Speak Up Policy

Winning Group is committed to a culture of integrity. Winning Group’s guiding values help to influence how you behave and interact with others, whether that be with our colleagues, our customers or our suppliers. Winning Group is committed to promoting and supporting a culture of honest and ethical behaviour, compliance and strong corporate governance.

1. Purpose

The purpose of this Speak Up Policy (Whistleblower Policy) is to encourage the reporting of any actual or suspected wrongdoing or any other issues that may be affecting your wellbeing at work or that may be affecting Winning Group, its customers or suppliers.

Winning Group recognises the importance of ensuring a safe, supportive and confidential environment where people feel confident to ‘speak up’ about wrongdoing and feel supported throughout the process.

This Policy establishes the minimum requirements for how Winning Group will foster and encourage a safe and confidential culture of speaking up whilst ensuring there are protections and protocols in place to support those who elect to seek protection as a result of speaking up under this policy.

2. Scope

Our Speak Up Policy applies to all current employees, contractors and suppliers of Winning Group (including its subsidiaries) who wish to make a Report about actual or suspected wrongdoing or any other issue that may be affecting your wellbeing at work or that may be affecting Winning Group, its customers or suppliers.

Reports made under this Policy can be general in nature, or in the event you have concerns for your wellbeing, safety or fear reprisal as a result of making a Report (i.e. speaking up), you can elect to seek protection as under this Policy (refer to 3.1).

3. Speaking Up

3.1. When to Speak Up?

a. Any employee, contractor or supplier who sees or suspects any wrongdoing or any other issue that may be affecting their wellbeing at work, or that may be affecting Winning Group, its customers or suppliers are encouraged to ‘speak up’ and report the issue at the earliest opportunity.

b. Where practicable, you are encouraged to approach your line manager in the first instance (if you are an employee or contractor) or account manager (if you are a supplier) as this provides a practical option to discuss your concerns and for Winning Group to take action where appropriate.

c. Alternatively, if the Report involves your line manager (or account manager), you are encouraged to report your concerns to Team Experience.

d. If you choose to speak up, and in making a Report, feel that it isn’t appropriate to report the issue to your line manager (or account manager), a member from Team Experience or you have concerns for your wellbeing or fears of reprisal as a result of making the Report (i.e. speaking up), you may elect to seek protection as provided for in terms of this Policy.

e. If the nature of your concern relates to a grievance or performance issue, you are encouraged to follow Winning Group’s formal complaint management/grievance procedure. Further information on this procedure can be obtained from the Dispute & Grievance Handling section of this Handbook. Such matters will be deemed not to be protected disclosures for the purpose of this policy.

3.2. Who can be a Whistleblower?

A Whistleblower is any person, whether they be an employee, contractor or supplier of Winning Group (and its subsidiaries) or any relative or dependant of the above, who speaks up and: - Makes a Report relating to any suspected or actual wrongdoing or other issue as defined as Reportable Conduct outlined in 3.3 below; - Makes the Report through one of the reporting channels set out in this Policy; - Makes a report in good faith (refer 3.6 below); and - Seeks to have their disclosure protected under this Policy.

3.3. What is Reportable Conduct?

Reportable Conduct is any conduct (e.g. issue or wrongdoing) which could be considered to be: - Illegal, unethical or improper conduct; - A breach of any legislation, regulation or criminal conduct; - Dishonest or fraudulent conduct (including bribery and/or corruption); - Bullying, harassment or discrimination; - A breach of an internal policy; - An activity that endangers health, safety or the environment; - A Whistleblower protection issue; and/or - Any other inappropriate behaviour.

3.4. How do you ‘Speak Up’?

Winning Group provides a number of reporting channels for employees, contractors and suppliers to ‘speak up’ and report issues.

Winning Group has a ‘Speak Up Hotline’, which is an externally managed and independent hotline service provided by our integrity partners, Core Integrity Pty Ltd (Core Integrity).

Core Integrity are experienced in the management of speak up and Whistleblower reports. The Core Integrity team treat all matters in the strictest of confidence and adhere to the procedures outlined in this Policy.

Any person who wishes to ‘speak up’ and qualify for protection as a Whistleblower, must ensure that they do so as an Eligible Recipient.

