SUPPLIER CODE OF CONDUCT

We are committed to transparent, safe and ethical procurement practices. Our aim is to partner with like-minded suppliers to help us deliver leading solutions that enhance our clients’ operations.

To achieve this, we have developed a Supplier Code of Conduct, which clearly sets out our minimum expectations of suppliers, their subsidiaries and subcontractors (suppliers).

The Supplier Code of Conduct aligns with our Corporate Governance Polices, company values and internal expected behaviours. Central to these polices, values and behaviours is:

• Safety for employees, contractors, clients, suppliers and the public
• Compliant and ethical business practices
• Diversity and human rights
• Protecting the environment and communities in which we operate
• Respect, transparency and support to speak-up.

We may choose not to work with, or cease to work with, suppliers who do not meet these minimum expectations.

CODE OF CONDUCT

Our Code of Conduct (the Code) provides an important framework for our decisions and actions at work and establishes the minimum standard of conduct required. The Code also highlights that all employees have a duty to act in the best interest of IMDEX.

Our Code is reviewed regularly by IMDEX Legal and is endorsed by our Board and Executive Leadership Team.

ANTI-BRIBERY AND CORRUPTION

Our Anti-Bribery and Corruption Policy builds on our Company Values and Code of Conduct. The Policy ensures we are committed to:

• Zero-tolerance for bribery and other forms of corruption;
• Honest and ethical business practices; and
• Compliance with the laws of the countries where we operate.

The Policy also sets out requirements for business conduct and provides information on how to recognise and respond to bribery and corruption.

Compliance with this Policy:

• Supports legitimate engagements;
• Promotes economic development and good governance; and
• Protects against significant legal, financial, safety and reputational risks.

To ensure ongoing compliance, all employees are required to complete annual Anti-Bribery and Anti-Corruption training.

CONFLICTS OF INTEREST

All employees and contractors are required to complete an annual conflict of interest declaration and manage this declaration if circumstances change. To do this most efficiently, we utilise ComplianceDesktop™ – our online compliance management system.

SPEAK-UP POLICY

Our Speak-Up Policy is designed to maintain the highest standards of corporate governance and ethical conduct across all our operations. It also ensures our Company is a safe, respectful and inclusive place to work.

All employees are encouraged to ask questions, query and report actual or suspected violations of our Code of Conduct or IMDEX Polices without fear of retribution.

Several methods can be used to make confidential and anonymous reports including IntegraCall® – a secure multilingual reporting platform that can be accessed via mobile or a desktop computer.

The user-friendly platform has an integrated case management system to ensure reports are stored, monitored and managed appropriately – including a function to prioritise and escalate reports if needed. IntegraCall® also allows reporters to receive updates via instant messaging and check on the progress of their report at any time.

ETHICS CERTIFICATION

To safeguard the ongoing ethical and compliant operation of our global business, all senior employees are required to complete Ethics & Compliance Certification every six months.

This certification is completed via ComplianceDesktop™ and confirms these employees:

• Have read and understand IMDEX’s Speak Up Policy, Code of Conduct and the Anti-Bribery & Anti-Corruption Policy;
• Have been, to the best of their knowledge, compliant with the Code, the two Policies and all applicable laws and regulations; and
• Their teams, to the best of their knowledge, have been compliant with the Code, the two Policies and all applicable laws and regulations.

Regular Ethics & Compliance Certification will ensure all relevant risks are being adequately reported and addressed. Importantly, the certification questionnaire also provides another confidential means of communicating potential breaches or concerns.