One Investment Group Employee Handbook PDF 2024

Summary

Employee Handbook for One Investment Group, effective 22 April 2024. This document details company policies, procedures, and benefits for employees.

Full Transcript

Employee Handbook 22 April 2024 CONFIDENTIAL Table of Contents Welcome to One Investment Group................................................................................................... 4 Guide to the OIG Employee Handbook.....................................................

Employee Handbook 22 April 2024 CONFIDENTIAL Table of Contents Welcome to One Investment Group................................................................................................... 4 Guide to the OIG Employee Handbook............................................................................................... 5 Probation............................................................................................................................................ 7 Hours of Work..................................................................................................................................... 8 Flexible Working Arrangements (including hybrid working arrangements)....................................... 9 Remuneration & Benefits................................................................................................................. 14 Remuneration Framework................................................................................................................ 14 Referral Bonus................................................................................................................................... 14 Staff Expenses Claims........................................................................................................................ 15 Electronic Fund Transfer................................................................................................................... 15 Superannuation................................................................................................................................ 16 Leave................................................................................................................................................. 17 Annual Leave..................................................................................................................................... 17 Personal/Carer’s Leave..................................................................................................................... 17 Long Service Leave............................................................................................................................ 18 Compassionate Leave....................................................................................................................... 18 Community Service Leave................................................................................................................. 18 Family and domestic violence leave................................................................................................. 19 Unpaid Parental Leave...................................................................................................................... 19 Federal Government’s Paid Parental Leave Scheme........................................................................ 20 Public Holidays.................................................................................................................................. 20 Leave Form........................................................................................................................................ 20 Personal Progress.............................................................................................................................. 21 Performance Management............................................................................................................... 21 Training, Education Assistance & Professional Development.......................................................... 22 Workplace Health & Safety............................................................................................................... 23 Complaints Management.................................................................................................................. 23 Drugs and Alcohol............................................................................................................................. 23 Introduction...................................................................................................................................... 23 Prohibited Conduct........................................................................................................................... 24 Exceptions......................................................................................................................................... 24 22 April 2024 CONFIDENTIAL 2 Disciplinary Action............................................................................................................................ 25 Employee Conduct & Related Matters............................................................................................. 26 Values Statement and Code of Conduct........................................................................................... 26 Diversity and Inclusion Policy............................................................................................................ 32 Anti- Discrimination.......................................................................................................................... 34 Harassment & Bullying...................................................................................................................... 36 Termination of Employment............................................................................................................. 41 Performance Counselling.................................................................................................................. 42 General HR Matters.......................................................................................................................... 