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Corporate Citizenship

During 2004 we continued our social investment programme by supporting selected charities and carrying out other significant community activities in countries where our businesses operate

The Group’s social investment programmes continued to concentrate on education, health and welfare, local economic development, the environment and the arts during 2004. In South Africa particular attention was given to Black Economic Empowerment and HIV/AIDS.

SOUTH AFRICA

OLD MUTUAL SOUTH AFRICA (OMSA)
 OMSA is committed to growing and investing in socially responsible business activities, employment equity and diversity, skills development and affirmative procurement, as well as sustainable social investment projects and the active involvement of employees in social and community affairs. Its Corporate Citizenship programme recognises the value of non-financial performance and social accountability.

The Old Mutual (South Africa) Foundation (the OMSA Foundation) is the primary source of funds for OMSA’s social investment programme. At the year end, the assets of the OMSA Foundation comprised 14.4 million shares in Old Mutual plc. The Group has also committed as part of the arrangements for the extension, in modified form, of its unclaimed shares trusts, to make a donation of the net amount released on expiry of the original unclaimed shares trusts to its Foundations (or another public benefit or similar organisation) in the five territories where these operate. For South Africa, this will result in OMSA committing an additional R190 million of endowment to the OMSA Foundation or other public benefit causes.

In 2004 some R15.5 million was expended by the OMSA Foundation, of which R8.7 million was devoted to its flagship projects, namely the Rural Economic Development Initiative (REDI), the AIDS Orphans Programme, which has entered its third year and supports the children of orphan-headed households, and the Staff Community Volunteer Programme. This last programme comprises both the Community Builder Programme, through which staff volunteers support a range of community-based projects, and initiatives to encourage and support staff involvement in charities through payroll giving.

OMSA also has a general donations programme. During the year R4.2 million was distributed by way of general donations among 31 education programmes, 42 community development projects and 12 ad hoc projects.

REDI
 REDI had a very active year in 2004, the highlight being a celebratory event in Johannesburg attended by a variety of representatives of Government and the business sector at which the REDI champions mounted a display of their regional products. This event and the annual conference held before it were the first time all the REDI champions had gathered together. REDI continues to make a profound impact on the communities within its network and in 2004 it supported 58 different projects with total funding of R4.1 million.

The community development component of REDI funding was allocated primarily to AIDS and food security projects. A total of 50 individual projects received funding this year. In total some 140 food security and AIDS projects have been established over the past four years.

There was a significant shift in focus in Local Economic Development activities, with funding being allocated during 2004 to fewer, but larger, initiatives with the potential to impact on a greater number of people, such as the establishment of a soya processing plant. In total 18 new businesses were established under this aspect of the REDI programme during 2004. This brings the total over the four years to 211, 123 of which are owned or managed by women, with the creation of 2,000 jobs.

In the area of educational projects REDI supported the “Out of the Box” Environmental Education Programme. A total of R500,000 was provided in the first half of the year towards the development of materials and teacher workshops for this programme, which aims, among other things, to encourage environmental awareness among teachers and pupils.

AIDS Orphans Programme
 Old Mutual has adopted a four-pronged strategy to address the socially and economically crippling challenges caused by the HIV/AIDS epidemic in South Africa. This covers the workplace (employees), the broader community, financial services and advice (customers), and business impacts.

In 2004 OMSA’s AIDS Orphans Programme provided R1.8 million to support around 2,000 orphans and vulnerable children via Heartbeat, Noah, Living Hope Hospice and SOS Children’s Village. It is clear from feedback received that this programme has had a positive impact on the children of orphan-headed households during the three years it has been in operation.

Staff Volunteer Programme
 The Staff Volunteer Programme consists of the Staff Community Builder Programme, “Adopt an Orphan” and the Staff Charity Fund.

In its tenth year the Staff Community Builder Programme supported 101 projects in seven provinces, giving a total of R2 million.

During 2004, 543 staff members committed funds on a regular basis through the Staff Charity Fund. On average R100,000 was paid to various charities and “adopted” orphans on a monthly basis from this fund. Donations were also made to animal welfare, the elderly, abused women and children and HIV/AIDS prevention and treatment. A total of 375 members of staff have “adopted” 650 orphans to date. Of these, 156 receive additional tertiary educational support.

