Governance

This policy provides information on how we manage the personal information that we hold.

There are some matters to which this policy does not apply. These are referred to in section 12 below.

1. What kinds of personal information do we collect and hold?

The personal information we collect and hold is dependent on your relationship with us and reflects what is reasonably necessary for our business functions and activities. The following are some examples of the types of personal information that we may collect from you directly or indirectly:

• Name, addresses, email addresses, telephone numbers, age and gender;

• Car registration details;

• Financial details including banking information of our suppliers, commercial partners or customers (all debit and credit card information is encrypted and managed in accordance with PCI/DSS standards);

• Whether you have a connection with others whose personal information we may collect or hold (for example, family members who may be linked to your loyalty program membership);

• Your purchase history including what, how, where and when you buy from us or have expressed an interest in buying from us; Your stated or likely preferences, for example whether you may be interested in particular products or promotions;

• Your interactions with our customer service representatives (for example, with prior notice to you, monitoring or recording your conversations with our customer call centre for coaching, training, record keeping and dispute resolution purposes);

• Images, including, your activity at our sites as recorded by 24-hour CCTV video surveillance;

Information collected from competitions and contests (for example, with prior notice, the contestant’s name and address); and

In the context of employment, your name, addresses, telephone numbers, email addresses, qualifications, employment history including records associated with performance and conduct issues, identification documents, referees, emergency contacts, TFN, banking and superannuation details. We may also collect details regarding professional registrations, sanctions with professional bodies, financial and criminal checks, pre-employment medical records (if applicable, with your consent), medical certificates or medical reports supplied to us, potential psychological and drug testing and other publicly accessible data on the Internet. We may also collect photos and video images for compliance purposes

We may also collect health information from you for the purpose of determining any insurance claims or public liability issues involving you or in the context of your employment (including, prospective employment). This information is only used to provide you with those services or to manage such issues. You generally have the option of not identifying yourself or of using a pseudonym when dealing with us, but not where this is impractical (for example, where your images are captured by CCTV) or where the law or a court order provides otherwise. Maintaining anonymity may also limit our ability to assist you or provide you with a product or service, including processing a claim.

2. How do we collect and hold personal information?

We do this when:

• You visit an EG Group website;

• You register with us, for example to create an account, to become a member of one of our clubs or loyalty programs or to send you information;

• You interact with us on social media, online, in-store or over the phone;

• You take part in our promotions, competitions, testimonials, surveys and focus groups;

• You communicate with us online or with our customer service representatives through our call centre;

• You deal with us in other ways involving a need for personal information to be provided such as if claim against us; or

• You apply for or commence employment with us or supply information in the course of your employment.

Most of the personal information we collect and hold about you is from your direct dealings with us. We may sometimes collect your personal information other than from you directly. For example, from other suppliers who, in common with us, have a relationship with you.

3. How do we hold personal information?

Personal information we hold is generally stored in computer systems. These may be operated by us or by our service providers. In all cases, we have rigorous information security requirements aimed at eliminating risks of unauthorised access to, and loss, misuse or wrongful alteration of, personal information. In particular, we use encryption for some of our services, maintain access control for authorised users and have a specialised IT support team to manage security risks. Our security procedures are reviewed from time to time and updated when relevant.

Personal information in our possession may be retained in archival storage. Generally, we will destroy personal information after a period of seven (7) years following its collection unless it is required, or may be required, to be kept for a longer period.

4. Why do we collect, hold, use and disclose personal information?

We collect, hold, use and disclose personal information in ways people would reasonably expect and where it is reasonably necessary for our business, for example:

• To monitor use of our websites and online services, and improve and protect our products, content, services and websites, both online and offline;

• To learn of your likely preferences so that we may promote goods and services to you in a way which may be of most interest to you. This includes the products and services of our suppliers and other trusted partners who offer products and services that may be of interest to you;

• To assist in investigating your complaints and enquiries;

• For account management and verification;

• For our internal business and management processes;

• For use in connection with legal claims, litigation, compliance, regulatory and investigative purposes as necessary;

• For any other purposes that would be reasonably expected by you and to allow us to comply with our obligations under the law or where permitted by law; and

• In the context of employment, to assess an applicants suitability to work with us or supporting an application for leave or assessing your fitness to work or assist with return to work after illness or injury, or as part of assessing liability for and managing any workers compensation claim.

We also disclose personal information we collect for purposes which are incidental to the sale and promotion of our goods and services to you. For example, we may disclose your personal information within our group, to service providers who assist us in our day-to-day business operations and as part of buying or selling businesses.

5. Direct Marketing.

We may anonymise and aggregate your personal information to determine preferences and shopping patterns. We share this anonymised data with our trusted partners to assist them in marketing products and services to you that are likely to be relevant to your interests and preferences.

If you have consented to receive direct marketing material, you may receive offers that are tailored towards your preferences based on the information provided to us by you, your use of our websites and applications, your membership with our loyalty programs and other digital channels. You have the right to opt-out of direct marketing at any time. You can do this by following the instructions on our direct marketing material

6. Website and app tracking.

We may also indirectly collect personal information about you by accessing data from other sources and then analysing that data together with the information we already hold about you in order to learn more about your likely preferences and interests. When you visit our websites, social media pages or mobile applications or click on our advertisements on the online media of other companies, we may collect information about you using technology which is not apparent to you, for example cookies. This may include your purchase history, electronic device information, IP addresses, log information, browser type and preferences, location information, online identifiers to enable cookies and other similar technologies. You can control and set your cookies preferences by changing your browser settings.

7. How can you enquire about, access and correct your personal information?

Access to personal information: We will provide you with access to any of your personal information we hold (except in limited circumstances recognised by law). If you wish to access your personal information or have an enquiry about privacy, , please contact our Privacy Officer at privacyofficer@eg-australia.com or by calling us on 1300 655 055

Alternatively, you can write to us at:

Privacy Officer
Euro Garages Australia
Level 39, Northpoint 100 Miller Street, North Sydney, NSW 2060

Before we provide you with access to your personal information we may require some proof of identity. We may charge a reasonable fee for giving access to your personal information if your request requires substantial effort on our part.

