Business Partner Code of Conduct

TABLE OF CONTENTS I. INTRODUCTION ........................................................................................................................................... 3 II. BUSINESS ETHICS ....................................................................................................................................... 3 A. Misconduct ...................................................................................................................................... 3 B. Whistleblowing ............................................................................................................................. 3 C. Ethics Advice and Violation Reporting (Grievance Mechanism) .................. 4 III. LEGAL & REGULATORY COMPLIANCE ......................................................................................... 4 A. Bribery and Corruption ........................................................................................................... 4 B. Commercial Bribery .................................................................................................................. 4 C. Gifts, Entertainment and Sponsorships ......................................................................... 5 D. Trade Controls ................................................................................................................................ 5 E. Competition and anti-competitive behaviour ..................................................................................... 5 IV. HUMAN RIGHTS ...........................................................................................................................................6 A. Forced Labour ...................................................................................................................................6 B. Operational Practices ................................................................................................................ 7 V. DIVERSITY, EQUITY & INCLUSION ................................................................................................... 8 VI. HEALTH & SAFETY ..................................................................................................................................... 8 VII. CONFIDENTIALITY AND INTELLECTUAL PROPERTY .......................................................... 8 VIII. ENVIRONMENT ............................................................................................................................................9 I. INTRODUCTION The purpose of the Business Partner Code of Conduct is to set forth Complete Global Solutions Pty ltd (CGS) general standards concerning ethical and legal conduct. It complements our Employee Code of Conduct. Together, these Codes govern the actions and working relationships between CGSs employees, current and potential customers, suppliers, distributors, agents, competitors, government and self-regulatory agencies, the media and anyone else with whom CGS has contact. Through appropriate contractual arrangements, consultants, agents, distributors, service providers and suppliers of CGS are expected to comply with this Business Partner Code of Conduct. In addition, these third parties shall respect that CGS employees are bound by the Employee Code of Conduct and shall not encourage our employees to breach these Codes in any way. II. BUSINESS ETHICS Beyond legal compliance, all CGS business partners are expected to observe high standards of business and personal ethics in the course of their job duties related to doing business with CGS. This requires the practice of honesty, integrity, and sound judgement in dealing with CGS employees, the public, the business community, customers, suppliers, competitors, government, and regulatory authorities. A. Misconduct If you become aware of or suspect any misconduct related to CGS’s business, you must notify CGS promptly. The most effective way to report misconduct is to utilize the grievance mechanism described below. B. Whistleblowing All business partners, as well as employees and any other individual, can submit a whistleblowing grievance, without fear of retaliation, via the mechanism described below. CGS expects its business partners to offer their own employees and business partners reasonable and sufficient reporting channels, including protection from fear of retaliation. C. Ethics Advice and Violation Reporting (Grievance Mechanism) There is no easy answer to many ethical issues faced during daily business activities. In some cases, the right course of action will be evident, but in other more complex situations, it may be difficult to determine. Anyone can report violations or send ethics-related questions to management@completeglobal.com.au. All reports are taken seriously and investigated, and if substantiated, resolved through corrective action and/or discipline. You can rest assured that any good-faith reports of violations will result in zero retaliation. III. LEGAL & REGULATORY COMPLIANCE Complete Global Solutions requires our business partners to comply with all relevant local and national legislation and regulations. We expect and require everyone working with CGS to respect all anti-corruption, anti-trust, and fair competition rules. Please utilize our grievance mechanism to report any suspected violations of relevant legislation and/or regulations as it pertains to CGS’s business. A. Bribery and Corruption CGS prohibits its business partners from making or causing to be made the offer, promise, gift, or authorization of payment of other benefit, favour or hospitality, whether directly or indirectly, to any government official to influence or with the intention to influence an action, inaction, or decision to obtain or retain business advantage for CGS. A government official includes any public official or officer or employee of government anywhere in the world, at any level. Regardless of local practice, CGS does not allow under any circumstances the making of “facilitation payments,” i.e., payment to a government official for routine governmental action (such as processing papers, issuing permits, etc.), to expedite performance of duties. B. Commercial Bribery CGS does not tolerate the offering, making, requesting, or receiving of payments in kind (gifts, favours, charitable donations, etc.) to influence individuals to award business opportunities to Green or to make a business decision in CGS’s favour. C. Gifts, Entertainment and Sponsorships Gifts and entertainment given and received as an award or encouragement for preferential treatment are not allowed. In certain circumstances, the giving and receiving of modest gifts and entertainment is acceptable. A business meal for example can provide a relaxed way