Whistleblowers are encouraged to make the disclosure to the CEO. If the disclosure relates to conduct by the CEO, the disclosure may be made to the General Counsel & Company Secretary or any member of the Advisory Board. Alternatively, the disclosure may be made to: - another officer or senior manager of Winning Group; or - auditors or actuaries of Winning Group.

Disclosures to the following will also constitute a protected disclosure: - Relevant regulator: Where necessary, disclosures may be made to ASIC, APRA and the Commissioner of Taxation. - Lawyer: Any disclosure of information made to a lawyer for the purpose of obtaining legal advice or legal representation in relation to the discloser's rights at law will also be a protected disclosure. - Public interest disclosure: In certain circumstances, 90 days after you have made a report in accordance with this policy to ASIC, APRA or a Commonwealth authority prescribed for this purpose by law (the Regulator), and provided that you have reasonable grounds to believe that: a. no action is being, or has been, taken by the Regulator or Winning Group to address the matters you raised in your report; and b. the making of a further disclosure would be in the public interest, you may give limited disclosure of the matter to a member of Parliament or a journalist. Such a step is a serious matter and, to ensure you are protected by law, you should take independent legal advice before taking any such step. - Emergency disclosure: In certain circumstances and provided you have reasonable grounds to believe that the information concerns a substantial and imminent danger to the health or safety of one or more persons or to the natural environment, you may give limited disclosure of the matter to a member of Parliament or a journalist. Such a step is a serious matter and, to ensure you are protected by law, you should take independent legal advice before taking any such step.

3.5. What happens when you make a Report?

When making a report under this Policy, you will be requested to provide as much information as possible about the issue being raised. Information such as dates, times, location, individuals involved, other witnesses, physical evidence (e.g. documents, images) and any other general information may be sought.

This information is important as it enables Winning Group to properly assess the concerns being raised and decide on the appropriate course of action to be taken.

Any information provided in a Report may be used by Winning Group in consideration of an investigation or some other action except in certain circumstances such as a Whistleblower report (Protected Disclosure) where the person speaking up (a Whistleblower) has specifically requested that such information is kept confidential.

3.6. How is your Report Protected?

- If you make any Report under this Policy, you will have your details, and the information you provide, treated in the strictest of confidence. If you are seeking to have your Report (disclosure) protected under this Policy (i.e. a ‘Whistleblower’) you must make your report in good faith with reasonable grounds to believe the Report and information supplied is true.

- Winning Group is committed to ensuring that a person who speaks up in terms of this Policy is provided support and protection from personal or financial disadvantage as a result of making a report in good faith.

- A Whistleblower who makes a report in good faith is afforded protection and Winning Group will not tolerate any form of retaliation against employees, contractors or suppliers who make a Report in good faith under this Policy.

- If a person who speaks up believes that they have been subjected to a reprisal as a result of their Report (disclosure), the first point of contact should be to notify the Speak Up Protection Officer (SUPO).

3.7. Can you remain anonymous?

Any person making a Report under this Policy can choose to remain anonymous, including those seeking protection as provided for in 3.1.

The identity of the person making a Report will be protected unless the person making the Report consents to the disclosure of their identity or if Winning Group has been compelled or permitted by law, regulatory obligations or broader external requirement to disclose the person’s identity.

It is important to remember that anonymous reports can, at times, be more difficult to investigate and if you choose to remain completely anonymous and do not provide any contact information, the SUPO and/or Speak Up Investigations Officer (SUIO) will be unable to make contact with you to ask further questions about your report or provide you with any updates on the investigation or provide you with feedback on the Report.

Should you wish to remain anonymous, you are encouraged to submit your Report via our online reporting channel (web link and/or QR code), refer to 3.4.

If you submit a Report via our online reporting channel, and elect to remain anonymous, you can receive updates on your Report, provide more information and check on the status of your Report by supplying your email address.

Your email address will not be accessible or visible to anyone from within Winning Group or the independent and external provider, Core Integrity, thereby providing you with true anonymity.

3.8. No civil or criminal liability

The fact that a person has made a protected disclosure will not give rise to any civil, criminal or administrative liability (including disciplinary action) on the part of the discloser, and the fact of making the disclosure and its content is not admissible against the Whistleblower in criminal or civil proceedings.

However, the Whistleblower can still be pursued for having made a false disclosure and in connection with the discloser's own conduct which is revealed by the matters highlighted in the disclosed information (i.e., the discloser's own conduct in the misconduct, improper affairs or other circumstances which are revealed by the protected disclosure).

