Whistleblower Policy

1.Purpose and Commitment

Taitung Australia Pty Ltd (ACN 101 496 646, “Taitung,” “we,” “us,” or “our”) is committed to conducting business honestly, ethically and in accordance with the law. People connected with our business are often the first to know when something is seriously wrong — and speaking up takes courage.

This policy explains who can report wrongdoing, what can be reported, how to make a report (including anonymously), how we will handle it, and the protections available under Australian law. We encourage anyone with reasonable grounds to suspect misconduct to come forward, and we will support and protect them when they do.

2.Who Can Make a Report

Under the whistleblower provisions of the Corporations Act 2001 (Cth), the following people (called “eligible whistleblowers”) can make a protected disclosure about Taitung:

• Current and former employees (permanent, part-time or casual)
• Current and former directors and officers
• Current and former contractors and consultants, and their employees
• Current and former suppliers of goods or services (paid or unpaid), and their employees
• Associates of Taitung
• Relatives, dependants and spouses of any of the people above

You do not have to identify yourself to be protected — anonymous reports are covered too.

3.What Can Be Reported

You can report information you have reasonable grounds to suspect concerns misconduct, or an improper state of affairs or circumstances, in relation to Taitung. This includes suspected:

• Fraud, theft, money laundering or misappropriation of funds
• Bribery, corruption or offering/accepting secret commissions
• Dishonest or unethical behaviour in business dealings
• Breaches of the Corporations Act 2001 (Cth) or other financial services laws
• Any offence against Commonwealth law punishable by 12 months' imprisonment or more
• Conduct that represents a danger to the public or the financial system
• Serious breaches of workplace health and safety obligations
• Modern slavery or exploitation of workers (see our Modern Slavery Policy)
• Concealment or destruction of records relating to any of the above
• Victimisation of a person for making, or planning to make, a report under this policy

The conduct does not necessarily need to break the law to be reportable — serious misconduct or an improper state of affairs is enough. You need reasonable grounds for your suspicion, but you do not need to be certain or have proof.

4.What This Policy Does Not Cover

Personal work-related grievances are generally not covered by whistleblower protections. These are grievances about your own employment that affect only you, such as:

• An interpersonal conflict with another employee
• A decision about your own engagement, transfer, promotion, pay or conditions
• A decision about discipline, suspension or termination that affects only you

These matters should be raised with your manager or through our normal HR channels. However, a grievance is protected where it also concerns broader misconduct (a “mixed report”), or where it relates to victimisation for whistleblowing.

5.How to Make a Report

You can make a report to any of the following:

Under the law, you can also make a protected disclosure directly to:

• The Australian Securities and Investments Commission (ASIC) — asic.gov.au
• The Australian Prudential Regulation Authority (APRA) — apra.gov.au
• Taitung's auditor or actuary (if applicable)
• A legal practitioner, for the purpose of obtaining advice about the whistleblower provisions (protected even if the advice is that your matter is not covered)
• For tax-related concerns: the Australian Taxation Office (ATO) or your registered tax agent — ato.gov.au

Helpful details to include (if you can): what happened, when and where, who was involved, whether it is ongoing, any evidence or documents, and whether you fear retaliation. If someone is in immediate danger, call 000 first.

6.Anonymity and Confidentiality

• You may report anonymously, and remain anonymous during and after any investigation. You may also use a pseudonym
• If you report anonymously, consider providing a way for us to contact you (for example, an anonymous email address) so we can ask follow-up questions and keep you informed
• If you identify yourself, your identity — and information likely to reveal it — will be kept confidential. It is a criminal offence for anyone to disclose a whistleblower's identity without consent, except to ASIC, APRA, the Australian Federal Police, or a lawyer for advice about the whistleblower provisions
• During an investigation we may need to disclose information that does not identify you; we will take reasonable steps to reduce the risk that you could be identified from it
• Reports are stored securely and access is restricted to those directly involved in handling them

7.Legal Protections for Whistleblowers

If you make a report covered by this policy, then under the Corporations Act 2001 (Cth):

• You are not subject to civil, criminal or administrative liability for making the report
• No contractual or other remedy can be enforced against you on the basis of the report
• The information you provide is generally not admissible in evidence against you in criminal proceedings or proceedings for a penalty (except for proceedings about the falsity of the information)
• Your identity is protected as described in section 6

These protections apply automatically under the law — they do not depend on Taitung's agreement, and they continue even after any investigation ends. Protection is not lost simply because a report turns out, after investigation, to be unfounded — provided it was made with reasonable grounds.