Correction of personal information: We take reasonable steps to ensure that the personal information we collect and store, use or disclose is accurate, up-to-date and complete. However, we rely on you to advise us of any changes to your information to help us do so. If you believe your personal information requires correction, please contact our Privacy Officer at one of the above contact points.

8. How can you complain about our management of personal information?

If you wish to complain about a breach of the privacy rules that bind us, you may contact our Privacy Officer at one of the above contact points. We may ask you to put your complaint in writing and to provide details about it. We may discuss your complaint with our personnel and our service providers and others as appropriate.

Our Privacy Officer will investigate the matter and attempt to resolve it in a timely way. Our Privacy Officer will inform you in writing about the outcome of the investigation. If our Privacy Officer does not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, our Privacy Officer will inform you that your complaint may be referred to the Privacy Commissioner for further investigation and will provide you with the Commissioner’s contact details.

9. Sharing your personal information overseas.

Data is shared internally, across EG Australia and its affiliates, with our international colleagues for the purposes of tracking the usage and functionality of our websites. It is our policy to require all of our overseas sharing of personal information to be done in a way which requires observance of strict privacy and security standards, both during transit and at the overseas destination. We may allow your personal information to be shared with those who are in countries other than your own location. We do this:

• Where we have made a business decision to store our data with a trusted service provider who is in the business of providing technical/network support, data storage, analysis and processing services. Examples are those who store and process our email and mobile application data. These services commonly involve diverse geographic locations which change from time to time for reasons which include data protection and processing efficiency. These countries may include the UK, the US, India and countries within the European Union;

• For disclosures between our group companies. Our main business locations are in Australia but our ultimate holding company is based in the United Kingdom and it has subsidiaries based in other countries, including the US and within the European Union; and

• Where you are involved with public liability issues concerning a product, we may disclose your personal information to any overseas supplier of such a product in the course of managing those issues.

• If you would like more information about the safeguards we employ when transferring your data oversees, or details about the data accessed by overseas recipients, please contact our Privacy Officer at one of the above contact points.

10. Changes to our Privacy Policy.

This Privacy Policy is current at the date below and is available on our website at www.eg-australia.com.

We may amend our Privacy Policy from time to time to take into account new laws and technology, changes to our operations and practices, and the changing business environment. By continuing to use our website or applications, and continuing to provide us with your information, you confirm your acceptance of these changes.

11. Other privacy terms and limits of this policy.

This is a policy. There may be additional privacy notices and terms relevant to you depending on the nature of your dealings with us and on our particular businesses.

EG Group and our associated entities website may also provide links to other sites for you to access. You should be aware that these other sites are not subject to this Privacy Policy or our privacy standards and procedures. You will need to contact them directly to ascertain their privacy standards.

12. More information.

More information about privacy law and privacy principles is available from the Privacy Commissioner. The Privacy Commissioner may be contacted at www.oaic.gov.au (email- enquiries@oaic.gov.au ) (Australia).

1 Purpose

EG Group (Australia) Pty Ltd and its subsidiaries (EG Australia) is committed to conducting its business with the highest standards of honesty, integrity and accountability. Our Code of Conduct and other guidelines and policies seek to ensure we operate in accordance with these standards.

EG Australia encourages a culture of openness and accountability. We expect all team members to maintain high standards, and to speak up and provide feedback when they see activity or behaviour that they feel is wrong or does not match our ways of working.

The purpose of this policy is to provide clear guidelines on how we approach and manage this feedback and establish a framework for EG Australia to comply with its legal obligations regarding whistleblower protection.

This policy sets out the procedure for you to speak up confidentially, and anonymously (if you choose), to raise genuine concerns you may have about misconduct in our business or operations without fear of reprisals and with the knowledge that all reports will be taken seriously and investigated appropriately.

Please note that this policy is not to be used for the purpose of raising a complaint specific to the employee’s own personal circumstances. Personal issues of concern or complaint must be raised using EG Australia’s grievance policies and procedures.

2 Reportable conduct – what can you report?

We want to hear from you if you witness or know about any actual or suspected Reportable Conduct. Reportable Conduct includes:

• A breach of law or regulation;
• Conduct which is unethical, dishonest, fraudulent, corrupt or involves a conflict of interest;
• Conduct which creates an unsafe environment or otherwise endangers health, safety or the environment;
• Any breach of our Code of Conduct or any of our company’s policies;
• Inappropriate work behaviour (e.g. discrimination, harassment and bullying);
• An improper state of affairs or circumstances or misconduct in relation to EG Australia.

Any concerns reported should be legitimate and have a proper basis. Before making a report, you should have reasonable grounds to suspect that the information you will provide indicates that one of the above matters is occurring or has occurred. Making deliberately false or vexatious reports will be viewed seriously and will not qualify for any internal or legal protection.

3 Reporting Concerns

We encourage you to raise any concerns you have with your team leader or your People & Culture partner. However, we understand you may not always want to raise matters internally for reasons including:

• you feel that raising the issue internally could result in adverse consequences;
• you feel that, if you raised the matter internally, it may not be dealt with objectively; or
• The matter has already been raised internally, but you think it has not been addressed appropriately.

Our Speak Up service (Stopline) offers an independent avenue (external to EG Australia) where you can confidentially raise the matters listed above (see details below).

3.1 Reporting within EG Australia or via Stopline

If you would like to make a report, you can:

• Speak with any senior member of the People & Culture team, any senior manager or officer of

EG Australia¹;

• Speak to our auditor or a member of an audit team conducting an audit;
• In case of a disclosure under the Tax Act, any other employee or officer of EG Australia who has functions or duties that relate to the tax affairs of EG Australia;
• Use our confidential 24/7 third party operated Speak-Up service (Stopline) by:
  • Making an online report: https://eggroup.stoplinereport.com ;
  • Sending a confidential anonymous email: eggroup@stopline.com.au ;
  • Making a confidential phone call on the team member hotline: 1300 304 550;
  • Writing a letter addressed to: C/o Stopline, P.O. Box 403, Diamond Creek,VIC 3089 .