Black Economic Empowerment (BEE)
 The Old Mutual Group remains committed to achieving the targets to ensure it is considered an ‘A’ performer for the purposes of the Financial Sector Charter Scorecard. To this end, initiatives continue to be implemented to develop black management, make sound infrastructural investments, facilitate the entry of black entrepreneurs into corporate South Africa through structuring and investing in BEE deals, and make direct investments into communities and society at large.

OMSA is well on track to achieve its BEE objectives. The company is already a leader in empowerment financing through various structured financing transactions and partnerships with Wiphold, J & J, Aka Capital and Amabubesi. OMSA plays a leading role in social investing and infrastructural investment and asset management, and the company’s robust employment equity programme positions it well to exceed the Charter targets.

In addition, the Group is committed to completing the empowerment ownership transaction required under the Financial Sector Charter.

OMSA will be publishing a more detailed report on its corporate citizenship activities in April 2005, which will be available on the Company’s website www.oldmutual.comfrom April 2005. It will also be obtainable upon request from the Public Affairs Manager, Old Mutual (South Africa), PO Box 66, Cape Town 8000 and from the Director of Corporate Affairs, Old Mutual plc, 5th Floor, Old Mutual Place, 2 Lambeth Hill, London EC4V 4GG.

NEDCOR
 The Nedcor group focused its corporate social investment (CSI) work in 2004 mainly through the Nedbank Foundation, which funded over 450 projects (an increase of almost 100 on the previous year) in the fields of welfare, community development and sustainable development.

Projects were supported throughout South Africa and were grouped through a programmatic approach to ensure higher impact for beneficiaries and optimal use of resources.

The Community Support Programme was launched in 2004 to broaden staff involvement in Nedbank’s CSI work. The programme encourages staff members around the country to act as the Foundation’s eyes and ears, so as to align CSI activities more closely to the business of the bank and identify worthy and relevant projects needing its support, and increase cooperation between Nedbank’s staff, clients and the broader community.

The largest Foundation Programme is the Corporate Collaborative Programme. This involves the raising of capital for larger projects by engaging Nedbank’s corporate and other business clients. The Foundation partners these clients in support of projects that involve relief aid on a larger scale, the building of schools, roll-out of IT infrastructure in disadvantaged areas, and similar ventures. An example is the funding of the Western Cape Red Cross Children’s Hospital.

The Nedbank Heritage Programme supports projects that leave a legacy footprint. These include funding the regeneration of Clarkebury Educational Institute in the rural Eastern Cape.

While the Foundation is primarily responsible for the Nedcor group’s external CSI, its Roots Programme involves Foundation support for employees or the families of employees with relevant, unusual and urgent needs for relief aid, as well as for helping to support objectives under the Financial Sector Charter and the bank’s HIV/AIDS programmes.

The National Economic Development Incubator Programme provides infrastructure for small business development and partners with skills development centres to increase their reach among the poorest communities. Focus is placed on developing artisan, building, mechanical, catering, garment industry-related and agricultural and related skills. It also facilitates relevant community-wide development that assists general upliftment.

In addition to continuing collaborations between the Foundation and the public sector, in 2004 it enjoyed the involvement of prominent politicians at a variety of functions. President Thabo Mbeki presented the first Nedbank Digital Hope IT training container to the community of Makopane. This was a corporate collaborative project involving Hewlett Packard and Nedbank, among others. Labour Minister Membathisi Mdladlana and Deputy Correctional Services Minister Cheryl Gillwald opened the Qalabotjha Multi-Purpose Community Centre at Villiers and Education Minister Naledi Pandor launched the national Readathon campaign in Cape Town and the National Business Initiative Adult Learners Week Campaign at Nedbank.

A national tour by Josh Groban was the latest in a series of collaborative partnership efforts undertaken by the Foundation and Tiger Brands to support the Unite Against Hunger campaign. Beneficiary organisations of this campaign include the O R Tambo Foundation, Heartbeat and African Children’s Feeding Scheme. The Foundation, in conjunction with the O R Tambo Foundation, has undertaken the feeding of approximately 10,000 destitute elderly people on the East Rand for the past nine years. Beneficiaries receive bulk packs of food, designed to last three months at a time. The success of the Josh Groban tour enabled the Foundation to increase the reach and impact of this feeding scheme substantially. As a result, trucks carrying food aid to the destitute on the East Rand, in parts of greater Soweto and in Sharpeville were despatched, with almost 24,000 disadvantaged families being fed.