43 IT Systems Usage............................................................................................................................... 43 Social Media Guidelines ……………………………………………………………………………………………………………. 45 Travel Policy...................................................................................................................................... 48 22 April 2024 CONFIDENTIAL 3 Welcome to One Investment Group First let me join with all your new colleagues in welcoming you to One Investment Group. Whether you work in Unity Funds Services, One Registry Services, One Corporate Trust, Trustee Operations or Custody, it should really go without saying that the core of our continued success is our people and without you, our ability to serve our clients and achieve our future ambitions as an organisation would not be possible. We hope you will have a rewarding and successful career here at One Investment Group and welcome you to the OIG family. Frank Tearle CEO One Investment Group 22 April 2024 CONFIDENTIAL 4 Guide to the OIG Employee Handbook Our group policies have been established to assist you to act in the manner required while working at One Investment Group (OIG). The information in this Handbook will enable you to become familiar with how we operate and what we stand for. Please take time to read the Handbook carefully as it should answer the questions you may have about our policies. The policies in this Handbook apply to all activities, and people involved in those activities, that take place: on work premises; elsewhere where activities are undertaken in the course of employment; and at work-related activities, such as social functions. The policies contained in this Handbook do not form part of your terms of employment, and may be varied, replaced or withdrawn by OIG in its discretion from time to time. They may be used by OIG as part of a work direction. If you need further information about any of these policies or you find a situation that is not covered in these policies, please ask your manager for assistance and guidance. Effective policies for OIG mean: Increased knowledge and better understanding of business operations, human resources issues and other necessary systems for employees. Increased morale as employees understand business operations and what is expected of them. Increased productivity, which leads to increased business value. What Do Our Corporate Policies Cover? Where do I find them? We have a range of policies covering most facets of our business to ensure we conduct our daily business to the highest standards of integrity and professionalism. You can find these policies on the OIG Intranet. These are read-only documents and cannot be copied and edited. You must not provide them to any person without your manager’s consent. Who Do These Policies Apply To? These policies apply to all employees engaged in the separate business units comprising the One Investment Group (OIG) including employees that provide services to: those companies that hold an Australian financial services licence (AFS Licence) to provide financial services to retail and/or wholesale clients and their OIG Corporate Authorised Representatives (each an OIG Licensee) including the Trustee Services business unit (OTS) and Corporate Trust business unit (OCT); and; those companies that provide registry services (ORS); and those companies that provide fund administration services (UFS). It is the responsibility of each Manager to ensure their employees are familiar with and comply with these corporate policies. Failure to comply with these policies may lead to disciplinary action up to and including dismissal. Ignorance of the requirements of these policies will not be accepted as a reason for non-compliance. 22 April 2024 CONFIDENTIAL 5 How Should These Policies Be Interpreted? While these policies have been approved, it is recognised there may be occasions where compliance with certain aspects of the policies may be impractical or not in the best interests of the business. Under such circumstances, deviation may be allowable but only in relation to certain aspects of the policies since some policies must be strictly complied with, and only with agreement from your Manager. It should also be noted that such allowances shall not be construed as a precedent. How Do Policies Get Updated? Our policies are reviewed on an ongoing basis. OIG reserves the right to vary policies at its discretion from time to time to suit business circumstances. If there are any changes, we will make every effort to inform you. We also welcome your feedback – your suggestions on improvements or changes to this Handbook are valuable to us. What If an Employee has a query relating to a Policy? If you have a question relating to any of the policies or are in any doubt about how to conduct business, you are encouraged to discuss this with your Manager. 22 April 2024 CONFIDENTIAL 6 Probation Purpose OIG’s Employment Agreements include a probationary period for new employees. During this probationary period your ability to satisfactorily perform in the position will be assessed. At the end of this probationary period, and subject to satisfactory performance in the position, OIG may confirm your appointment. Responsibilities The manager of a new employee has responsibility to monitor performance during the probationary period and to arrange confirmation with the Chief Financial Officer at the end of the period. Guideline During the probationary period your performance will be closely monitored. The expected level of performance will be explained to you by your Manager during your first weeks at OIG. Unless otherwise stated in your Employment Agreement, your employer may give one week’s notice or one week’s pay in lieu of notice and you may give one week’s notice during the probationary period. If the probationary period is completed to the satisfaction of your employer, your permanent employment will be confirmed by your Manager. 