When making a report, please provide as much information as possible to enable an investigation to be conducted. For example, please include the date, time and location of the relevant incident or matter, the names of persons involved, any possible witnesses and any available evidence to support the report.

Please note: A disclosure via Stopline is not a protected disclosure (see section 7 below).

1 Note: ‘officers’ include an EG Australia director or company secretary; A ‘senior manager’ is a person whose decisions affect at least a substantial part of EG Australia, or have the capacity to significantly affect EG Australia’s financial standing.

4 Confidentiality and anonymity

Our Speak Up Platform is operated by an independent third-party provider.

Even if you provide your details like your name, these details will be kept confidential.

You can choose to remain anonymous or to reveal your identity at the time of (or after) making a Speak Up report or a protected disclosure.

In either case, an anonymous email address, or a pseudonym you may choose will assist EG Australia in seeking further information and clarity from you. During such conversations, you can choose not to answer any follow-up questions, if you feel it could reveal your identity. In some cases, anonymity may limit the ability to investigate and deal with the matter.

The information you provide (including your identity) will be stored securely in access-controlled systems, and will not be shared without your consent unless it is reasonably necessary for managing and investigating the issues raised in your report, we are required by law to disclose the information or the disclosure is necessary to protect a person’s health, safety or welfare.

5 How will we investigate and handle reports?

Stopline will assess each report and provide appropriate details to the Chief People Officer (CPO) or their delegate. Each report will be handled confidentially, where it is practicable and appropriate in the circumstances.

The CPO or their delegate will:

• acknowledge receipt of the report; and
• assess the report to determine applicable protections, triage, review, and allocation for investigation as appropriate. The CPO will consult with the General Counsel (or their equivalent) (“GC”) where required.

EG Australia will appoint a case manager to investigate a report or a protected disclosure where sufficient information is provided to warrant an investigation. The objective of an investigation is to determine whether there is enough evidence to substantiate the matters reported. Investigations will be carried out objectively, fairly and independently following due process without bias. They will typically be conducted by an investigator independent of the relevant function or division involved, and allow any persons against whom allegations are made or whom is the subject of a disclosure an opportunity to respond. In some cases, an investigator external to EG Australia will be engaged (for example, due to a potential conflict of interest or the seniority of those involved). If required, a suitable person will be appointed to manage the case and carry out the investigation.

The case manager will provide relevant management and the informant with regular progress updates. The nature of the updates will depend on the circumstances. For example, we will not provide information that may compromise the investigation or the disclosure of confidential information. You will be informed when the investigation has been completed, but will not routinely receive details on findings into each of your allegations.

Once the investigator has finalised their investigation and report, management and the informant will be updated. Management will consider, and if appropriate, implement any recommendations made by the investigator.

The duration of a formal investigation will depend on the circumstances including the number of allegations, witnesses and other factors. However, EG Australia’s intent is to complete an investigation as soon as practicable.

Anyone involved in an investigation, whether as an investigator, witness or decision maker, must treat information related to the investigation as confidential.

If, after receiving the summarised report of the investigation, the person making the report is not satisfied with the result, they can escalate this to the CPO and/or the GC. The informant can provide this escalation in writing so that a formal review can take place. While the CPO and GC commit to review the request, EG Australia is under no obligation to reopen the investigation. If the CPO or GC concludes that the investigation was conducted properly and no new information exists that would change the results of the investigation, the investigation will be concluded.

In cases of a protected disclosure (see section 7), EG Australia will report findings of an investigation to the GC. The method for documenting and reporting the findings of an investigation will depend on the nature of the disclosure and the circumstances. Reporting of findings will have regard to applicable confidentiality requirements.

6 What support and protection is provided?

EG Australia is committed to protecting you, including against adverse consequences or victimisation as a result of raising a matter, and by protecting your identity and maintaining confidentiality.

6.1 Protection of your identity (confidentiality and anonymity)

EG Australia will protect your confidentiality whether you choose to reveal your identity or remain anonymous. Reports received via the Speak Up service are handled by an independent third party.

EG Australia seeks to protect the confidentiality of an informant’s identity, including by:

• storing information about a disclosure securely;
• redacting the informant’s identity from relevant documents; and
• only sharing the informant’s identity with those who have a legitimate need to know, subject to the consent provided by the whistleblower.

6.2 Protection from detrimental acts or omissions

EG Australia strictly prohibits and will take reasonable steps to protect an informant from retaliation and victimisation. Where a report is made in good faith, even where it is ultimately unable to be substantiated, EG Australia will protect them from the following in relation to the report:

• Being terminated or having their employment ceased;
• Performance management;
• Harassment on the job or workplace bullying;
• Warnings or disciplinary actions;
• Discrimination; or
• Any other action that can be perceived as retaliation for making a report;

Any team member who discloses your identity inappropriately, or causes detriment to you, may face disciplinary action, including potential termination.

EG Australia may, on a case by case basis, in order to protect an informant from the risk of retaliation, take certain protective action to allow you to perform your duties from another location or in another role at the same level, or make other modifications to your workplace or the way you perform your work duties, or allow you to take leave or reassign or relocate other staff involved in the disclosable matter.

If you feel your report of retaliation was not resolved adequately, you can escalate this in writing to the Chief Executive Officer who will investigate the matter and process for how the retaliation was dealt with.

You may also wish to seek independent legal advice in connection with the disclosure.

6.3 Support for others involved in the investigation

Other parties that might have to bear witness or are involved in the investigation will be protected from retaliation in the same manner as the informant.