Non-profit organisations (NPOs) comprise the core of the Foundation’s client base. NPOs rated Nedbank in 2004 as third-highest placed among 70 companies in the category “Good Corporate Grantmaker”, third among 48 companies as “Most Widely Recognised Corporate Grantmakers”, and as having the third biggest CSI budget out of 39 identified companies.

In 2004 Nedbank sponsored the South African Paralympic team, which won 35 medals in total, 15 of them gold, at the Athens Paralympic Games. A Nedbank employee, who was a member of the Paralympic swimming team, won four medals.

The Nedbank Green, Sport and Arts Affinities continued to grow during 2004. Together these have donated over R83 million to environmental, sports and art projects since they began.

In 2004 the Green Trust supported a variety of projects including tree planting, food gardens and species-based projects. More than 30 projects were supported and almost R4 million was given through this trust.

Nedbank again supported the Nedbank Golf Challenge and the day after this prestigious event the Sports Trust held its annual golf challenge, which raised over R1 million for a variety of projects to support golf at a grass roots level.

Donations from Nedbank’s Arts affinity bank accounts grew by 27% in 2004, which increased the amount available for use by the Arts and Culture Trust. R1.2 million was split between nine disciplines and 30 projects. An open-air music and arts and crafts festival received funding, as well as the Jazzart Dance Theatre and the Zanendaba Storytellers.

During 2004, Nedcor revised its environmental policy as part of its commitment to environmental responsibility, also evidenced by involvement with its conservation partner WWF-SA, and its membership of the United National Environment Programme Finance Initiative.

Nedcor is publishing a Sustainability Report in April 2005, which will be available on its website www.nedcor.co.za. It will also be obtainable upon request from the Senior Manager, Corporate Governance and Sustainability, Nedcor Limited, PO Box 1144, Sandton 2196.

MUTUAL & FEDERAL
 Mutual & Federal supports community-based projects that contribute towards the creation of a stable and prosperous society. Funding is directed to projects that are non-profit making in nature. Support is generally given to the same projects each year to establish long-standing relationships. In 2004, R1.6 million of investment was directed to 25 organisations in five areas: education, health and welfare, road traffic safety, crime prevention and conservation/environment. Road traffic safety and crime prevention have a direct relevance to Mutual & Federal’s business, as high accident rates and car hijacking translate into higher insurance costs. Mutual & Federal also supports national initiatives aimed at improving road safety, including the Drive Alive Trust, which promotes safe and responsible driving. Its safety campaigns are particularly visible during the holiday seasons and have resulted in the steady reduction of road accidents and fatality rates.

Six educational projects received funding in 2004, including Thusenang Training and Development, a community project which supports illiterate and unemployed rural women. The project supplies basic courses such as knitting, needlework, embroidery, cooking and nutrition. It also offers advanced courses in business skills, life guidance and AIDS guidance and supplements these courses with job creation projects including bakeries, vegetable gardens and sewing groups.

The National Institute for Crime Prevention and the Reintegration of Offenders (Nicro) was one of the crime prevention projects that received support. Nicro offers help to young offenders and communities to rise above the effects of crime. Its Diversion Programme diverts youth in conflict with the law from the criminal justice system by providing courses on drug abuse prevention, anger management, parenting skills and life skills.

REST OF AFRICA
 The Old Mutual (Namibia) Foundation strives to develop and maintain an effective social empowerment programme, which will have a beneficial impact on health and welfare and education and community development in Namibia. Its approach to social investment is to support activities that are linked to its national agenda and in communities that are close to its business operations.

In 2004 significant donations were made by the Namibia Foundation to national AIDS programmes, Rehoboth Primary and Secondary Schools and the Onamulele Primary School. The Mathematics Teachers’ Support System project, which is aimed at improving examination results in mathematics, was successfully launched in partnership with Nedbank Namibia’s Social Investment Fund.

The Namibia Foundation also supported four other major school education projects, the Cancer Association and the Genadegawe feeding scheme during 2004.

Old Mutual Namibia’s staff participated actively in various community initiatives, including the Mariental “Day of the Homeless”, clean-up operations in Opuwo and Rundu Town Councils, the Erongo House of Safety for orphans in Swakopmund, the Cancer Association, Childline Namibia, and SOS Children Villages’ Christmas Card initiative.