22 April 2024 CONFIDENTIAL 7 Hours of Work OIG’s ordinary working hours are 37.5 hours per week. OIG expects staff will work around 7.5 hours a day during our core business hours of between 7.30am and 6:30pm, with precise start and finish times to be approved by your Manager. The usual spread of our core working hours is between 9:00am to 5.30pm each Monday through Friday (inclusive of a 1 hour unpaid lunch break). OIG will observe the gazetted public holidays in the state in which you work. Where you are requested by your Manager to work on a public holiday, an alternate day off with pay should be provided at a time agreed with your Manager. Whether working in the office of from home, we aim to complete the majority our work within our core business hours, and to set internal meetings between 10:00am and 3:00pm. Staff should use their judgement when communicating with clients and colleagues outside of regular business hours and, where possible, should avoid sending emails outside of 7.00am to 7.00pm on workdays. After Hours Work When an employee is required by their Manager to work after 7pm in the Office, OIG will reimburse them for the cost of: a meal up to the value of $20; and a taxi or “Uber” to their home. Any request for reimbursements must be approved by your Manager before being submitted for payment. 22 April 2024 CONFIDENTIAL 8 Flexible Working Arrangements (including hybrid working arrangements) Purpose Flexible working arrangements help OIG retain experienced employees and attract the best possible new employees by enabling employees to balance their personal needs and their work requirements. OIG will consider flexible work practice options for employees by individual negotiation. Where the flexible work arrangement is to allow an employee to work-from-home, the request will be considered in accordance with our working from home policy. Guideline OIG will consider flexible work requests from all employees including requests from employees who are pregnant, or where they, or a member of their immediate family or household, have experienced family and domestic violence, or in other circumstances where the National Employment Standards (NES) apply to employees. OIG will consider options such as: Moving from full time to part time work, either permanently or for an agreed period. Flexible working hours (such as nine day fortnights, changed hours to enable attendance at particular events such as school-parent discussions). A hybrid working arrangement where it is in line with our working from home policy. Salary sacrificing for additional holidays. Communication and consultation between management and employee is critical to the successful development of a flexible working arrangement. If you wish OIG to consider a flexible working arrangement, you must provide your Department Head with a written summary of the proposed arrangement, taking into account business requirements. The summary should take into consideration: Timing and length of the proposed work period. Location, if different from current arrangement. How the work will be completed. Impact on other employees and clients. Reason for your request. Any agreed changes to work hours or patterns may result in changes to your remuneration and benefits as salary is calculated against actual hours worked per annum. Department Heads are responsible for approving flexible working arrangements in consultation with the CEO, giving serious consideration to employee proposals in order to accommodate employee needs where practicable. OIG may deny flexible or remote work requests where there are reasonable business grounds for refusing a request, which may involve: considerations of any costs to OIG to implement the new working arrangements requested, the capacity and practicality of OIG changing the working arrangements of other team members to accommodate the new working arrangements requested, practicality, inefficiency or impact on OIG’s ability to meet our clients’ expectations. Approvals may be given on a trial basis. OIG will try to facilitate requests for flexible working arrangements and will respond in writing within 21 days to written requests for flexible work arrangements, to approve or reject the request. Where a request for flexible work arrangements is made under the NES, a request will only be refused after discussing it with the employee, genuinely trying to reach an agreement for alternative arrangements and 22 April 2024 CONFIDENTIAL 9 considering the consequences for the employee of refusing the request. Written reasons for such refusal will be provided. Working from home policy (WFH Policy) OIG is a client facing business operating at a fast pace in a highly regulated environment. Central to OIG’s Purpose, Vision, and Values is our ability to offer clients a “one-stop-shop” solution, bringing higher degrees of collaboration and integration than our competitors. OIG’s business requires high degrees of teamwork, professionalism, knowledge, and attention to detail. One Investment Group wants staff to be able to collaborate, train, mentor, socialise, network, and strategise as one team, and believes being in the office helps us achieve this. OIG is also committed to creating a work environment where people can balance their professional and personal lives and acknowledges hybrid working may support staff to live a balanced and healthy life. We want to encourage this balance where it is suitable and works for individuals, their team, OIG’s stakeholders, and the business as a whole. OIG’s WFH Principles Any hybrid working arrangement request will be considered by your Department Head against the following principles: Full-time employees may request to work from home up to 2 days per week, but generally such requests will only be approved after they have completed the first 3 months of their probationary period1. The WFH days nominated should be same days each week (and not the “all-in” day) and must be agreed with your Department Head. While, with your Department Head’s approval, you may be able to change the day within a week, this is not a permanent change, and any day in the office is not carried forward as an additional WFH day in any subsequent week. Department Heads will set one ‘all in’ day a week requiring all members of that team to be in the office. Clients’ needs are prioritised and WFH arrangements are planned around those requirements. Individual hybrid working arrangement must seek to: o minimise the potential impacts on other team members, the broader business, and OIG’s clients; o ensure effective communication is maintained both with other team members and OIG’s external stakeholders. This may require you to use your personal mobile to receive and make calls; o ensure you can comply with all of OIG’s policies and procedures when working from home; o ensure the preservation of confidentiality, integrity and availability of information but only to those intended to have access to that information; o ensure you can work from home safely, so you must provide completed relevant checklists as part of your request for flexible work; and o ensure your team can continue to deliver work on time and to a high standard. Any hybrid working arrangement agreed to, is subject to the following principles: OIG’s Hours of Work apply whether you are in the office or at home. Department Heads and Managers will aim to schedule team meetings for the “all-in day”. A Department Head may determine reoccurring key tasks, projects or meetings (such as month end reporting) requires staff to work onsite for the duration of that matter and not work from home until the conclusion of the matter and you will be expected to work from the office as required. If, for any reason, you are required to or choose to work in the office on the day that would be one of your usual WFH days, that day is not carried forward to the next week, but may, with your Department Head’s prior approval be substituted for another day that week. 1 See “Requesting hybrid working arrangements” below for more details. 22 April 2024 CONFIDENTIAL 10 Whether working from home or in the office we communicate and collaborate and use technology to include people in key discussions wherever they are working. We focus on what and how people deliver their work. This may determine future ability to work from home. Completed workplace health and safety checklists must be received before staff start to work from home. In any week where 2 or more annual leave days are taken, you will be expected to be in the office the remaining days. If 1 day of annual leave is taken in any week, you are permitted to WFH 1 day that week. However, the day to WFH is to be agreed with your Manager and must not be consecutive with the annual leave day. Regardless of work location: o Staff must comply with OIG’s policies and procedures including IT, Cyber Resilience and Disaster Recovery Policy, Privacy Policy and those policies set out in this Handbook with regards to dress code (for video conferences), drugs and alcohol and bullying and harassment; o we are open and honest communicating what is working well and what isn’t - so we can course-correct early; and o we all contribute to OIG’s culture and live its values. Requesting a hybrid working arrangement Under OIG's WFH policy each full-time employee may request to work from home up to 2 days per week. There is no requirement for you to work from home and, if you prefer, you can be in the office each working day. Please note that WFH arrangements are not a substitute for suitable child-care arrangements, particularly in relation to young children. You cannot WFH while having taking care of young children. If your request is approved, then your nominated WFH days must be agreed with your Department Head and will be subject to your nominated days to work-from-home: will be fixed (same days at home per week) cannot be the “all-in” day for your business unit cannot be consecutive days (for example you cannot select both Friday and Monday or Tuesday and Wednesday. You could select Tuesday and Friday, subject to your team’s nominated “all in” day). Your Department Head will aim to accommodate everyone’s preferences, but they must balance the requests of all team members and you may not be able to secure your first preference. OIG will require at least some members of each team to be in the office on each workday and all team members to be in on your business unit’s nominated “all-in” day. Ask your Managing Director if you need to either temporarily or permanently change your WFH day(s), and they will consider your request based on our WFH principles. If you need to work in the office, and you can’t substitute an alternative day from home that week, the day in the office is not carried forward as an additional WFH day in any subsequent week. If you are still in the probationary period of your employment, your Department Head will be focussed on ensuring you are settling in, forming relationships with your colleagues, and learning about your role. It is important therefore that you be based in the office full time alongside key mentors and colleagues, and hybrid working arrangements will only be approved in exceptional circumstances. Your Department Head will consider whether a hybrid working arrangement is right for you in your role and generally, you will be required to attend the office for the first 3 months of your probationary period. When requesting a hybrid working arrangement staff should demonstrate to their Department Head that they have considered the potential impacts on other team members, the broader business, and Clients including: How they will ensure effective communication when working remotely and whether they have consulted with their Manager to discuss their preference. How they will ensure their WFH arrangement will not affect the team’s ability to deliver work on time and to a high standard. 