6.4 Coaching and counselling

EG Australia also understands that speaking up and being involved in any subsequent investigation can be stressful. Therefore, our Employee Assistance Program, Telus Health, is available to all employees. It is a free and confidential counselling service which can provide strategies on how to minimise and manage stress, or other challenges resulting from your report or its investigation. Benestar can be reached by calling 1300 360 364.

6.5 Separation of issues

EG Australia will be able to still raise any issues related to work or performance related issues. While EG Australia will protect the informant from any retaliation, it is also important that they are still effective in their job. EG Australia can still raise any performance or contract issues with the informant as long as they are kept separate and not influenced at all from any reports that have been made.

6.6 Court orders – compensation and other remedies

Courts are also given broad scope to make orders remedying a detriment or threatened detriment.

These include injunctions, compensation orders (including against individual employees and their employer), reinstatement, exemplary damages and the making of apologies. Civil and criminal sanctions also apply to breaches of the Corporations Act, the Tax Act and other applicable legislation.

7 Disclosable matters and ‘whistleblower’ protections

Some of the matters listed above may also be a “disclosable matter” under the Corporations Act 2001 (Cth) (Corporations Act) or Taxation Administration Act 1953 (Cth) (Tax Act). If so, and you meet specific requirements, you may receive additional protections under those laws, and your report is known as a “protected disclosure”.

7.1 What is a “disclosable matter”?

In order to qualify for protection under the whistleblower laws, your disclosure must be about a “disclosable matter”.

Information is a “disclosable matter” under the Corporations Act if the eligible whistleblower has reasonable grounds to suspect that the information disclosed:

• concerns misconduct or an improper state of affairs or circumstances in relation to EG Australia. Misconduct may include:
  • illegal conduct by EG Australia or its employees/officers, such as theft, dealing in, or use of illicit drugs, violence or threatened violence, and criminal damage against property;
  • fraud, money laundering or misappropriation of funds;
  • offering or accepting a bribe;
  • financial misstatement or irregularities;
  • failure to comply with, or breach of, legal or regulatory requirements; and
  • engaging in or threatening to engage in detrimental conduct against a person who has made a disclosure or is believed or suspected to have made, or be planning to make, a disclosure;
  • negligence; and
  • breach of trust and breach of duty (not just the personal conduct of an individual)

• Indicates that EG Australia or any employee or officer has engaged in conduct that:
  • constitutes an offence against, or a contravention of, a provision of any of the following:
    • the Corporations Act;
    • the Australian Securities and Investments Commission Act 2001;
    • the Banking Act 1959;
    • the Financial Sector (Collection of Data) Act 2001;
    • the Insurance Act 1973;
    • the Life Insurance Act 1995;
    • the National Consumer Credit Protection Act 2009;
    • the Superannuation Industry (Supervision) Act 1993;
  • constitutes an offence against any other law of the Commonwealth that is punishable by at least 12 months’ imprisonment;
  • represents a danger to the public or the financial system; or
  • is prescribed by any regulations made under the Corporations Act.

Information is a “disclosable matter” under the Tax Act if:

• The eligible whistleblower has reasonable grounds to suspect that the information concerns misconduct or an improper state of affairs or circumstances in relation to tax affairs of EG

Australia or an associate of EG Australia; or

• The eligible whistleblower considers that the information may assist the eligible recipient to perform functions or duties in relation to the tax affairs of EG Australia or an associate of EG Australia.

7.2 What is not a protected disclosure?

Except in certain circumstances, personal work-related grievances will not be protected under the Corporations Act. A disclosure is a ‘personal work-related grievance’ if:

• it concerns the whistleblower’s employment and has implications for them personally; and
• the information:
  • does not have significant implications for EG Group, or another regulated entity, that do not relate to the eligible whistleblower; and
  • does not concern conduct, or alleged conduct, referred to above.

Examples of personal work-related grievances that do not qualify for protection may include:

• the eligible whistleblower having an interpersonal conflict within the workplace;
• the eligible whistleblower being inadvertently underpaid once;
• the eligible whistleblower being subjected to discipline or not receiving a promotion; or
• any matters that don’t have significant implications for EG Australia as a whole, unless they relate to the eligible whistleblower being victimised for making a previous protected disclosure.

A personal work-related grievance may still qualify for protection if it relates to a disclosable matter and a personal work related grievance (i.e. it is a mixed disclosure); or the eligible whistleblower seeks legal advice or legal representation about the operation of the whistleblower protections under the Corporations Act.

EG Australia takes personal work-related grievances seriously. They should generally be raised with your manager or People & Culture partner.

7.3 Eligible whistleblowers

While we encourage anyone to report any legitimate concerns of misconduct, only certain “eligible whistleblowers” reporting “disclosable matters” under this policy may receive protections under law.

An “eligible whistleblower” reporting under this policy and therefore entitled to legal protections, includes any current or former:

• Employees (including, any contractors) or directors;
• Business partners, suppliers or any employees of our business partners or suppliers; or
• Any associate of the above, including, any relative, spouse or dependant.

7.4 Protection from legal action

Eligible whistleblowers who make a protected disclosure under the Australian whistleblower laws are protected from certain legal action in relation to having made the disclosure, including:

• any civil, criminal, and administrative (including disciplinary) action against the whistleblower; and
• contractual action, including termination of a contract on the basis that making a disclosure is a breach of that contract.

Any information that is disclosed as part of a protected disclosure to either:

• ASIC, APRA or a prescribed Commonwealth authority, under the Corporations Act; or
• The Commissioner of Taxation, under the Tax Administration Act, will not be admissible in evidence against the whistleblower in criminal proceedings or in proceedings for the imposition of a penalty, except for proceedings in respect of the falsity of the information.