At the end of the year, the Namibia Foundation had assets of N$6.2 million, comprising 300,000 shares in Old Mutual plc and cash and other assets of N$2 million. In addition to these, the Namibia Foundation has received a donation of N$4,354,235 from the Namibian Unclaimed Shares Trust under the proposals approved by the Group’s shareholders in May 2004 relating to the extension of the arrangements for claiming entitlements under the original demutualisation of the Group.

Old Mutual Zimbabwe has a structured social responsibility programme, which is actively involved in the sponsorship of sport, education and health projects.

Old Mutual continued to sponsor the Zimbabwe cricket team in 2004, covering home and away test matches, one-day internationals and overseas tours. The Group continues to believe it is important to support the development of cricket in Zimbabwe.

In 2004 Old Mutual Zimbabwe pledged to support the Jairos Jiri Association, which cares for disabled and blind children from pre-school through to secondary education. Jairos Jiri is an indigenous association established over 50 years ago and now has centres in every major urban area in Zimbabwe. As part of its support, Old Mutual has adopted pre-school centres for the blind and disabled in Harare.

Old Mutual Zimbabwe continued to run the Mathematics Olympiad in conjunction with the University of Zimbabwe. This programme is designed to promote mathematics at high school level and to identify outstanding mathematical talent. In 2004 Old Mutual sponsored two students to the Pan-African Mathematics Olympiad, one of whom won a bronze medal.

At the end of the year, the Zimbabwe Foundation had assets of Z$67,521,018,956, comprising 2,680,000 shares in Old Mutual plc and cash and other assets of Z$531,018. In addition to these, the Zimbabwe Foundation has received a donation of Z$91,452,000 from the Zimbabwe Unclaimed Shares Trust under the proposals approved by the Group’s shareholders in May 2004 relating to the extension of the arrangements for claiming entitlements under the original demutualisation of the Group.

Old Mutual Malawi supported a number of projects in the areas of health and education during 2004, giving a total of MK1.3 million. Sponsorship was offered to medical students through a prize for the top medical student of each class, with financial prizes being awarded to five of them. In 2004 Old Mutual Malawi registered as a member of the Coalition against AIDS. Donations were also given in support of the Red Cross for its work on HIV/AIDS, the Kamuzu College of Nursing and the Kachere Rehabilitation Centre.

At the end of the year, the Malawi Foundation had assets of MK38,523,976, comprising 190,000 shares in Old Mutual plc and cash and other assets of MK2,423,976. In addition to these, the Malawi Foundation has received a donation of MK13,913,369 from the Malawi Unclaimed Shares Trust under the proposals approved by the Group’s shareholders in May 2004 relating to the extension of the arrangements for claiming entitlements under the original demutualisation of the Group.

USA
 Old Mutual Asset Management (OMAM)’s Charitable Foundation supports local communities in need around its Boston headquarters and wherever OMAM has a presence through member firms. The OMAM Foundation continued to focus its efforts during 2004 on making meaningful contributions to its partner organisations in four target areas: community, healthcare, homelessness and emergency/crisis intervention. In 2004, it made 19 direct gifts totalling $278,000, including $25,000 in staff matching.

Grants were made to national organisations such as The Rose Fund, Boys and Girls Club of America and Health Care for All, as well as local organisations including Pine Street Inn, Home for Little Wanderers and Rosie’s Place.

OMAM’s member firms also made a wide range of charitable gifts. Support was provided to healthcare organisations, such as American Cancer Society, St. Jude’s Children’s Hospital, and the Heart Association; cultural organisations, including schools, museums and libraries; and community causes, including The Family Place, Bottom Line and the Bethesda Project.

In addition to making monetary grants through its Foundation, OMAM seeks to promote employee involvement by encouraging employees to take advantage of paid volunteer days, sponsoring company-wide charitable events and matching personal charitable gifts from Foundation assets.

In 2004, more than 65% of OMAM’s employees volunteered in five or more service projects or events. In June, employees joined the JP Morgan Corporate Challenge to benefit the Bay State Games, which provide Olympic-style athletic competitions and developmental programmes for Massachusetts amateur athletes of all ages and abilities. In October, OMAM served another year as a Neighbourhood Sponsor for City Year’s Serve-a-Thon event, at which a team of OMAM employees, family members and friends banded together and worked to restore a local Boston community. Additionally, throughout the calendar year, OMAM employees lent their support to Daffodil Day, benefiting the American Cancer Society, Lee Denim Day benefiting the Susan G. Komen Foundation, and the Winter Clothing Drive benefiting the Salvation Army.