22 April 2024 CONFIDENTIAL 11 How they will ensure the team’s work schedule is not impacted by their working from home and what will be done to ensure others can continue to deliver their work. Demonstrating they have considered their clients’ needs ahead of time and plan their WFH arrangements around those requirements. Ad-Hoc Flexible Arrangements OIG understands all staff (including part-time, casuals and those in their probationary period) may require ad- hoc flexibility, outside of our WFH policy. In these situations, please discuss these requirements with your Department Head to see if your needs can be accommodated. For guidance, requests for ad-hoc flexibility are generally for arrangements that last no longer than two weeks and you are expected to schedule appointments (eg with trades-people or your local doctor or dentist) on your scheduled WFH days. When you may need to attend the office OIG wants to ensure that we are all actively working towards building and maintaining high performing, accurate and productive work culture that is compliant, safe, sociable. To do this OIG may require staff, regardless of their location or hybrid work arrangements, to attend in person the office, client meetings or functions or team building events. Your manager will inform you of these events ahead of time. To provide the best level of support, guidance and attention to new colleagues in your team, your Department Head may request that you work in the office full time for a period of time to ensure staff on-boarding training and development is both possible and effective. If a Manager has identified that a staff member requires additional support to learn or upskill within their role, then while they are developing those skills or working through performance/behavioural improvements, they may be required them to perform their role from the office full-time. Email and Communication Guidelines Whilst working from home provides greater autonomy and flexibility, it can also unintentionally extend normal business hours as team members can send emails at any time. Please consider the guidance given in “Hours of Work” section above. Work Health and Safety Based on government advice regarding Pandemics like COVID-19, you may be directed to work from home full time for a period of time in order to ensure compliance with OIG’s work, health and safety obligations. Each of us is responsible for creating a safe and comfortable work environment when working remotely. If you require any guidance in creating this environment, please speak to your Department Head or HR. The remote work checklist that has been distributed across the business should allow us to understand what level of support you need in order to be able to work effectively at home. Before you work from home in any capacity, this form must be completed. 22 April 2024 CONFIDENTIAL 12 Information Security Management System Staff requesting to work from home are required to: Only access OIG’s network using an approved devise and OIG’s VPN; Maintain appropriate security in their homes to ensure that the confidentiality and security of OIG’s information and that the premises are always secured. This should include locks on all doors and windows and ensuring any visitors to the home do not access OIG’s information; Work in a quiet place without distractions from other members of the household and to ensure other members of the household do not have access to any OIG information including by maintaining a clean desk and clear screen as would be required if they were working in the office; Keep printed documents classified as “confidential” and “sensitive” secure where they cannot be accessed by anyone else. Any failure to comply with these Information Security Management provisions will immediately terminate your ability to work from home and may result in disciplinary action. 22 April 2024 CONFIDENTIAL 13 Remuneration & Benefits Remuneration Framework Purpose OIG values the contribution employees make to the business and recognises the need to attract, retain and motivate employees through the provision of total reward packages which are market competitive and based on top pay for top performance. Guideline To ensure a market-competitive reward structure, OIG has access to both financial services and general job- market remuneration surveys. Our policy is to use these surveys as a guide, and to remunerate consistent with similar positions in similar organisations in the market. Total reward packages are designed to: Attract, motivate and retain the best talent through the provision of remuneration packages that are competitive with the market and industry; Align the interests of individuals with Business Unit and group results; Reinforce the high performance, innovative and collegiate culture of OIG; and Create a sense of ownership in OIG focused on building long term value. OIG will not reward employees with benefits that could reasonably be expected to influence them in the performance of their duties or the advice they give. OIG will not, for example, reward staff with commissions, volume-based payments, so-called 'soft dollar benefits' and volume-based shelf space fees. Elements of the Total Reward Package Fixed pay – includes salary and superannuation. Short Term Incentive (STI) – annual bonus which may be wholly discretionary or based on individual performance against agreed targets and the financial performance of the Business Unit and/or Group subject to position type. To be eligible for a discretionary bonus payment, you must be in employment at the date of payment and have at least three months’ service at the end of the financial year. Further, if either party gives notice of termination of your employment for any reason, then any bonus entitlement is forfeited for the year in which notice is given and for any subsequent period. As at the date of this policy OIG has no Long Term Incentive (LTI) plan although one may be implemented in the future. Employees entitled to participate in this plan will be issued with an invitation setting out their rights and obligations. The level and mix of fixed pay and “at risk” pay (STI/LTI) will vary for individuals based on their job type, level of expertise and performance. Employees will have their remuneration reviewed on an annual basis based on market information and it may or may not be increased. The reviews are generally done in June / July and any changes in remuneration are effective from 1 July each year. Incentive plans may change from time to time at the discretion of OIG to reflect changes in the business and the marketplace. Referral Bonus At One Investment Group we value you and your opinions- especially when it comes to inviting new members to join our team. OIG