7.5 Public interest disclosures

There is an additional category of disclosures called ‘public interest disclosures’ that qualify for protection under the Corporations Act only. These can be made to journalists and members of Parliament, but only if the eligible whistleblower complies with the following strict requirements:

• the eligible whistleblower must have first made a qualifying disclosure under the Corporations

Act to ASIC, APRA, or a prescribed Commonwealth authority;

• at least 90 days has passed since the qualifying disclosure was made;
• the eligible whistleblower does not have reasonable grounds to believe that action is being, or has been, taken to address the matters to which the qualifying disclosure related;
• the eligible whistleblower has reasonable grounds to believe that making a public interest disclosure would be in the public interest;
• after 90 days has passed, the eligible whistleblower must give the body to which the qualifying disclosure was originally made, a written notification that:
  • includes sufficient information to identify the qualifying disclosure; and
  • states that the eligible whistleblower intends to make a public interest disclosure; and

• The extent of the information disclosed in the public interest disclosure is no greater than to inform the journalist or member of Parliament of the misconduct or improper state of affairs or circumstances, or other conduct falling within the scope of the Whistleblower Protection Scheme.

7.6 Emergency disclosures

There is an additional category of disclosures called ’emergency disclosures’ that qualify for protection under the Corporations Act only. These can be made to journalists and members of Parliament, but only if the eligible whistleblower complies with the following strict requirements:

• the eligible whistleblower must have first made a protected disclosure under the Corporations Act to ASIC, APRA or a prescribed Commonwealth authority;
• the eligible whistleblower has reasonable grounds to believe that information concerns a substantial and imminent danger to the health or safety of one or more persons or to the natural environment;
• the eligible whistleblower gave notice to the body to which the qualifying disclosure was made that states:
  • that they intend to make an emergency disclosure; and
  • includes sufficient information to identify the qualifying disclosure; and

• The extent of the information disclosed in the emergency disclosure is no greater than is necessary to inform the journalist or member of Parliament of the substantial and imminent danger.

Before making a public interest or emergency disclosure, it is important that an eligible whistleblower understands the criteria for protection under the relevant legislation.

7.7 Reporting outside EG Australia

While EG Australia encourages eligible whistleblowers to make disclosures internally, an eligible whistleblower may also make a protected disclosure:

• under the Corporations Act to the Australian Securities and Investments Commission (ASIC), the Australian Prudential Regulation Authority (APRA) or a prescribed Commonwealth authority; and
• under the Tax Administration Act to the Commissioner of Taxation.

Under the Corporations Act and Tax Act disclosures of information to legal practitioners in order to obtain legal advice or legal representation in relation to the whistleblower provisions in that legislation also are protected disclosures.

7.8 Whistleblower Protection Officer

EG Australia will appoint a Whistleblower Protection Officer (WPO) to provide certain protections and supporting persons reporting under this policy. This will include:

• maintaining regular contact with the whistleblower;
• maintaining the confidentiality of the whistleblower: and
• reviewing any complaints of retaliation or victimisation against the whistleblower and escalating matters as appropriate to relevant members of the EG Australia leadership team.

7.9 Protecting whistleblower’s identity

If you make a protected disclosure, and in doing so, reveal your identity (or information by which you can likely be identified), a person must not disclose your identity or identifying information without your consent (subject to the exceptions set out below).

If an eligible whistleblower makes a protected disclosure, it is likely that the eligible whistleblower will be asked to provide consent to the disclosure of their identity. This would be to facilitate any investigation and/or resolution of the matter. If consent is withheld, it may not be possible to adequately investigate and respond (if at all) to the disclosure.

If an eligible whistleblower does not consent to their identity being disclosed, it will still be lawful to disclose their identity to:

• ASIC, APRA, the AFP or the Commissioner of Taxation (in relation to protected disclosures under the Tax Act);
• a legal practitioner for the purposes of obtaining legal advice or legal representation about the disclosure; or
• a body prescribed by the Corporations Regulations.

It will also be lawful to disclose information (other than your identity) which you share that may lead to your identity becoming known if it is reasonably necessary in order to investigate the issues raised, in which case we will take all reasonable steps to protect your identity.

ASIC, APRA or the AFP can disclose the identity of an eligible whistleblower, or information that is likely to lead to the identification of the eligible whistleblower, to a Commonwealth, State or Territory authority to help the authority in the performance of its functions or duties.

As set out in the body of the Policy disclosures can be made anonymously. Such disclosures are still capable of being protected under the Corporations Act and Tax Act.

7.10 No immunity

The protections mentioned above do not grant immunity for any misconduct a whistleblower may have engaged in that is revealed in their disclosure.

8. Our Roles & Responsibilities

The roles within EG Australia’s Speak-Up program are summarised in the table below.

Role	Person	Responsibilities
Program owner	General Counsel (or their equivalent) “ GC ” and CPO	The GC and CPO jointly oversee the Speak Up program.
Whistleblower Protection Officer	EG Australia will appoint a senior manager as the Whistleblower Protection Officer	The Whistleblower Protection Officer is a senior member of management and will be independent of the investigation process and equipped to review or escalate the whistleblower’s concerns.
Day-to-day manager	CPO	The day-to-day manager views incoming anonymous reports, assigns these reports to case managers, and manages them as they conduct investigations. This person is the first line of escalation and works collaboratively with case managers to ensure anonymous reports are heard and acted upon.
Case manager	The GC will assign an independence case manager to investigate a whistleblower report.	Case managers are assigned anonymous reports and their role is to investigate these reports. This includes interacting and asking questions of informants, as well as using the information provided to investigate the report submitted. Their investigation can be internal or external to the organisation depending on what was documented in the report. Their goal is to gather the facts and put forth a final report to management on what happened and what action they feel needs to take place.
People & Culture team		Colleagues from People & Culture assist in the management of the external Speak Up provider and may be called upon to provide advice and guidance during any investigation. The Speak Up program leverages their expertise and acumen to ensure EG Australia are using HR best practices during investigations and we are treating all team members fairly.

9 Governance

The GC will convene a Speak Up Committee every 12 months (or on an as-needs basis) to review a sample of allegations, to ensure consistency of resolution and make recommendations as to improvement opportunities relating to the operation of the Speak Up program more broadly. The committee will comprise of the GC, CPO and other senior leaders.

