Code of Conduct

Nomenclature

Term	Definition
Westlink	Westlink Logistics Pty Ltd.
Personnel	All employees, contractors, and consultants that work for and on behalf of Westlink.
WMS	Westlink Management System.
CEO	Chief Executive Officer.
Conflict of Interest	A situation where a person’s private interests could improperly influence, or appear to influence, the performance of their duties for Westlink — see GOV-POL-019.

Purpose

The Code of Conduct gives a consolidated description of the legal and ethical behaviour we expect of our business and its personnel. It is an important element of our corporate governance framework. It enhances our core values and beliefs, setting the right culture.

Westlink is committed to promoting a culture of corporate compliance and ethical behaviour. We expect personnel to report any matter that may cause financial or non-financial loss to the company or damage the company’s reputation. To meet this commitment, everyone that works at Westlink must comply with internal and external standards.

The Code of Conduct sets the mandatory standards for the decisions we make and the way we work. It is not a full list of do’s and don’ts. Where this Code addresses a topic governed by a Westlink policy, that policy contains the detailed requirements and this Code states the expectation. We reference each policy by document code throughout. All personnel are encouraged to discuss any concerns with their supervisor or other leaders within the business. You are protected from retaliation if you report any misconduct.

It is important that all personnel understand that a violation of this Code will result in disciplinary action, which may include termination.

Scope

This Code applies to all employees, contractors, and consultants that work for and on behalf of Westlink.

Positive Work Environment

Health and safety

Westlink gives health and safety priority over all our activities. We empower all personnel to stop or delay any work where effective risk management controls are not in place. The Work Health and Safety Policy (GOV-POL-002) and the Stop Work Authority Policy (GOV-POL-017) commit us to this. It is of utmost importance that we identify and manage any risks to prevent work-related injury or illness.

Alcohol and drugs

All personnel — including employees, contractors, subcontractors, and consultants working for and/or on behalf of Westlink:

• Must comply with the Westlink Drug and Alcohol Policy (GOV-POL-003); and

• Must not possess, use, consume, distribute, or sell alcohol or illicit unprescribed drugs, or misuse prescribed medication, while performing work for Westlink.

Smoking is a health hazard, and all workplaces are to be smoke-free environments. Smoking is prohibited unless in an authorised designated smoking area.

Environment

Westlink believes excellence in environmental performance is essential to our business success. It is compatible with balancing the economic, social, and environmental needs of sustainable development. All personnel must undertake every activity so as to minimise adverse impacts on the environment and the communities in which we work. This is consistent with the Environmental Management Policy (GOV-POL-004).

Act professionally

Personnel are ultimately responsible for their own conduct. Even so, Westlink management must set out clear expectations for behaviour: you represent Westlink and must uphold our values and principles.

Pursuit of excellence

The Pursuit of Excellence is the philosophy that drives the Westlink culture. It is the ‘Westlink Way’. Through it, we aim to provide superior value to our shareholders. We do this by taking pride in our work and not settling for outcomes that are less than excellent. We expect that you will:

• Take pride in everything you do;

• Seek to improve your skills and knowledge to pursue excellence in every task;

• Not back away from challenges, and not settle for outcomes that are deemed to be less than excellent;

• Implement strong systems and processes that produce consistently excellent outcomes for safety, environmental, people, and financial goals;

• Strive for execution excellence, resulting in flawless project start-up and successful operations for clients; and

• Aim to provide superior value to shareholders.

Respect others

Our working environment should be considerate and supportive, reducing workplace conflicts and stress. A respectful workplace encourages effective communication, strong teamwork, and an overall positive culture, which results in happy and motivated personnel. The Inclusion and Diversity Policy (GOV-POL-010) and the Workplace Behaviour Policy (GOV-POL-006) set the expectations for all personnel.

Follow workplace policies

All personnel must be familiar with and comply with the WMS, including policies, standards, procedures, and supporting documents.

Business Ethics

What are ethics

Business ethics go beyond the law. They are the application of ethical values and behaviours of individuals and the conduct of our organisation in our business dealings. We all have a responsibility to maintain the Westlink values in all dealings, both internal and external to the business.