considers a referral is better than just finding a candidate through an ad because you refer them, and we think you will only refer someone who will help build up the skills in our team and will be 22 April 2024 CONFIDENTIAL 14 able to pull together to help continue being a cohesive team and most importantly someone who is a hard worker who you enjoy working with. We have an introduction bonus that we offer all members of staff. You may refer as many people as you like, there is no limit to how many people you can refer. How does it work? You need to refer us a candidate that you know and that you have worked with before or met through an industry event. You send that person’s CV with a summary of why you think they would be a good fit for our team. If you refer us to a candidate who then goes on to be employed by One Investment Group, you will be eligible for a referral bonus. This referral bonus is payable in two parts. Part 1: $250 when we hire the individual, this is payable in the next regular payroll period after the start date of the new hire. Part 2: $750 when that person completes their probationary period, provided you are also still employed with One Investment Group, which is payable in the next regular payroll period. You won’t have to refund Part 1 of the payment if the person’s employment doesn’t work out. This is a one-off bonus and is subject to tax and superannuation. Staff Expenses Claims One Investment Group will reimburse you for all reasonable and properly incurred approved expenses related to your employment. For Travel related expenses, see our Travel Policy in this handbook. For all other expenses you must provide original receipts / tax invoices for any expense you request be reimbursed and must submit your request within 3 weeks of expense being incurred. Reimbursement requests received a week before the next pay-roll cut-off time will be received in that pay-roll run and requests received less than a week before that cut-off date will be included in the next pay-roll run. Expense Manager only approval Manager and CEO / CFO Memberships / Subscriptions Less than $100 and less than $500 More than $100 and more than $500 in aggregate in the last 12 months in aggregate in the last 12 months Training / Education Less than $100 and less than $500 More than $100 and more than $500 in aggregate in the last 12 months in aggregate in the last 12 months Client entertainment Less than $100 More than $100 (pre-approval required) Electronic Fund Transfer Pay is transferred into a bank account nominated by you. As part of the Welcome Pack, you will receive a form seeking your bank details. This form must be completed and returned to the Chief Financial Officer. Pay will be deposited into the nominated account on the 15th of each month, covering two weeks in arrears and two weeks in advance. 22 April 2024 CONFIDENTIAL 15 Superannuation In compliance with relevant statutes, OIG provides superannuation to its employees as part of their remuneration to the legal minima. A superannuation form is provided with the Welcome Pack which will allow you to provide the details of your existing superannuation fund (stapled fund) into which your contributions will be deposited. Your chosen superannuation fund must comply with Australian superannuation laws and regulations. If you do not nominate a superannuation fund, we will have to check with the ATO to see if you have an existing super account. If not, employer contributions will be paid into the OCS default superannuation fund. The current employer superannuation contribution is 10.5% of salary up to the maximum superannuation contribution base (MSCB) for the relevant financial year. Employees may choose to make additional voluntary contributions towards superannuation from their pre tax (“salary sacrifice”) or post tax salary subject to any restrictions or limits imposed under law. Details of OIG’s default superannuation fund available to OIG employees who do not nominate an eligible super fund and OIG has received confirmation from the Commissioner of Taxation that the employee does not have a “stapled fund” is as follows. Fund Name AustralianSuper Phone: 1300 300 273 (8am–8pm AEST/AEDT weekdays) Email australiansuper.com/contact-us My Super: MySuper Authorised 65 714 394 898 856 Website www.australiansuper.com 22 April 2024 CONFIDENTIAL 16 Leave Purpose OIG recognises employees are a valuable asset to our business. Time out away from the office to re-charge and relax is encouraged, and we are committed to ensuring that annual leave is taken each year in order to provide you with an effective break from the working environment. Responsibilities Employee – must ensure a Leave Application Form is completed and approved by your Manager. Manager – must ensure appropriate leave is granted and authorised. Annual and long service leave must be taken at a mutually convenient time for the business. This may not always be the case for personal leave, compassionate leave, community service leave and domestic violence leave. Annual Leave Employees are entitled to annual leave in accordance with the National Employment Standards (NES). Annual leave should be taken each year as it is an important aspect of both OIG’s risk management and compliance frameworks and the health and safety of our employees (including by reducing the risk of employee-burnout). In this regard, most of OIG shuts-down over the Christmas and New Year periods and all but critical staff will be required to take annual leave during this period. Full time employees are entitled to four week’s paid annual leave for each 12 months of service. An employee’s entitlement accumulates continuously. Part time employees accrue annual leave on a pro rata basis, as a percentage of the full time hours worked they have worked. Casual employees are not entitled to annual leave. Accrued but unused annual leave, which carries over from year to year, will be paid out on termination of employment. Any employee wishing to access accrued but unused annual leave must do so by applying through OIG’s on- line system. Annual leave must not be taken until you have been advised it has been approved by