The Board of EG Australia will receive an update on 12 monthly intervals on EG Australia’s Speak Up program. The Board at any time can ask about anonymous reports, investigations, as well as the state of the program.

This policy will be reviewed regularly and will be made available to EG Australia officers and employees on the intranet and website.

10 What training does EG provide?

General training on how to make reports is available for all employees in our Code of Conduct learning module. Specialist training will be made available for employees who are involved in the process of handling reports.

EG Group Australia Pty Limited and its subsidiaries (EG Australia) is committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery does not take place anywhere in our business operations or supply chain.

This policy applies to all persons working for us or on our behalf including, employees, directors, officers, contractors, external consultants, third party representatives and our business partners.

EG Australia will:

• undertake due diligence activities including, risk assessments to identify, prevent and mitigate any potential risks of modern slavery across our supply chain and operations;
• where possible, insert appropriate provisions into supplier contracts to address compliance with applicable laws including, modern slavery laws and seek supplier assurance of or, where appropriate take reasonable steps to audit, supplier compliance with this policy;
• train employees involved in procurement and sourcing to provide an understanding of the potential risks of modern slavery in our supply chain and operations and awareness of our policy and internal processes to mitigate these risks,
• ensure that there is an effective communication channel for concerns or disclosure in relation to modern slavery and processes in place to investigate and report on matters raised through this channel; and
• take appropriate steps to rectify or otherwise address any identified non-compliance.

We recognise the need to continually monitor and review this Responsible Sourcing Policy. We will review this policy annually or where required (for example, due to regulatory change).

Each member of the Executive team will continue to monitor and evaluate the implementation and effectiveness of this policy with respect to their area of responsibility.

Mike McMenamin
CEO – EG Group Australia
April 2020

EG Group Australia Pty Limited and its subsidiaries (EG Australia) recognise workplace health and safety is of utmost importance. EG Australia is committed to providing, so far as is reasonably practicable, a safe and healthy workplace for its employees, contractors and visitors.

This policy applies to all employees, contractors and visitors of EG Australia. Every person who works at EG Australia is responsible for ensuring that health and safety is a priority in all aspects of our business.

EG Australia will demonstrate its commitment to health and safety by:

• so far as is reasonably practicable, providing and maintaining a safe and healthy working environment;
• implementing a governance framework to manage Health and Safety in compliance with relevant health and safety legislation;
• providing training, instruction, appropriate equipment and facilities to enable employees to perform their work safely;
• meaningfully consulting with employees, their representatives and others on Health and Safety matters;
• providing return to work programs to facilitate safe and durable return to work for employees, where possible, for both work related and non-work related health conditions;
• continually striving to improve health and safety performance by establishing clear and measurable objectives and targets, and by auditing, reviewing and reporting performance against those objectives and targets;
• reporting, investigating and addressing incidents and hazards in accordance with statutory obligations and internal policy; and
• identifying, assessing and controlling any Health and Safety hazards and ensuring risks are eliminated or minimised, so far as is reasonably practicable.

Employees, contractors and others undertaking work at EG Australia must:

• take reasonable care for the health and safety of themselves and those under their supervision, and take reasonable care that their acts or omissions do not adversely affect the health and safety of others;
• cooperate in all matters concerning health, safety and welfare;
• comply with applicable policies and procedures, and following any lawful and reasonable direction including wearing personal protective equipment as required for the task being conducted;
• store equipment and stock in a safe manner;
• practice and demonstrate safe work procedures;
• report all hazards, unsafe work practices and incidents, and participate in training and consultation with the support of EG Australia; and
• meet their obligations under the return to work program and other guidelines to support their return to the workplace following injury or illness.

The National Head of Health, Environment, Safety and Security is responsible for monitoring and evaluating the implementation and effectiveness of this policy.

As part of EG Australia’s commitment to continuous improvement, the Health and Safety Policy will be reviewed on an annual basis.

SMOKING or VAPING Petrol is a volatile, highly flammable liquid that gives off vapours. It’s important to never smoke, light a match or stub a cigarette out, especially around pumps or fuel containers. You also shouldn’t leave cigarettes burning in your car’s ashtray.

FUEL NOZZLES Please do not lock or prop open fuel nozzles, this is both illegal and dangerous. The nozzle may dislodge and spill fuel onto the forecourt or your clothing.  It can also cause petrol to overflow from your car’s tank.

LPG LPG has a distinctive odour. If you notice or smell a leak when filling you must stop the pump using the emergency button, located next to LPG Pump.

SPEEDING Petrol stations are busy places. Reduce your speed and be aware of moving vehicles and pedestrians. Be particularly careful when reversing your car on the forecourt.

FILLING OF FORKLIFTS The filling of  LPG  bottles on the back of forklifts is not permitted at our sites. As per AS 1596, bottles must be fitted with an automatic fill limiting valve and permanently mounted. Console operators must check this prior to filling. Our sites are unable to conduct this check, so filling isn’t permitted.

FILLING PORTABLE CONTAINERS Only approved containers can be filled (has Standard AS2906 label or mark) with petrol or other fuels. They must be metal or plastic containers and can be purchased from petrol stations.

EG’s policy is that only containers up to 25 litres can be filled at petrol stations. Greater quantities can build up a static charge and cause a fire or explosion. By law, filling of larger containers such as 205 litres (44 gallon) drums is illegal. Filling of larger approved containers is permitted with diesel only, and only once the verification of the container has been approved by the Store Manager.

When filling containers they must be placed firmly on the ground, in the open air, not in the boot of a car or ute, as this can increase the risk of fire and explosion.

PILOT LIGHTS Many boats, motorhomes or caravans have gas-powered fridges or cooking devices. Whenever possible, turn the pilot light off before arriving at the service station to avoid any likely ignition source.