Gifts and entertainment

Westlink is committed to conducting our business with integrity. We comply with the laws and regulations of the countries in which our business operates, as described in the Anti-Bribery and Corruption Policy (GOV-POL-012). Gifts, hospitality, and sponsored travel can be customary courtesies that build good relationships. They must never influence, or appear to influence, objective and unbiased decisions. The Gifts, Hospitality and Conflicts of Interest Policy (GOV-POL-019) governs gifts, hospitality, and entertainment. It sets out the value thresholds, approval steps, and gift register requirements for giving or accepting them. All personnel must comply with them. When receiving or offering gifts, ask yourself:

• Is the gift being given in the usual social and business context?

• What is the purpose?

• Are you comfortable disclosing the gift?

• Does it contravene the code of conduct of either organisation?

Sponsorships

Any proposed sponsorship agreements must be approved in accordance with the company’s Delegation of Authority.

Avoid conflicts of interest

Personnel must not hold assets or become involved in activities that create a material conflict between their personal interests and those of the company. Even when we act with integrity, the appearance of a conflict of interest alone can present problems. We strive to avoid actual and potential conflicts of interest, and to deal with them responsibly when they arise. The CEO will ensure all matters are properly investigated. GOV-POL-019 sets out the declaration and management requirements for conflicts of interest. These include outside employment that may interfere with your duties, draw on information obtained through your employment, or use company time or resources. The Fitness for Work Policy (GOV-POL-005) sets the fitness-for-duty obligations for second jobs.

Use company assets responsibly

You must not use company resources (funds, property, supplies, or equipment) for personal benefit without authorisation. Such use may be considered theft, subject to disciplinary action.

Data protection

All personnel are obligated to protect Westlink’s information systems and information at all times, in accordance with the Information Security Policy (TEC-POL-001). This includes safeguarding access to any information that is not generally available outside the organisation, for example:

• Intellectual property;

• Contracts and agreements;

• Supplier and customer lists;

• Internal information;

• Marketing plans; and

• Customer data.

Privacy

Westlink is committed to protecting the privacy of its personnel in accordance with relevant legislation and the Privacy Policy (GOV-POL-015).

Maintain confidentiality

Personnel will, throughout the course of their employment or engagement, receive and have access to information that is confidential to Westlink and to our clients. In some cases, intellectual property rights protect this information. All contracts of employment must contain confidentiality and intellectual property clauses. We must also include these clauses in all contracts with consultants, contractors, and other parties who provide services to and on behalf of Westlink. Our standard employment contract refers to Westlink ownership of the work product of personnel.

Both during and after their employment, personnel must protect to the best of their ability any confidential information acquired during their engagement. They must also protect the intellectual property rights of the company, our clients, and our suppliers. Personnel must return all confidential information to the company upon termination of service.

Follow the Law

All personnel must understand and comply with the law and this Code. You must act with honesty and integrity, and exercise good judgement to avoid even the appearance of improper behaviour. The events or circumstances listed within this document are non-exhaustive. Where a specific event or circumstance is not listed, you must act at all times in accordance with the guiding principles of this Code. Consider all your actions and ask yourself:

• Is it legal?

• Is it ethical?

• Does it comply with the Code?

If the answer is no to any of the above, don’t do it, and seek guidance from management. If you are ever in doubt, trust your intuition.

Westlink operates in a number of legal jurisdictions. The company and its personnel are therefore subject to the laws of Australia and the laws of the countries in which we operate. All personnel must understand the legal environment in which they are operating — ignorance of the law does not excuse non-compliance. You must seek professional advice where necessary. In the first instance, seek this advice through the CEO, who will determine any external legal advice required. Aspects of the law commonly encountered include competition and consumer law, health and safety legislation, environmental law, employment law, corporations law, and taxation law. For our transport activities, they also include the Chain of Responsibility obligations committed in QHSE-POL-001.

Financial inducements

A bribe is an offer or gift made with the intent of securing an advantage. It would not have been given if the offer or gift had not been made. Bribery — including bribery of foreign public officials — is unlawful in Australia. Offering, paying, soliciting, or accepting bribes, kickbacks, secret commissions, or similar payments in any form is an unacceptable practice. You must never structure a transaction to conceal or misrepresent the involvement of a party to a transaction (e.g. to conceal money laundering or the involvement of sanctioned countries, entities, or individuals). Violations of anti-bribery law can result in criminal consequences for the individual and for Westlink. The Anti-Bribery and Corruption Policy (GOV-POL-012) sets out the detailed requirements. These include the treatment of facilitation payments, record-keeping, and how to refuse and report demands for payment.