Old Mutual US Life (OMUSL) focused its support in 2004 on the community, arts and education.

Employee gifts to charitable organisations were matched by OMUSL through its matching programme on a dollar-for-dollar basis up to an annual limit of $1,000. During 2004 the projects supported in this way included several cancer foundations, the Baltimore School for the Arts, the Baltimore Shakespeare Festival and several universities.

OMUSL also continued to support employee involvement in charitable organisations such as the Baltimore Child Abuse Centre and Rebuilding Baltimore Together, a community project that repairs and rehabilitates the homes of low-income, elderly or disabled homeowners in Baltimore, where OMUSL’s headquarters are based.

Other organisations supported by OMUSL during 2004 were the Living Classrooms Foundation, an organisation focused on teaching academic and social skills by using community work sites and other real-world environments, and the Salem Children’s Trust, a school with both residential and non-residential programmes that help facilitate a successful transition to public schools and society for emotionally disturbed and abused children.

UK
 The UK/SA schools twinning project, a partnership between Old Mutual plc and the British Council involving six schools from the London Borough of Southwark and six schools in the Cape Town area, began in earnest in 2004. Most of the schools made reciprocal visits during the year and a number of new curricular activities have been developed as a result. Highlights of the first year included the writing of plays, participation in a video-conference link to mark South Africa Freedom Day on 16 June 2004 and a series of special Drum Café workshops in all the schools to celebrate the tenth anniversary of democratic government in South Africa.

The relationships within the twinned schools have been extended, at the instigation of the head teachers, to include all the pupils – far beyond the individual classes and teachers originally allocated to the project, clear evidence of the enthusiasm with which the partnerships have been embraced. Additional funding has also been provided to assist the schools with the development of the programme in 2005.

Old Mutual staff from all its London-based businesses were invited to volunteer as stewards for the Drum Café workshops. A formal volunteering programme centred on numeracy partnering, using a Maths games kit developed by the Group in Cape Town, is now being developed for 2005 and beyond. Staff are allowed two hours a month to spend in the schools if they wish to participate. Additional Maths kits have also been provided to the participating Cape Town schools.

To mark the celebrations in the UK of the tenth anniversary of South African democracy, Old Mutual sponsored the 2004 City of London Festival South Africa series, supporting a number of South African musicians and artists in activities in the UK. The highlight of the festival was a concert in St Paul’s Cathedral where Lady Blacksmith Mambazo performed in front of a full house. A programme of team-building activities was developed for the Company’s UK staff around the festival including arts workshops, Drum Cafés, access to the concerts and other volunteering activities. The Company was delighted to receive a grant of £35,000 from Arts in Business in support of this programme. This funding also helped the Company to run the Drum Café activities in the London schools involved in the twinning project described above. Old Mutual has been nominated for an award for its programme of external and internal events associated with the Festival activities.

The Company operates a staff matching scheme, which supports Old Mutual employees in their own activities to raise money for a wide range of charities. In 2004, these included The Tusk Trust, the Race for Life, a 5km walk which was supported by a group of women from head office, Jeans for Genes Day and Children in Need.

Ad hoc donations were made throughout the year and Old Mutual plc began a three-year supporting role with the South African High Commission’s aim of building a cinema in the High Commission. Old Mutual has committed funds towards the cinema’s running costs. At the beginning of 2005 Old Mutual gave £20,000 to the Disasters Emergency Commission’s appeal for victims of the Tsunami in East Asia.

Other good causes supported by the Bermuda Foundation at the request of the Group’s UK businesses were the Shooting Star Trust and the Friends of the Citizens, a charity which promotes quality education to primary and secondary school age children in an environment that encourages not only intellectual growth, but also spiritual and moral growth.

At the end of the year, the Bermuda Foundation had assets of £4,487,000, comprising 3,650,000 shares in Old Mutual plc and cash and other assets of £107,000. In addition to these, the Bermuda Foundation has received a donation of £25,170 from the Bermuda Unclaimed Shares Trust under the proposals approved by the Group’s shareholders in May 2004 relating to the extension of the arrangements for claiming entitlements under the original demutualisation of the Group.