3.9. No breach of contract or enforcement of other rights

Winning Group will not take (and the law prohibits any other person from taking) any action under a contract to which a Whistleblower is a party (including to terminate a contract on the basis that the disclosure is a breach of contract) or seek to enforce any other right against a discloser, solely on the basis of the protected disclosure.

3.10. False Reporting

This policy applies to disclosures where the discloser has objectively reasonable grounds to suspect wrongdoing, or of an improper state of affairs or circumstances in relation to Winning Group or its operations. Accordingly, where it is shown that a person purporting to be a whistleblower has knowingly or recklessly made a false report of wrongdoing, then that conduct itself will be considered a serious matter and that person may be subject to disciplinary action, which may include dismissal in serious cases.

4. Investigation Following A Report

4.1. Stage One

Once a report has been received and assessed, Winning Group will determine the appropriate action required. Examples of actions could include: - the report is forwarded for an investigation to take place; - the report is recorded for information purposes; or - no further action is taken.

If a Report you submitted is recommended for information purposes or for no further action, where practicable you will be contacted and advised of the determination.

4.2. Stage Two

If a report you submitted is recommended for an investigation to take place, an assessment will be made by a member of Team Experience or, in the event of a Protected Disclosure, the Speak Up Investigations Officer (SUIO).

As a general guide and subject to the particular circumstances applying to the disclosure, the steps in the investigation process are normally expected to include the following: - interview you to obtain relevant information; - interview any alleged wrongdoer to obtain a response to the disclosure in so far as it relates to the alleged wrongdoer; - interview any relevant witnesses regarding relevant matters arising from the disclosure; - review any documents or other material relevant to the disclosure; - if necessary, conduct further interview/s with you to obtain further information or a response to material arising from the investigation; and - if necessary, conduct further interview/s with any alleged wrongdoer regarding further material arising from the investigation.

Interviews need not be conducted face to face. All relevant material including interviews and documents obtained during the investigation is then considered and a report prepared.

The report will make findings of fact and determine whether a disclosure has been substantiated or not substantiated, in whole or part. The report may also include recommendations arising from any factual findings.

The Report will be assigned to an appropriate investigator for further action. The investigation may be conducted by the SUIO, a Winning Group employee nominated by the SUIO or by an external investigator appointed by Winning Group.

All investigations will be conducted in a manner that is fair, confidential, objective (without bias) and timely. Winning Group aims, where practicable, to finalise investigations of disclosures within 90 days of the date the disclosure is first made. Where finalisation is not practicable, however, Winning Group will take all reasonable steps to ensure that significant progress is made in relation to a disclosure within 90 days of the date the disclosure is first made.

4.3. Stage Three

At the conclusion of an investigation, you may be informed of the outcome of the investigation by a member of Team Experience, the SUIO or another senior member of Winning Group.

4.4. Discretions

Winning Group may in certain circumstances, whether required by law or in its discretion, inform the relevant authority of any contents of a report made.

4.5. Fair treatment

Winning Group will ensure fair treatment of employees mentioned or implicated in a protected disclosure within the meaning of this policy or to whom such disclosure relates (Relevant Employee) by applying the following principles.

4.6. Confidentiality

To the extent practicable, the ID of a Relevant Employee will be kept confidential during the investigation of a protected disclosure relating to that person.

4.7. Impartiality

An investigator appointed to investigate a protected disclosure will act impartially and without bias in conducting the investigation. An investigator must declare any material personal interest the investigator has in any matter relevant to the investigation for which the investigator has responsibility immediately to Winning Group. The investigator must then take no further part in the investigation unless directed otherwise (other than to provide relevant material or information by way of a handover to a new investigator or to take any necessary incidental action for that purpose).

4.8. Fair process

An investigation into a protected disclosure will follow a fair process including: - informing a Relevant Employee of the substance of a protected disclosure, as far as it applies to the Relevant Employee; - giving a Relevant Employee a reasonable opportunity to respond to any matter referred to above, before the investigation is finalised; - informing a Relevant Employee of any adverse finding directly affecting the Relevant Employee arising out of the investigation; and - giving a Relevant Employee a reasonable opportunity to respond to any such adverse finding before the report is finalised.