Fraud

Fraud in any form is unacceptable behaviour and subject to disciplinary action.

No anti-competitive behaviour

It is against the law for businesses to act in a way that limits or prevents competition. Examples include contracts, arrangements, or understandings that have the purpose, effect, or likely effect of substantially lessening competition in a market. They also include making agreements with competitors to fix prices. You must elevate any request for such an arrangement to the CEO.

Commercial conduct

Our commercial dealings must be fair and transparent, in accordance with the Supplier and Subcontractor Management Procedure (QHSE-PRO-002) and the Purchasing and Procurement Procedure (QHSE-PRO-005). Sub-contracts must carry the anti-corruption warranties, back-to-back obligations, and termination remedies required by the Anti-Bribery and Corruption Policy (GOV-POL-012).

Share trading and inside information

Australian corporations law prohibits a person from dealing in shares or other securities of a company while in possession of certain information. This is information that is not generally available to the investment community and which, if generally available, would influence the market for those securities. All directors and personnel must act lawfully.

Unlawful discrimination

Unlawful discrimination, harassment, or demeaning behaviour of any kind against any individual or group is unacceptable. All personnel must be familiar with and comply with three policies. These are the Inclusion and Diversity Policy (GOV-POL-010), the Workplace Behaviour Policy (GOV-POL-006), and the Sexual Harassment Prevention Policy (GOV-POL-014).

Equal employment opportunities and practices

Westlink values equal opportunity in the workplace. We treat every person fairly and equitably. We recruit and employ all personnel in accordance with our Equal Employment Opportunity Policy (GOV-POL-009), our Inclusion and Diversity Policy (GOV-POL-010), and supporting procedures. Discrimination or any form of unjust influence on the recruitment process is unacceptable behaviour.

Keep accurate records

It is imperative that we maintain valid, complete, and accurate business records to provide Westlink protection in the event of an audit.

Responsibility

Check your conduct

We act professionally and respectfully. We are ambassadors for Westlink. As such, your conduct in the work environment and at work-related social functions must be professional and respectful at all times. This applies towards our clients, our colleagues, our stakeholders, and the community. You must:

• Behave appropriately in the work environment and at work-related social functions;

• Be accountable for your own decisions and actions;

• Not disparage people or spread rumours;

• Not disclose Westlink’s confidential information without ensuring the recipient is bound by a duty of confidentiality;

• Not engage in or tolerate bullying, harassment, or unlawful discrimination;

• Not engage in favouritism in the selection of staff and/or the people and organisations we work with;

• Treat each other with respect and kindness;

• Support each other; and

• Speak up when you see others doing the wrong thing.

We work as a team and want a working environment where everyone is happy to come to work and achieves their full potential. As part of this, we encourage and support our colleagues.

Reporting potential violations

Westlink is committed to promoting a culture of corporate compliance and ethical behaviour. We encourage the reporting of matters that may cause financial or non-financial loss to the company or damage to the company’s reputation. All personnel are required to immediately report circumstances that may involve a breach of the spirit or the letter of this Code of Conduct. In normal circumstances, report breaches of the Code to your line manager or directly to the CEO. You may make disclosures that qualify for whistleblower protection through the channels in the Whistleblower Policy (GOV-POL-018). The Grievance Resolution Policy (GOV-POL-011) manages personal work-related grievances. You are protected from retaliation when you report misconduct.

Consequences of Non-Compliance

All personnel must comply with the Code of Conduct. Any breach of the Code, prevailing business ethics, or the law is unacceptable behaviour and is subject to disciplinary action. This may result in reprimand, formal warning, demotion, or termination of employment or contract.

Applicable Standards and Legislation

• Criminal Code Act 1995 (Cth)

• Corporations Act 2001 (Cth)

• Privacy Act 1988 (Cth)

• Fair Work Act 2009 (Cth)