Old Mutual International continued to support the Guernsey Maths Challenge during 2004. Staff from Fairbairn Private Bank (IoM) Limited, in Douglas, raised money for three Manx registered charities, the Manx Cancer Help Association (Lisa Lowe Centre), The Isle of Man Children’s Society and The Koru Hospital Fund, which provides support for the construction and operation of a hospital in Koru, Kenya, raising a total of over £3,000.

ENVIRONMENT
 As a financial services provider, the Group’s primary aim is to meet the financial needs of its clients. In doing so, the Group recognises that it has an impact on the environment, both directly through the running of its offices and indirectly through meeting the investment needs of its clients.

The Group introduced its environmental policy three years ago and designated Julian Roberts, the Group Finance Director, as the member of the Board responsible for the Group’s environmental performance. Objectives were set and individuals named at business unit level to oversee environmental issues. Monitoring and reporting against Key Performance Indicators (KPIs) fall under these individuals’ control and this discipline is, where possible, being applied across the Group. The Group’s KPIs and environmental targets are reviewed annually to ensure their continuing appropriateness.

The Group’s environmental objectives are:

These objectives are applied across the Group at the business unit level, using best practice in environmental management. Where appropriate, business units have introduced policies more specific to their operations.

Raising environmental awareness continued throughout 2004 and, with the introduction of Environmental Management Systems (EMSs) at many key sites across the Group, specific targets and management plans were put in place to deal with any impact considered significant. The EMSs in place all follow ISO14001 guidelines. Certification is achieved on a site basis and therefore the number of certified sites is increasing as roll-out continues across the Group. EMSs establish guidelines and procedures that, when followed, aid site-specific objectives, target-setting and monitoring. EMSs require regular reviews and this in turn requires the Group to revisit its impacts frequently. The systems in place speed up data collection and enable the Group to track improvements and issues more easily. Data is gathered centrally at least twice a year and reported to the Board. The roll-out of EMSs and raising of employee awareness will continue during 2005. Data disclosure occurs through both Old Mutual South Africa and Nedcor, which each report separately on resource use in their Corporate Citizenship and Sustainability Reports.

The Group has little contact with materials that could do great damage to the environment. It has ensured, where relevant, that it has avoided using materials that may cause harm.

Old Mutual was looking to finalise its commitment to the UK government scheme “Making a Corporate Commitment” (MACC2) in 2004, but this programme ceased before it could do so.

Old Mutual participated in Business in the Community’s Corporate Environmental Engagement Index for the third time in 2004 and submitted data for The Giving List, published by The Guardian and co-ordinated by Business in the Community. Participation in these systems and indices allows the Group to benchmark itself against other members of the financial services industry in the countries where it operates.

In 2004 the Group joined the London Stock Exchange’s Corporate Responsibility Exchange system, allowing it to input information on to a database system to enable interested parties to review information on its environmental and CSR activities without having to contact the Company directly. This tool covers many of the issues previously raised through questionnaires and allows the Group to input data to one common reference point.

HEALTH AND SAFETY
 The Group recognises its obligation to supply its employees with a safe and clean working environment. Data on health and safety compliance are collated and reported to the Board twice yearly via Julian Roberts, the director responsible.

Nedcor is aware of the risk of robberies and attacks at its banking business and works continually to improve its systems to minimise the risk to its employees.

During 2004 there were no significant accidents, and no material health or safety issues at work were reported from around the Group.

FTSE4GOOD/JSE SRI INDICES
 Old Mutual plc is a member of the FTSE4Good Index, the selection criteria for which include working towards environmental sustainability, developing positive relationships with stakeholders, and upholding and supporting universal human rights.

Old Mutual and Nedcor both qualified for inclusion in the JSE Securities Exchange South Africa’s Socially Responsible Investment Index launched in the second quarter of 2004. The JSE SRI Index will measure participant companies’ commitment and performance against a triple bottom line of sustainability in terms of environmental, economic and social impacts.

CODE OF BUSINESS CONDUCT AND ETHICS
The Old Mutual Group has adopted and aims to abide by a Code of Business Conduct and Ethics. This Code is provided to staff, is accessible on the Company’s website and may also be obtained free of charge upon request from the Company Secretary at the registered office.

Martin C Murray
Group Company Secretary
28 February 2005


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