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.

A copy of this whistleblower policy is available to all employees and officers of BIA on BIA’s website and will be available internally on the intranet so that concerns regarding any serious wrongdoing (including unethical, illegal or other improper conduct) can be reported and addressed.

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 dependent of the persons listed above.

These people will be considered as an Eligible Whistleblower for the purposes of this policy and qualify for protection when making a disclosure in relation to reportable conduct.

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. If an eligible person believes something wrong is happening and strongly feels that normal lines of communication will not address the problem, or if they feel threatened about speaking up, this policy provides a confidential means of expressing those concerns. /p>

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 (including but not limited to dishonest conduct, unlawful conduct, corruption or fraud) in relation to BIA or a related body corporate of BIA; or
2. indicates that BIA, or an officer or employee of BIA, or a related body corporate of BIA, or an officer or employee of a related body corporate 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, where the eligible whistleblower considers the information may assist the eligible recipient to perform functions or duties in relation to the tax affairs of BIA or an associate of BIA.

Annexure A describes special protections for whistleblowers who disclose information concerning misconduct or an improper state of affairs or circumstances in relation to BIA under the Corporations Act.

Annexure B describes special protections for tax whistleblowers.

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 relating to an individual‘s employment or former employment (other than as set out in Reportable Conduct), 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 not be deemed to be Reportable Conduct, do not fall within the scope of this policy, and will be typically handled in accordance with BIA’s broader people and culture policies and procedures, which may include its Grievance Handling Policy.

3.4.3. Disclosures that do not relate to Reportable Conduct, or that are malicious or false, do not qualify for protection under the Corporations Act.

How to make a disclosure?

3.4.4. A disclosure of Reportable Conduct can be made by an Eligible Whistleblower in person, by video conference or in writing to any eligible recipient, as set out in this paragraph 3.5.

3.4.5. Disclosures made anonymously may still be protected under the Corporations Act. However, if BIA is not able to contact the Eligible Whistleblower, its ability to conduct an investigation into the disclosure may be limited.

3.4.6. To ensure appropriate escalation and timely investigation, we request that reports are made to BIA’s external reporting pathway, independently monitored by Resolve Advisors via the Elker portal at brother.elker.com/report

3.4.7. The relevant panel member will provide the details of your disclosure to BIA’s external Managing Director and Company Secretary (‘Protected Disclosure Officers’). Reports may be made anonymously but if you provide your contact details to Resolve Advisors via the Elker Portal, those contact details will only be provided to the Protected Disclosure Officer if you consent.

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

1. an “officer” or “senior manager” of the company (or a related entity). These are defined in the Corporations Act as “a director, or a senior manager in the company who makes, or participates in making, decisions that affect the whole, or a substantial part, of the business of the company, or who has the capacity to affect significantly the company’s financial standing”;
2. the external auditor of BIA (or a related entity);
3. an actuary of BIA (or a related entity);
4. the Australian Securities and Investments Commission or the Australian Prudential Regulation Authority;
5. a prescribed Commonwealth authority;
6. a legal practitioner, if you are disclosing for the purposes of obtaining legal advice or representation;
7. where the disclosure about the Reportable Conduct is in relation to tax affairs:
   • 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
8. in instances of a public interest disclosure or emergency disclosure, to a journalist or parliamentarian. For further information regarding a ‘public interest disclosure and emergency disclosure’, please see clause 1317AAD of the Corporations Act.

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 as a result of you making a disclosure.
3. Detrimental treatment includes dismissal, demotion, harassment, discrimination, disciplinary action, bias, threats or other unfavourable treatment connected with making a disclosure.
4. BIA will take all reasonable steps to protect you from Detrimental Conduct and will take action it considers appropriate where such conduct is identified, including by:
   • ensuring the Protected Disclosure Officer and any other eligible recipients who are employees or officers of BIA are trained to identify and report behaviour that may cause detriment;
   • ensuring all employees and officers of BIA are aware of this policy and the right for an Eligible Whistleblower to make a protected disclosure without suffering detriment; and
   • enabling Eligible Whistleblowers to make a complaint to the eligible recipients if they believe they have suffered a detriment.
5. BIA also strictly prohibits all forms of Detrimental Conduct against people who are involved in an investigation of a Whistleblower Disclosure in response to their involvement in that investigation.
6. Some laws provide additional protection for certain disclosures by people who make them in accordance with the provisions of that legislation. These protections are designed to encourage people to disclose unlawful, improper or unethical behaviour to relevant parties. The relevant Australian laws can be found in the Annexures section of this Policy.