your Manager. Generally no annual leave in advance of its accrual will be permitted to be taken, as is also the case for unpaid leave. The WFH Policy has some other considerations for when you may take annual leave where are working under a hybrid arrangement, which you should read before requesting your annual leave. In accordance with the NES, all employees wishing to access accrued but unused annual leave must provide reasonable notice of the request. At least two weeks’ notice will be considered to be “reasonable”, however, in unusual circumstances, lesser notice may be permitted at the discretion of OIG. We will usually refuse requests for annual leave where the notice period provided by any employee is unreasonable. Personal/Carer’s Leave Employees are entitled to personal/carer’s leave in accordance with the terms of the NES. Full-time employees are entitled to personal leave of 10 days each year. Part-time employees are entitled to pro-rata personal leave. Personal leave may be used as: paid sick leave, when an employee is not fit for work due to illness or injury; or 22 April 2024 CONFIDENTIAL 17 paid carer's leave, which an employee may take when an employee needs to provide care or support to a member of their immediate family or household, due to the personal illness or injury of that person, or an emergency which affects that person. Immediate family means any of: a spouse, de facto partner, child, parent, grandparent, grandchild or sibling of the employee; or a child, parent, grandparent, grandchild or sibling of a spouse or de facto partner of the employee. Unused personal/carer’s leave entitlements accrue from year to year. However, unused personal leave entitlements are not paid out upon termination of employment. If you do not have any personal leave accrued or you have exhausted your entitlement to take paid carer's leave in any year, you may take a period of up to 2 days as unpaid carer's leave on each occasion that a member of your immediate family or household requires care or support due to the personal illness or injury of that person, or an emergency which affects that person. You must advise your Manager personally of your absence on personal leave as soon as possible on the day of the absence as well as an expected date of return. A medical certificate stating both nature and duration of illness is required for absences in excess of one day. Where a medical certificate cannot be provided for the personal leave, you can provide a statutory declaration which includes details of evidence that substantiate the reason for the leave. A medical certificate will also be required for absences of one day if that day is immediately before or after a weekend or public holiday. OIG reserves the right to request an employee to provide a medical certificate from a registered health practitioner if it is reasonably practicable to do so, otherwise it may require a statutory declaration. Long Service Leave Employees are entitled to paid long service leave in accordance with the long service leave legislation applicable in the state in which they work. Compassionate Leave Employees are entitled to two days paid compassionate leave on each occasion that a member of their immediate family or household: contracts or develops a personal illness or sustains an injury that poses a serious threat to his or her life; or dies. One Investment Group may ask you to provide satisfactory evidence within a reasonable time after taking the leave. Immediate family means any of: a spouse, de facto partner, child, parent, grandparent, grandchild or sibling of the employee; or a child, parent, grandparent, grandchild or sibling of a spouse or de facto partner of the employee. Community Service Leave Employees are entitled to community service leave in accordance with the NES when they: are summoned to participate in jury service; or participate in eligible community service activity, such as voluntary emergency management service relating to dealing with a current emergency or natural disaster. 22 April 2024 CONFIDENTIAL 18 Community service leave is unpaid leave, except where the employee is participating in Jury service, in which case community service leave is paid leave for up to ten days. Where an employee is paid by the court in respect of any period for which they also received payment from One Investment Group, the employee must sign over the payment from the Court to One Investment Group. Family and domestic violence leave Paid family and domestic violence leave applies to all types of employees (including part-time and casuals). Up to 10 days in any 12-month period is available in full at the commencement of each 12 month period of employment. It is available as either 10 continuous days or in separate periods of more than one day each. It does not accrue through the year and does not accumulate from year to year. The 10 days resets at the beginning of each work anniversary. Employees will be entitled to take unpaid family and domestic violence leave if they need to deal with the impacts of family and domestic violence, and it is impractical this be undertaken outside of their ordinary hours of work. Family and domestic violence includes violent, threatening or other abusive behaviour by a close relative of an employee that seeks to coerce or control an employee and causes the employee harm or to be fearful. Examples of situations in which an employee may need to deal with the impact of family and domestic violence includes arranging for the safety of the employee or a close relative, attending urgent court hearings, or accessing police services. We may ask you for evidence as to whether the leave was taken to deal with family and domestic violence where it is reasonable for us to do so. We will keep any information you provide OIG confidential (as far as reasonably practicable). Unpaid Parental Leave Both male and female full-time and part-time employees (and "eligible" casual employees as defined under statute) may be entitled to 12 months of unpaid parental leave in connection with the birth or adoption of a child. Parental leave rights are provided in accordance with the NES. Details of