Code of Business Conduct and Ethics
The Company has
established a Code of Conduct and Business Ethics to govern the
conduct of its business and operations which is applicable to
all directors, officers and employees of the Company.
Any LonePeaks Drilling
employee or a member of the public who becomes aware of an
existing violation of the Code of Business Conducts and Ethics
of the Company is encouraged to contact and report the violation
either by email, fax or telephone to the Chairman of the GCN
Committee.
All complaints will be
treated on a confidential basis or if so requested, will be
treated on an anonymous basis. In general, an infraction report
or complaint will be disclosed only on a need-to-know basis in
order to investigate the infraction or complaint.
There will be no
retaliation or other action taken against any Lone Peak
Drilling employee who reports a complaint in good faith. Anyone
engaging in retaliatory or mischievous conduct will be subject
to disciplinary action by San Gold, which may include
termination of employment.
Disclosure Policy
The board of directors
of the Company has adopted a Disclosure Policy to ensure that
the Company provides judicious, accurate and balanced disclosure
of material information regarding the Company to investors and
the public. The goal of the Disclosure Policy is to raise
awareness of the Company's approach to disclosure and to ensure
compliance by the Company with applicable securities laws and
regulations regarding disclosure issues. The
Disclosure Policy extends to all directors, officers and
employees of the Company and its affiliates and those persons
authorized to speak on the Company's behalf.
Employee and Insider Trading Guidelines
The board of directors
of the Company has adopted certain employee and insider trading
guidelines to ensure that the Company and its affiliated
entities avoid any activity, or the appearance of any activity,
based on an improper use of confidential material information.
The guidelines apply to "insiders", "associates", persons in a
"special relationship" with the Company and all directors,
officers and employees of the Company or an affiliate.
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