8.Protection from Victimisation

It is unlawful — and a criminal offence — to cause or threaten detriment to a person because they made, may have made, or could make a whistleblower report. Detriment includes:

• Dismissal, demotion or altering a person's position or duties to their disadvantage
• Harassment, intimidation or discrimination
• Harm or injury, including psychological harm
• Damage to a person's property, reputation, business or financial position

Taitung will treat any victimisation of a whistleblower as serious misconduct, which may result in disciplinary action up to and including dismissal or termination of engagement. A person who suffers detriment may also seek compensation and other remedies through the courts.

9.Public Interest and Emergency Disclosures

In limited circumstances, the law also protects disclosures to a journalist or a member of Commonwealth, state or territory parliament:

• Public interest disclosure — available only if you have already reported to ASIC or APRA, at least 90 days have passed, you reasonably believe further disclosure is in the public interest, and you have first given the regulator written notice of your intention
• Emergency disclosure — available only if you have already reported to ASIC or APRA, you have reasonable grounds to believe there is a substantial and imminent danger to health, safety or the environment, you have given the regulator written notice, and the disclosure is limited to what is necessary to inform of the danger

Strict conditions apply to these disclosures, and protection can be lost if they are not met. We strongly recommend obtaining independent legal advice before making a public interest or emergency disclosure.

10.How We Investigate

• We will acknowledge your report as soon as practicable (where we have a way to contact you)
• We will assess each report to decide whether it falls under this policy and whether a formal investigation is required
• Investigations are conducted promptly, fairly and objectively, by a person with no personal interest in the matter; where appropriate we may engage external investigators or advisers
• Where possible, we will keep you informed of progress and outcomes, subject to confidentiality and privacy considerations — the frequency of updates may vary with the nature of the report
• Findings are reported to the appropriate level of management or the directors, and we take corrective action where wrongdoing is found
• We report suspected criminal conduct to the appropriate authorities

11.Fair Treatment of People Mentioned

A report may name people who are later found to have done nothing wrong. Taitung will ensure the fair treatment of employees and others who are mentioned in a report:

• Reports are handled confidentially — being named in a report is not a finding of wrongdoing
• A person who is the subject of a report will be informed of the substance of the allegations at an appropriate time in the investigation, and will have an opportunity to respond before findings are made against them
• They may seek support through their manager or our normal support channels

12.False Reports

Deliberately making a report you know to be false is a serious matter. It is not protected by the whistleblower provisions, may result in disciplinary action, and can expose the person making it to legal liability. This does not affect honest reports that simply turn out to be mistaken — those remain protected where there were reasonable grounds for the suspicion.

13.Related Laws, Availability and Review

This policy is informed by and operates alongside:

• Corporations Act 2001 (Cth), Part 9.4AAA (whistleblower protections)
• Taxation Administration Act 1953 (Cth), Part IVD (tax whistleblower protections)
• ASIC Regulatory Guide 271 — whistleblower policies
• Our Modern Slavery Policy, Privacy Policy and Terms & Conditions

This policy is made available to all Taitung officers and employees, including via this page. We review it at least annually and update it as our business or the law changes; the “Last updated” date at the top reflects the most recent revision.

14.Contact Us

To make a report, or for questions about this policy:

Regulators you can also contact directly: ASIC (asic.gov.au), APRA (apra.gov.au), and for tax matters the ATO (ato.gov.au).