Nordex Explosives Ltd.

> CODE OF CONDUCT | WHISTLE BLOWER | DISCLOSURE & INSIDER TRADING

CODE OF CONDUCT

This policy details Nordex Explosives' policies and practices related to the conduct of business and is reviewed annually and revised as required. Nordex Explosives Ltd. will be referred to as "Nordex" within this document.

OBJECTIVE AND SCOPE

Nordex is committed to conducting business with integrity in a clearly ethical manner and in compliance with all laws applicable to the Company. Nordex will conduct business with honesty, integrity and fairness at all times. Nordex and its employees will compete vigorously and fairly in the market place on the basis of price, quality and service in accordance with competition laws.

This code of business conduct policy applies to all employees of Nordex, its Officers, and Board of Directors. Everyone is responsible for ensuring this policy is followed at all times and any concern or suspected breach of this policy is to be brought to the attention of an officer of Nordex.

STAKEHOLDERS

This policy will guide our relationship with all stakeholders including employees, customers, suppliers, shareholders and the community.

(a) Employees

Nordex values and respects, and expects each employee to respect, the individuality, dignity and worth of every Nordex employee. Nordex encourages, recognizes and rewards individual and team productivity and creativity.

Nordex undertakes to:

- provide a safe and healthy workplace
- maintain a harassment, coercion and discrimination free environment
- treat all employees with respect and dignity
- communicate in an open and timely manner
- respect privacy by protecting the confidentiality of personal information

(b) Customers

Nordex expects all employees to compete fairly and ethically for all business opportunities. All Nordex employees are personally committed to satisfying Nordex customers with products and services which meet or exceed our customers' expectations.

(c) Shareholders

Nordex has a responsibility to protect and enhance shareholder value through the legal and ethical conduct of business.

(d) Suppliers

Nordex will seek to obtain the best value on the basis of price, quality and service while dealing with suppliers with respect and integrity. Nordex employees will act fairly and will avoid real or appearances of impropriety or conflicts of interest.

(e) Community and Environment

Nordex will obey all applicable environment laws in the jurisdictions in which it operates. Nordex is committed to being an environmentally responsible and supportive corporate citizen, dedicated to the protection of the environment and community affected by its operations. Nordex expects that all employees will conduct themselves in a safe and responsible manner so as to avoid risk to the environment.

CONFLICTS OF INTEREST

Nordex's employees must be and must be seen to be independent of any personal interests, social relationships or other personal considerations when conducting company business. When a situation arises where there is a conflict or the possible perception of a conflict, the employee involved must disclose this to an immediate supervisor or to an officer. Appropriate action should be taken to ensure the perception of improper behaviour is avoided.

Situations where an employee would receive some sort of benefit directly or indirectly should be avoided. It is acceptable to receive a benefit, in some situations, where the benefit is of relatively small value and is perceived as normal in the course of business. These benefits are usually available on a regular basis to all competitors and are usually of nominal value. An example would be a lunch or dinner where you are being accompanied by an employee of the hosting firm. The reverse is also true; Nordex employees must refrain from giving a large benefit (unrelated to work) to potential clients or anyone else for that matter.

If a Nordex employee is uncertain of the propriety of a gift or benefit he or she should seek his or her supervisor's advice. In any case, the benefit should never be able to influence or be perceived to influence the judgement/decision of a Nordex employee, client, or potential client.

CONFIDENTIAL INFORMATION

Some Nordex employees have access to corporate information - both Nordex's and that of their partners and customers - that may be sensitive and confidential. This information includes personnel and payroll records, customer information, company strategies, financial and competitive information, and other forms of intellectual property such as patents, copyright, trademarks, technical know-how and processes. Release of these types of information is potentially very harmful to Nordex and its stakeholders. In some cases disclosure is illegal. Employees of Nordex must, therefore, use extreme care when dealing with confidential or sensitive information. Unless otherwise authorized by an officer of Nordex, such information shall not be released to anyone outside of Nordex who is not authorized or legally entitled to receive it. Nordex must take all practical measures required to preserve the confidentiality of such information.

INSIDER TRADING

Nordex employees and directors are required to comply fully with applicable insider trading and securities laws governing transactions for Nordex securities. It is illegal for Nordex employees to trade securities of Nordex or any other company when possessing confidential information which if disclosed could have an effect on the market price of the security. Employees of Nordex must not exploit financial opportunities on the basis of confidential information secured by being an employee of Nordex. This relates to Nordex securities, as well as, any other company.

ENFORCEMENT

Compliance with this policy is a condition of employment with Nordex. If any employee is uncertain of the ethical aspect of any situation they should seek advice from their immediate supervisor or an officer of Nordex.