Any potential disciplinary action against a Relevant Employee arising out of or as a result of an adverse finding in an investigation report under this policy will be dealt with consistently with Winning Group's usual practice, policy or procedure relating to a disciplinary action.

4.9. Disclosures relating to the CEO

Any disclosure relating to the CEO will be investigated in accordance with this policy but with the CEO's role in the investigation being replaced by another member of the Board (or his or her nominee).

4.10. Support

Relevant Employees will have reasonable access to support made available by Winning Group such as contact with a nominated person and, where relevant, access to Winning Group's Employee Assistance Program (EAP) or similar counselling service. Winning Group will consider any request for other support for a Relevant Employee on a case-by-case basis.

5. Roles And Responsibilities

5.1. Speak Up Protection Officer

1. The Speak Up Protection Officer (SUPO), often called a Whistleblower Protection Officer, is usually a senior employee appointed by Winning Group to, as far is reasonably practicable, protect a person who seeks protection when making a Report and is accountable for the provisions of this Policy.

In respect of Protected Disclosures, the SUPO will: - Provide assistance and support to a person seeking protection for speaking up before, during or after they make a Report in respect of this Policy; - Consider whether the conduct or issues raised amounts to Reportable Conduct; - Enable the investigation of Reportable Conduct; - Maintain the confidentiality, privacy and anonymity (as required) of the person speaking up.

2. Details of Winning Group’s current SUPO can be found on Winning Web on its Speak Up page found at https://web.winning.com.au/policies-and-guidelines/.

5.2. Speak Up Investigation Officer

1. The Speak Up Investigation Officer (SUIO), often called a Whistleblower Investigation Officer, is responsible for leading, co-ordinating or overseeing the investigation of Protected Disclosures made under this Policy.

The SUIO can elect to appoint another party, either from within Winning Group or external to it, to undertake an investigation on their behalf under this Policy and is to ensure that the investigation is conducted in a fair, confidential, objective (without bias) and timely manner.

2. Whistleblower reports will be assessed by the SUIO who will review the Report and decide on the appropriate next steps. The SUIO may be assisted, as required, in determining what the appropriate next steps should be.

3. Details of Winning Group’s current SUIO can be found on Winning Web on its Speak Up page found at https://web.winning.com.au/policies-and-guidelines/.

6. Speak Up Champions

1. As further demonstration of its commitment in fostering a safe, supportive and confidential environment where people feel confident to ‘speak up’ about wrongdoing, Winning Group has appointed ‘Speak Up Champions’ whose role is to act as positive supporters (champions) of this Policy and the commitment to speaking up across the Group.

Speak Up Champions will be senior members of the Group who display Winning Group’s values and they will ensure the intent of this Policy and program is upheld.

Any employee, contractor or supplier can approach a Speak Up Champion to seek advice or assistance in relation to this Policy and program. Speak Up Champions can refer those seeking advice to the appropriate area internally, and where appropriate, take a Report on behalf of an employee, contractor or supplier and submit this through the Speak Up Hotline.

2. Winning Group Speak Up Champions are: - Troy Tindill: Andoo (NZ Andoo) - Amy Cowper: Legal (Group Functions) - Matt Ahern: Team Experience (VIC Academy) - Alyce Hanson: Team Experience (NSW TX Operations) - Lyndsey Richardson: Winning Appliances (WA WA Retail) - Amy Hynes: Winning Appliances (WA NSW Commercial) - Darren Coleman: Winning Appliances (WA NSW Retail) - John Greenstreet: Winning Appliances (WA VIC Retail) - Peter Primrose: Winning Appliances (WA WA Commercial) - Zeena Yousif: Winning Appliances (WA NSW Retail) - Christopher Knight: Winning Group (NSW Technology) - Rob Dunn: Winning Group (NSW Technology) - Sam Shinkins: Winning Group (NSW Marketing) - Tim Fielding: Winning Group (NSW Technology) - Cameron Harrison: Winning Home (NSW Winning Home) - Ben Merchel: Winning Services (NSW Winning Services) - Mathew Verzeletti: Winning Services (NSW Winning Services) - Peter Walker: Winning Services (QLD Winning Services) - Robert Wallace: Winning Services (NSW Winning Services) - Monique Cawood: Winning Services (NSW Winning Services) - Leigh Franks: Winning Services (NSW Winning Services) - Ash Manjhoo: Winning Services (NSW Winning Services)

7. Glossary of Key Terms