FUEL HANDLING Always take great care when handling fuel or LPG from pumps at the petrol station. Vehicles must be turned off prior to filling vehicles. Petrol can irritate your skin and LPG can cause cold burns on contact. Never let fuel come into contact with your eyes. Avoid inhaling fuel vapours whenever you can. 

If you spill fuel on your clothes, soak the area affected with water before cleaning it off to reduce the chance of creating a static electrical spark.

It’s good practice to touch a metal part of your car with your hands before removing the petrol cap to discharge any electricity.

Please remember to report all fuel spills to the console operator and don’t hose the spill down the drain with water. This is illegal and against our policy and procedures.

DRIVEWAY SAFETY AND CHILDREN Due to the dangerous nature of the products, handle fuel, diesel and LPG with care. For this reason young people are not permitted to dispense fuel. Only persons 16 years and older are permitted to fill vehicles. Children should not stand next to parents or carers when they are filling the vehicle, this could cause an injury.

JUMP STARTING A VEHICLE Batteries emit hydrogen gas. If a spark was to occur, the battery could explode. Vehicles must not be jump started within 8M of any pumps, fuel points, vents or drains.  

MOBILE PHONES Don’t use your mobile phone while filling. We ask that you leave your mobile phone in your vehicle while you’re refueling.

Mobile phones must not be used while you’re standing or walking on the forecourt. This will allow you to observe the forecourt area carefully. 

When using your phone to Pay at Pump from the EG App, make sure you are compleing the details while you are in the safety of your stationery vehicle.

MOTORBIKES Many riders prefer to keep their bike upright rather than propped on the side stand while filling the tank so that they can squeeze in that little bit extra. It’s safer to allow some space in the tank so that if the temperature increases the fuel can expand without overflowing.

Get off your motorbike when refueling. Keeping your motorbike steady is crucial when refueling. This is because the risk of splashing fuel on yourself and your motorbike is higher if the bike moves.

Because the fuel tank is so close to the engine the risk of ignition is higher. Ignition could happen if you’re distracted and inadvertently pull the nozzle out of the tank before the trigger is released.

1. Introduction

This Modern Slavery Statement (Statement) has been prepared in accordance with the
requirements of the Modern Slavery Act 2018 (Cth) (the Act). This Statement covers EG Group
Australia Pty Ltd ACN 629 792 810 and its related bodies corporate including, EG Fuelco
(Australia) Limited ACN 627 348 645 (together, EG Australia, we or us).
This Statement sets out:
• our structure, operations and supply chains;
• our policies which address the risks of modern slavery;
• the actions taken by us during the financial year ending 31 December 2023 to identify, address and minimise modern slavery risks in our operations and supply chains (including due diligence and remediation processes); and
• how we assess the effectiveness of these actions.

This Statement was approved by our Board of Directors on 29 April 2024 and signed by our Chief Executive Officer in accordance with the Act.

2. EG Australia structure, business, operations and supply chains

Our structure

The EG Australia companies are subsidiaries of EG Group Limited (EG Group), which is
headquartered in Blackburn, United Kingdom. EG Group is a leading global independent
convenience retailer with a diversified portfolio of over 6,000 sites across ten countries in North
America, Europe and Australia, supported by over 47,000 employees globally.

EG Australia owns and operates 525 fuel and convenience sites, and currently employs more than 4,200 people nationwide.

Our operations

Our operations have remained materially the same as the previous financial year. We employ
most of our team members directly and on permanent contracts. This reduces the risk of modern slavery within EG Australia’s operations.

In our previous Statements we have recognised that there is a risk of modern slavery in areas
of our business that use contracted or third party labour providers. Although we do not have direct control over the employment terms of these contracted parties, we strive to ensure that all of our contracted parties comply with current modern slavery laws. The standard terms in our vendor agreements require third party vendors to complete a modern slavery due diligence questionnaire, provide warranties that they are not aware of any modern slavery practices within their supply chain or operations, and promptly notify us if they become aware of any such modern slavery practices.

We have not been notified, or otherwise become aware, of any modern slavery practices in our
supply chain, or the supply chains of any contracted vendors from the date of filing our first Statement.

Our Supply Chains

Our supply chain consists of trade suppliers and non-trade suppliers with the majority of our goods/services supplied by Australian businesses.

We have communicated our expectations to our trade suppliers, non-trade suppliers, partners
and stakeholders to adhere to ethical business conduct consistent with our own. As stated in
our previous Statement, we are committed to working with these parties to ensure their goods, materials and related supply chains are:

• fully compliant with all applicable labour laws and regulations, including the Act;
• transparent, accountable and auditable;
• free from ethical ambiguities;
• free from forced, compulsory or child labour; and
• free from discrimination in the workplace.

We communicate our expectations through a variety of channels, including supply or service agreements, tender and supplier due diligence documents and our Speak-Up and Code of Conduct available on our website.

Individuals with evidence of non-compliance within our supply chains are encouraged to follow the reporting procedure outlined in our Speak-Up Policy.

We continuously monitor our whistleblower platform for any reports of concerns or disclosure in relation to modern slavery. As at the date of this Statement, no such reports have been received in relation to the year ending 31 December 2023.

We will continue to ensure awareness and encourage our staff to use this channel of communication to report any unethical sourcing or modern slavery practices

Our Policies

Responsible Sourcing Policy

Our Responsible Sourcing Policy reflects our commitment to acting ethically and with integrity in all our business dealings and relationships and to take steps to ensure modern slavery does not take place in our business operations or supply chain. The policy outlines the steps EG Australia must take including undertaking due diligence to mitigate risks of modern slavery, inserting appropriate modern slavery clauses into supplier contracts and training employees involved in procurement and sourcing to understand the risks of modern slavery. Each member of our executive team monitors and evaluates the implementation and effectiveness of this policy with respect to their area of responsibility.

Code of Conduct

Under our Code of Conduct, we expect all team members to maintain high standards, and to speak up and provide feedback when they see activity or behaviour that they feel is wrong or does not match our ways of working.

