Whistleblower Policy

Version: 4.0
Last Reviewed: February 2026

1. Purpose

Brother International (Aust) Pty Ltd (‘BIA’) is committed to the protection of individuals who disclose information about illegal or improper conduct occurring within BIA that is of legitimate concern. This policy has been developed to provide a safe and confidential environment where such concerns can be raised by whistleblowers without fear of reprisal or detrimental treatment.

2. Scope

This policy applies to:

1. all employees and officers of BIA;
2. eligible whistleblowers of BIA in accordance with the Corporations Act 2001 (‘Corporations Act’); and
3. eligible recipients of BIA in accordance with the Corporations Act.

3. Policy

3.1. Policy Statement

This policy provides for processes and protections provided by BIA regarding the disclosure of Reportable Conduct. BIA must comply with the obligations relating to protection of whistleblowers in the Corporations Act and equivalent legislation in other jurisdictions.

3.2. Eligible Whistleblowers

Disclosures can only be made by a current or former:

1. officer or employee of BIA (or a related entity);
2. contractor or supplier (or employee of the supplier) of goods and services to BIA (or a related entity) on a paid or unpaid basis, including as a volunteer;
3. associate of BIA; or
4. spouse, relative or dependant of the persons listed above.

3.3. What can be disclosed? (Reportable Conduct)

3.3.1. Disclosures can be about misconduct or an improper state of affairs or circumstances suspected on reasonable grounds that has occurred or is occurring within BIA, including conduct by any BIA employee.

3.3.2. Disclosable matters (‘Reportable Conduct’) includes conduct where the Eligible Whistleblower has reasonable grounds to suspect that the information being disclosed:

1. concerns misconduct or an improper state of affairs or circumstances in relation to BIA; or
2. indicates that BIA, or an officer or employee of BIA, has engaged in conduct that:
   • represents a danger to the public or the financial system; or
   • contravenes the Corporations Act 2001, ASIC Act 2001, Banking Act 1959, Financial Sector (Collection of Data) Act 2001, Insurance Act 1973, Life Insurance Act 1995, National Consumer Credit Protection Act 2009, Superannuation Industry (Supervision) Act 1993; or
   • contravenes any other law of the Commonwealth that is punishable by imprisonment for 12 months or more; or
3. indicates misconduct, or an improper state of affairs or circumstances, in relation to the tax affairs of BIA or an associate of BIA.

3.4. What is not Reportable Conduct?

3.4.1. This policy is not intended to apply to disclosures relating to conduct concerning a personal workplace grievances, such as:

1. an interpersonal conflict at work;
2. a decision relating to employment engagement, transfer or promotion;
3. a decision relating to terms and conditions of employment; or
4. a decision to suspend or terminate employment or to discipline the person.

3.4.2. These matters will be typically handled in accordance with BIA’s broader people and culture policies, such as the Grievance Handling Policy.

3.5. How to make a disclosure?

3.4.4. A disclosure can be made in person, by video conference or in writing to any eligible recipient.

3.4.6. To ensure timely investigation, we request reports are made to BIA’s external reporting pathway: brother.elker.com/report.

3.4.8. Under the Corporations Act, you may also raise the matter with:

1. an “officer” or “senior manager” of the company (director or senior manager who affects the whole business);
2. the external auditor of BIA;
3. an actuary of BIA;
4. ASIC or APRA;
5. a legal practitioner for the purposes of obtaining legal advice;
6. for tax affairs: any employee/officer with tax duties, a registered tax agent, or the Commissioner of Taxation;
7. in instances of public interest or emergency disclosure, to a journalist or parliamentarian.

3.5. Legal protection for whistleblower disclosures

3.5.1. Protection against Detrimental Conduct

1. BIA strictly prohibits all forms of Detrimental Conduct against Eligible Whistleblowers.
2. Detrimental Conduct means any actual or threatened act or omission that could cause a detriment to you (dismissal, harassment, demotion, etc).
3. BIA will take all reasonable steps to protect you, including training eligible recipients and enabling complaints for detriment.

3.5.2. Protection of your identity and confidentiality

1. BIA will only share your identity if you consent, if reported to authorized authorities (ASIC, APRA, Tax Commissioner, AFP), or if required by law.
2. You may disclose anonymously and remain protected.

3.5.3. Protection of files and records

1. All files and records will be retained securely.
2. Unauthorised release of information is a breach of this policy.

3.6. Investigation of Reportable Conduct

3.6.1. BIA will facilitate an investigation into the disclosure and all persons must ensure they do not breach protections in Annexures A & B.

3.6.2. The Protected Disclosure Officer will prepare a Disclosure Report for BIA’s Compliance Committee.

3.6.3. Investigations will be conducted in an objective and fair manner.

3.6.7. The investigation:

1. may be undertaken internally or through an external investigator;
2. may be undertaken under client legal privilege;
3. will gather all relevant evidence in accordance with rules of natural justice;
4. will be undertaken in a confidential manner.

3.6.8. Where appropriate, BIA will provide feedback regarding the progress and outcome.

4. Appendices