the
employee’s ability to act in Renaissance’s best interests;

• Belong to any political party or organisation in anything but their own personal capacity;

• Have any interest, whether as shareholder, director, employee or independent

contractor, in any company or individual that Renaissance competes with;

• Accept any gift, personal benefit, or inducement from any outside party if these
compromise, or may be seen to compromise, any Renaissance decision; and

• Be involved in any other type of activity that interferes with the employee’s ability to act
in Renaissance’s best interests.

4. Receipt and Use of Corporate Information

Renaissance employees will use corporate information obtained during their service with
Renaissance to further Renaissance’s best interests, and not for their own personal benefit or
self interest. This includes trading in shares, or any other type of property, using information
acquired through the employee’s personal experience at Renaissance or information that is not
in the public domain.

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From time to time, Renaissance employees may be entrusted with confidential information by
Renaissance, its customers, other employees, managers, suppliers, and shareholders. This
information may include customer details, personal details of other employees, or information
regarding Renaissance’s business and financial affairs. Renaissance employees will maintain
the confidentiality of this information at all times, except where disclosure is permitted or
required under law.

5. Use of Corporate Assets and Property

Renaissance employees must act responsibly so as to ensure the protection of all

Renaissance assets and resources (including intangible assets such as confidential
information and intellectual property). In particular, Renaissance employees should take care
to prevent the loss, waste, theft, damage or misuse of this property.

Renaissance employees may only use the company’s assets and property to advance lawful
business purposes, with the appropriate authorisation by the company.

Renaissance employees will only create and retain such information and communications as is
necessary for the business’ needs or to satisfy any legal requirements.

6. Directors’ Obligations

Renaissance directors will:

• Give proper attention to the matters before them;

• Act in good faith and in what they believe to be Renaissance’s best interests;

• Exercise their powers for the proper purpose, in compliance with their legal
requirements and Renaissance’s constitutional documents;

• Not agree to Renaissance’s business being carried on in a manner likely to create a

substantial risk of serious loss to the company's creditors; and

• In exercising their powers or performing their duties as a director, exercise the care,
diligence, and skill that a reasonable director would exercise in the same
circumstances.

7. Behaviours and Attitudes

Renaissance employees will observe Renaissance values at all times. This means that they
will undertake their duties with integrity, and in the best interests of Renaissance, as required
by law. This involves dealing honestly with Renaissance’s employees, advisors, customers
and suppliers, and not acting in any way that could bring Renaissance into disrepute.

Renaissance employees will use proper skill, care and diligence in undertaking their duties.
This involves a responsibility to ensure that all Renaissance records and documents are
accurate and produced in accordance with Renaissance’s internal control mechanisms and
reporting standards.

Renaissance employees will respect the dignity of all other persons who are associated with
Renaissance, including customers, managers, or suppliers. This involves:

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 • Not discriminating against any person based on their gender, marital status, religion,
race, colour, ethnic or national origins, disability, age, political opinion, employment
status, family status, or sexual orientation (the prohibited grounds of discrimination
listed in the Human Rights Act 1993);

• Not sexually or racially harassing or bullying any person; and

• Using appropriate and courteous behaviour in all circumstances.

8. Compliance with Laws, Regulations, and Rules

Renaissance employees will, at all times, comply with applicable laws, regulations and rules.
This obligation may require the employee to undergo training.

9. Compliance with Corporate Policies

Renaissance employees will conduct their duties in compliance with all of Renaissance’s
frameworks, procedures, and policies.

10. Delegation of Authority Framework

Renaissance employees work within a Delegation of Authority framework. The Board of

Directors delegates the responsibility of managing all of Renaissance’s business affairs to the
Chief Executive Officer. The Chief Executive Officer then delegates to other management
levels responsibility for certain business, financial, or operational decisions within specific
limits. The Delegation of Authority framework governs this process.

Renaissance employees must only act within the level of authority that has been delegated to
them (if an employee is unsure as to their level of authority, they should consult with the
relevant manager).

11. Breaches of the Code of Ethics

The content of the Renaissance Code of Ethics forms part of every Renaissance employee’s
conditions of employment. Breaches of the Code will be treated seriously, and may result in
disciplinary action. Any issues regarding an ethical question or professional conduct should be
reported to a manager (or manager’s manager) as soon as possible.

There are specific procedures in place for the reporting of any breach of the Renaissance
Code of Ethics, other Renaissance policy, or legal obligation. Any person who receives a
report through one of these procedures has specific responsibilities. The Renaissance Intranet
site contains further information regarding these procedures and responsibilities.

Renaissance will support any employee who, in good faith, reports a breach or serious
wrongdoing. The reporting employee will have their identity kept confidential where possible.
However, any person who falsely reports a breach or serious wrongdoing may be subject to
disciplinary action.

12. Further Information

The Renaissance Code of Ethics is reviewed annually. Any questions or comments regarding
interpretation of this Code of Ethics may be directed to Clive Lewis, Group Finance Director.