Code of Conduct - SKY

1 code of ConductSky Network Television Limited ( SKY ) has a policy of conducting its affairs incompliance with all applicable laws and regulations and observing the higheststandards of business ethics. Integrity, honesty, forthrightness and fairness are of primary importance in allbusiness relationships involving SKY. SKY expects each employee to deal fairly withthe Company s customers, suppliers and competitors and to perform his or her dutiesin such a manner as to preserve the Company s good name and reputation. SKYintends that the spirit, as well as the letter, of this code be followed by employee of SKY having information or knowledge regarding a breachor a potential breach of these standards should report this to their manager, or a higherauthority if this is more of InterestAlthough employees are generally free to engage in personal financial and businesstransactions, there are certain limitations.

2 No employee or director, or a member of hisor her family, should receive improper benefits as a result of his or her position withSKY. All employees have a duty to avoid situations where their loyalties may bedivided between SKY s interests and their own interest. Employees should avoid eventhe appearance of such a conflict of director shall fully disclose all relationships they have with SKY and relevantprivate or other business interests to the Board, in order that the Board may assess theDirector s and EntertainmentGifts and entertainment should not be given or received if they could be interpreted ascreating an obligation, that an employees impartiality could be affected, or the gifts orentertainment could be perceived to influence a business decision.

3 Reasonable offersof entertainment such as dinner, theatre parties or sporting events may be accepted oroffered. In determining what is reasonable the onus is on the employee to consider notonly the value of the gift or entertainment, but the frequency with which they areoffered, and the circumstances in which they are OpportunitiesDirectors and employees will not take or use any opportunity discovered through theuse of SKY property, information or position for personal will maintain and protect the confidentiality of information about customers,work colleagues, suppliers, stakeholders and SKY s business and financial affairs,except where disclosure is allowed or required by law. Corporate AssetsEmployees of SKY are responsible and accountable for the proper expenditure offunds and use of company assets under their control.

4 SKY s assets are to be used onlyfor proper purposes in accordance with Company RecordsAll SKY data, records and reports must be accurate and truthful and prepared in aproper manner. The integrity of SKY s accounting, technical, personnel, financial andother records is based on their validity, accuracy and completeness. Anyone preparingthe information described above must be diligent in assuring its integrity and anyonecertifying the accuracy of such information should make an inquiry or reviewadequate to establish a good faith belief in the accuracy of the TradingDirectors and employees of the company may not buy or sell securities in thecompany while possessed with inside information, nor may they tip others.

5 Insideinformation is information which is not publicly available and which would be likelyto materially affect the price of the Company shares if it was publicly guidance on insider trading is available in the Company policy on InsiderTrading. Should any employee be uncertain as to whether they possess insideinformation and whether they can transact in SKY shares, they should contact theChief Financial Officer prior to undertaking any and SafetySKY is committed to ensuring that employees and those who work with SKY, do soin a safe environment. Working safely is a condition of every employee semployment. SKY will strive to ensure through sound practices that the safety, healthand well being of all staff is maintained.

6 Specific Health and Safety policies areoutlined in SKY s Health and Safety Manual. Every employee should familiarisethemselves with these policies and their impact on their is totally committed to being non-prejudiced across all society. We will nottolerate discrimination based on race, culture, gender, age, physical ability, religion,sexuality, family status or political belief. More information can be found in SKY spolicy, Equal Employment is committed to minimising any negative effects on the environment. If anyemployee becomes aware of any damage to, or potential damage that may effect, theenvironment, they must immediately report this to the Chief Executive June 2004