of exchanging information. Nonetheless, depending on their size, frequency, and the circumstances in which they are given, they may constitute bribes, political payments, or undue influence. The key test we must apply is whether gifts or entertainment could be intended or even reasonably be interpreted as a reward or encouragement for a favour or preferential treatment. If the answer is yes, you must not make such an offer to us. D. Trade Controls CGS’s business partners must comply with laws that govern international trade, including export controls, import requirements and economic sanctions (together “trade controls”). Trade controls typically cover: • Imports from or originating in a sanctioned country. • Imports with a sanctioned entity or individual • Business dealings with a sanctioned country, entity or individual • The transfer of restricted product, software, technical data, or technology without a license by email, download, or disclosure from people in or from a sanctioned country • The prohibition on engaging in certain sanction activities, refer, Australian Sanctions Office (ASO) E. Competition and Anti-competitive behaviour CGS is committed to the principles of free and fair competition. It is our policy to compete vigorously and effectively while always complying with applicable anti-trust laws. Accordingly, our business partners that are also our competitors must: • Keep contact with us to a minimum. • Not disclose to seek from or exchange with us any commercially sensitive information such as price, contract negotiations, capacity, commercial strategies or plans, bidding intentions, customers, or market share • Not discuss commercially sensitive information in joint ventures with us unless it relates to a specific venture. • When selling services to or purchasing services from us, only exchange information that is legitimately required to complete the transaction. IV. HUMAN RIGHTS At Complete Global Solutions, we set Human Rights requirements in two categories: Forced Labour and Operational Practices. A. Forced Labour Complete Global Solutions is committed to eradicating, and prohibits the use of, forced labour, human trafficking, modern slavery, and/or any other type of forced or compulsory labour in our global value chain. CGS requires that our business partners have the same or similar commitment. We also require our business partners to collaborate with us in these efforts. If you become aware of or suspect any use of forced labour in our global value chain, or conditions that create a risk of forced labour, you must notify CGS promptly at management@completeglobal.com.au Australian Modern Slavery Act (2018) AU-MSA Australia B. Operational Practices Complete Global Solutions requires that its business partners respect the human rights and fair labour practices listed below: • Provide all business partners, employees, jobseekers, and potential business partners with equal opportunity without discrimination and free of discriminatory criteria, including, but not limited to: • Ethnicity, race • Religion • Sex, sexual orientation, pregnancy, childbirth, medical conditions, gender identity, and/or gender expression • Age • Mental and/or physical disability • Ancestry, culture, national origin, citizenship status • Socio-economic, marital, and/or any other related status • Any other protected status not listed above. • Respect employee rights to associate freely and collectively bargain. • Ensure that employees can perform their work in an environment free from physical, psychological, and/or verbal harassment or intimidation, or any other form of abusive conduct. • Pay all workers at least the minimum wage and benefits. V. DIVERSITY, EQUITY & INCLUSION Complete Global Solutions believes in the power of diversity, that each one of us brings something unique to the table. As such we strive to achieve nothing short of equity for everyone at CGS and those we work with. We expect our business partners to comply with all applicable diversity, equity, and inclusion (DEI) and non-discrimination laws and to consider how their business decisions affect diversity and inclusivity in their workplace, their supply chain, and the communities where they conduct business. We ask our partners to not only not practice or engage in any form of discrimination, but to be anti-discrimination. Be an ambassador, question your own unconscious biases and speak up when you see something wrong, unfair, or unethical. VI. HEALTH & SAFETY Complete Global Solutions expects our business partners to share our commitment to conducting all business in compliance with all applicable safety, health and workplace laws and regulations in a manner that has the highest regard for the safety and health of employees. We expect you to provide your employees a safe workplace and the necessary tools and training to ensure they can do their jobs and conduct business in a safe manner. VII. CONFIDENTIALITY AND INTELLECTUAL PROPERTY CGS's business partners shall protect information and respect Intellectual Property (“IP”), including, but not limited to: • Respecting the legitimate proprietary rights and IP rights of CGS and others. • Taking proper care to protect confidential, personal, proprietary, and sensitive information • Any such information shall be collected and shared only when necessary and/or legally mandated. • Protecting the information exchanged from destruction, disclosure, modification, unauthorized access, and usage. • Maintaining accurate records, including all transactions and expenses. VIII. ENVIRONMENT • The transport sector has the highest reliance on fossil fuels of any sector and is one of the largest sources of global greenhouse gas emissions. Global supply chains have massive impacts on air, land, water, and biodiversity. • Complete Global Solutions requires our business partners to support our commitment to measure, minimize, and improve the environmental impacts of our business locally and globally, with a particular focus on immediate reductions of greenhouse gas (GHG) emissions. We encourage our business partners to make the same or similar commitment. • We require our business partners to adhere to all applicable environmental laws, regulations, ordinances, rules, permits, licenses, and approvals in every country in which they operate. This includes environmental reporting and disclosure requirements. • It is critical that our business partners operate in a manner that conserves natural resources, promotes resilience, and protects the environment. • We ask our business partners to invest in business practices and systems that enable identifying and managing environmental risks, measuring, and monitoring environmental performance, and driving continuous improvement of corporate environmental impacts.