Speak-Up Policy

Our Speak-Up Policy sets out the procedure for our staff to speak up confidentially to raise genuine concerns about misconduct in our business or operations without fear of reprisal, and includes an external reporting hotline for our staff and suppliers to use.

3. Identifying Risks of Modern Slavery Practices

We recognise that modern slavery practices are most prevalent where:

• service providers use unskilled or seasonal labour, or foreign or temporary workers;
• products are sourced from high-risk countries;
• there are poor governance structures within the organisation;
• there are poorly managed procurement or auditing processes; and
• there is a lack of awareness and training within the organisation.

We are constantly reviewing risks to prioritise our efforts where there is greatest risk to people in our operations and supply chain. Our risk assessment following consultation with internal
stakeholders has provided a better understanding of the potential risks in EG Australia’s business and the actions which have been implemented to address these risks. For example:

• some of the suppliers of goods for resale or use in our business in our extended supply chain fall within the potential risk area due to the nature of the goods or services being sourced (e.g. coffee or cleaning services) or the geographical locations from which certain goods or raw materials are sourced to manufacture such goods; and
• the prevalence of vulnerable workers or sub-contractors within the relevant sector (for example, in the construction and maintenance sectors).

We have assessed these suppliers to seek to identify any instances of modern slavery and are
not aware of any such instances in our supply chain.

We intend to continue to assess and monitor suppliers that fall within the potential risk areas in our extended supply chain to ensure that there are no instances of modern slavery.

4. Actions Taken

We have taken the following actions, and continue to take these actions, to assess and address the risks of modern slavery practices in our operations and supply chain:

A. Updated Standard Terms: We have updated the standard terms in our vendor agreements to
include a more detailed and comprehensive modern slavery clause which goes beyond an
obligation to simply comply with applicable laws. In particular, our vendors are required to
complete our modern slavery questionnaire and notify us if they become aware of or suspect
any modern slavery practices within its supply chain or business operations. We also have the right to audit vendors’ operations, working conditions and procedures. We are also working to ensure this clause is included in all of our existing agreements and any third party contracts we enter into. This will give us greater visibility and control over modern slavery risks within our supply chain.

B. Standard ESG Questionnaire: we have completed an ESG Questionnaire coordinated by EG Group which incorporates modern slavery due diligence questions. We completed this questionnaire for 2023 and provided supporting evidence and calculations to EG Group for all data included in our responses. The aim of this questionnaire is to monitor and ensure continued improvement in environmental, social and governance matters across the EG Group, including in relation to modern slavery.

C. Vendor Due Diligence: We conducted vendor due diligence/integrity checks to identify any
risks in the request for tender and procurement process and are working to ensure all vendors
are subject to appropriate modern slavery due diligence during our vendor on-boarding or
renewal process. We require our large suppliers to provide their own Modern Slavery
Statements and policies for our review;

D. Compliance with our Responsible Sourcing Policy, Speak Up Policy and Code of Conduct: Our Speak Up Policy and Code of Conduct are published on our website and our Responsible
Sourcing Policy is made available to key personnel who are involved in procurement and
sourcing. These policies reflect our commitment to act ethically and with integrity in all our business relationships. Most of our key suppliers have agreed to contractual terms which require them to comply with modern slavery laws and relevant obligations, including a provision allowing us to audit our business partners’ operations, facilities and working
conditions, procedures and systems to ensure compliance.

E. Employee Training: Our key employees are required to complete detailed modern slavery
online training. All of these employees have successfully completed training. We will continue to require staff to complete modern slavery training and monitor them in this regard.

F. Modern Slavery Questionnaire: Most of our business partners and suppliers have
completed self-assessment modern slavery due diligence questionnaire and/or warranted that they are not aware of any risks of modern slavery practices within their own supply chain or operations. Typically, we require this questionnaire to be completed either on the
initial on-boarding of a supplier or on a renewal of their arrangements.

5. Commitment to Continuous Improvement

We consistently monitor and assess modern slavery risks in our business and by way of continuous improvement will strive towards:

● extending our modern slavery training to key employees and mandating completion;
● continuing to assess the potential modern slavery risks in our operations and supply chains with emphasis on high risk geographical locations and sectors;
● continuing to work with EG Group to complete our annual ESG Questionnaire which
incorporates modern slavery due diligence questions;
● continuing to require new vendors to complete our modern slavery questionnaire and work towards having all existing vendors complete the questionnaire;
● ensuring all new vendors are subject to our new standard modern slavery contractual
terms;
● continuing to transition existing suppliers upon renewal or amendment of their contracts
to updated terms which incorporate our new standard modern slavery contractual terms;
● continuing to collaborate with suppliers to encourage sharing of information around
modern slavery risks and ongoing communication and continuous improvement to achieve compliance if any breaches of this Statement are identified; and
● measuring effectiveness through performance monitoring.

6. Assessing Effectiveness

We regularly review the effectiveness of our management of modern slavery risk by:

● investigating and analysing complaints, reports and grievances made through our
whistleblowing mechanisms;
● reporting on complaints, potential trends, and risk areas to the Speak-Up Committee and the Board;
● reporting on EG Australia’s performance on Environmental, Social, and Governance (ESG) matters in connection with EG Group’s ESG reporting and governance
frameworks;
● reviewing and conducting training to maintain awareness within our organisation; and
● publicly communicating this Statement so our employees and suppliers have a clear understanding of our policies, expectations and future commitments to reduce the risks of modern slavery.

7. Process of consultation

This Statement reflects the position of EG Australia. All entities of EG Australia operate
under a common set of policies and programs relating to modern slavery.

In implementing EG Australia’s modern slavery compliance program, we have continued to
consult with key stakeholders across the business. In addition, prior to approval by the
Board, this Statement was reviewed by the executives of EG Australia who are responsible
for the overall management of the EG Australia business.

8. Document control

Effective from: 30 June 2024
Date approved: 29 April 2024
Approved by: EG Australia Board