3.5.2. Protection of your identity and confidentiality

1. Subject to compliance with legal requirements, upon receiving a report under this policy, BIA will only share your identity as a whistleblower or information likely to reveal your identity if:
   • You consent.
   • The concern is reported to the Australian Securities and Investments Commission (ASIC), the Australian Prudential Regulation Authority (APRA), the Tax Commissioner or the Australian Federal Police (AFP); or
   • The disclosure is allowed or required by law (for example, for the purpose of obtaining legal advice from a lawyer).
2. When making a disclosure, you may do so anonymously and it will remain protected under the Corporations Act. Whilst you are encouraged to share your identity when making a disclosure to ensure BIA is equipped to appropriately investigate and address your disclosure, you are not required to do so at any point, including during the course of an investigation and after any investigation is finalised. If you do not share your identity, BIA will assess your disclosure in the same way as if you had revealed your identity. However, there may be some practical limitations in conducting any investigation if you do not share your identity.
3. necessary to share the information for the purposes of an investigation, all reasonable steps should be taken to reduce the risk that you will be identified. It is illegal for a person to identify an Eligible Whistleblower, or to disclose information that is likely to lead to the identification of the Eligible Whistleblower, except as outlined in clause 3.5.2 (a) above.
4. Whistleblower, except as outlined in clause 3.5.2 (a) above. Further, the non-identifying content of your disclosure may need to be shared in order to report a matter of significance to the Brother Group Compliance Committee.

3.5.3. Protection of files and records

1. All files and records created from an investigation will be retained securely.
2. Unauthorised release of information to someone not involved in the investigation (other than senior managers or directors who need to know to take appropriate action, or for corporate governance purposes) without your consent as a whistleblower or as otherwise allowed or required by law will be a breach of this policy.
3. Whistleblowers are assured that a release of information in breach of this policy will be regarded as a serious matter and will be dealt with under BIA’s disciplinary procedures.

3.5.4. Compensation and other remedies

An Eligible Whistleblower (or any other employee or person) can seek compensation and other remedies through the courts if they suffer loss, damage or injury because of a disclosure, and BIA failed to take reasonable precautions and exercise due diligence to prevent the detriment.

3.5.5. Civil, criminal and administrative liability protection

1. An Eligible Whistleblower is protected from all of the following in relation to their disclosure:
   • civil liability;
   • criminal liability; and
   • administrative liability.
2. However, this does not prevent an Eligible Whistleblower from being subject to any civil, criminal or administrative liability for their own conduct that is revealed by the protected disclosure.
3. BIA will not exercise any contractual right, or seek any contractual remedy, against an Eligible Whistleblower on the basis that the Eligible Whistleblower made the protected disclosure, including termination of contract.
4. Information contained in a protected disclosure made to the Commissioner of Taxation, public interest disclosure or emergency disclosure is not admissible in evidence against the Eligible Whistleblower in criminal proceedings or in proceedings for the imposition of a penalty.

3.6. Investigation of Reportable Conduct

3.6.1. When an Eligible Whistleblower makes a disclosure of Reportable Conduct to an eligible recipient who is an employee or officer of BIA in accordance with this policy, BIA will facilitate an investigation into the disclosure and all persons must ensure they do not breach the protections in Annexures A & B of this policy.

3.6.2. The Protected Disclosure Officer will prepare a Disclosure Report for BIA’s (Code of Conduct) Compliance Committee and an investigation will be instigated if required.

3.6.3. The investigation, as required, will be conducted in an objective and fair manner, and otherwise as is reasonable and appropriate having regard to the nature of the Reportable Conduct and the circumstances.

3.6.4. If the disclosure report involves a member of the Compliance Committee as an accused person, that member will not participate in the ensuing investigation other than as a respondent if called upon.

3.6.5. While the particular investigation process and enquiries adopted will be determined by the nature and substance of the report, in general, as soon as practicable upon receipt of the report, if the report is not anonymous, the Protected Disclosure Officer or external hotline representative will contact you to discuss the investigation process including who may be contacted and such other matters as are relevant to the investigation.

3.6.6. Where a report is submitted anonymously, BIA will conduct the investigation and its enquiries based on the information provided to it.

3.6.7. The investigation:

1. may be undertaken internally or through an external investigator;
2. where appropriate, may be undertaken under client legal privilege;
3. will be undertaken with the purpose of gathering all relevant evidence and in accordance with the rules of natural justice; and
4. will be undertaken in a confidential manner, including compliance with the confidentiality requirements provided in this policy.

3.6.8. Where appropriate, BIA will provide feedback to you regarding the investigation’s progress and/or outcome (subject to considerations of the privacy of those against whom allegations are made).

3.6.9. BIA will ensure the fair treatment of any employees or officers mentioned in the disclosure by:

1. to the extent possible, making the employee or officer aware of the nature of the allegations relating to or mentioning them and updating the employee or officer on the progress of the investigation;
2. giving the employee or officer an opportunity to respond to the allegations relating to or mentioning them; and
3. making the employee or officer aware of support services available to them.

3.7. Investigation of Reportable Conduct

3.7.1. Any breach of this policy by an officer, employee or contractor will be taken seriously by BIA, and may be the subject of a separate investigation and/or disciplinary action.

3.7.2. A breach of this policy may also amount to a civil or criminal contravention giving rise to significant penalties under the Australian whistleblower laws (regimes contained in Part 9.4AAA of the Corporations Act or Part IVD of the Taxation Administration Act 1953 (Cth)).

4. Appendices