parental leave and related entitlements can be found at www.fairwork.gov.au. To be eligible for unpaid parental leave, an employee must have completed 12 months of continuous service with One Investment Group at the date of birth or placement, or the expected date of birth. An employee must inform their Manager with their specific intentions to take unpaid parental leave with at least 10 weeks written notice (unless it is not possible to do so), specifying: the intended start and end dates for any continuous unpaid parental leave; and the total number of flexible unpaid parental leave days they intend to take. At least 4 weeks before the intended start date for the unpaid parental leave, an employee must: confirm (or inform of any changes to) the intended start and end dates for any continuous unpaid parental leave; confirm the total number of flexible unpaid parental leave days they intend to take. 22 April 2024 CONFIDENTIAL 19 Where taking flexible parental leave, an employee must provide at least 4 weeks’ notice of the specific flexible parental leave days they intend to take. Parents can begin unpaid parental leave at any point within 24 months following their child's birth or placement. Parents and pregnant employees may take 100 flexible parental leave days over a 24-month period commencing on the first day you take parental leave. Pregnant employees can access some of the 100 days flexible entitlement up to six weeks before their child's expected date of birth. Both parents can take up to 12 months’ unpaid parental leave over 24 months, irrespective of the leave the other parent takes. Parents can request an extension of unpaid parental leave up to an additional 12 months without affecting the leave available to the other parent. Requests to extend the period of parental leave must be made in writing within at least 4 weeks of the end of their current period of parental leave. Requests will be considered based on the reasonable business needs of One Investment Group. Eligible employees may take already accrued but unused annual leave and long service leave entitlements during their unpaid parental leave. However, the total period cannot exceed 52 weeks away from work (or 104 weeks where extended parental leave is provided). Employees will need to confirm their intention to return to work in writing at least 1 month prior to recommencing work. Employees are entitled to return to the same job, or if that position no longer exists, to a similar job at the same remuneration level to the one held by the employee when they went on parental leave. Federal Government’s Paid Parental Leave Scheme Some employees are also entitled to government funded paid parental leave. Services Australia provides details of the federal government’s Paid Parental Leave scheme, which provides government funded Parental Leave Pay at the National Minimum Wage to employees who meet eligibility criteria. Please refer to Service Australia for further information. If you are eligible, you need to inform OIG that you want to claim Parental Leave Pay under the federal government scheme with 10 weeks written notice since OIG will then need to register with Services Australia. Public Holidays All full-time employees are generally entitled to paid public holidays gazetted in the state in which they work. Part-time employees are entitled to paid public holidays gazetted in the state in which they work where the public holiday is on one of their regular workdays. One Investment Group may request employees to work on a public holiday on a reasonable basis, for example where the employee is based in a state with a gazetted public holiday but the functional jurisdiction of the client they service, does not have a public holiday and an urgent task requires completion and that task cannot reasonably be performed by another person. Leave Form For any form of leave, you must complete a Leave Application through OIG’s on-line employee services portal. Your application will be promptly considered for approval. Once approved, the payroll records will be automatically adjusted to reflect your period of leave. 22 April 2024 CONFIDENTIAL 20 Personal Progress Performance Management Purpose The purpose of the performance management system is to establish key result areas and targets for you (in line with business priorities); to give you feedback on your progress; provide an opportunity for you to discuss your career and development needs; and establish self-development plans designed to improve your performance and contribution to the business. Performance reviews for all employees are usually conducted at least once a year with your Manager. Feedback on performance at other times of the year, informal and formal, may occur at intervals initiated by either employee or manager. Guideline Ongoing performance management is seen as a shared responsibility of both you and your Manager. While formal reviews are conducted at least once a year, you are expected to take responsibility for your own performance by initiating discussions with your Manager regularly regarding your performance. In turn, managers are responsible for communicating business priorities for their area and providing regular feedback to their staff. The performance appraisal The annual performance appraisal process is fairly informal. Generally there is a meeting where the employee and their manager discuss their performance for the year and if there is anything their manager could do to assist the employee to achieve their goals. You should arrange a suitable time to meet with your Manager in February each year. Your manager, as part of the review process, might ask you to complete a self-appraisal for the past year or perhaps prepare a draft Performance Agreement for the coming year. If a Performance Agreement is required, it should be in place by the end of March at the latest. Reviews should discuss achievements, areas for improvement, training & development needs and any changes which need to be made to the Agreement as a result of changed business circumstances. Process to review performance appraisal If you do not agree with the results of your performance appraisal, you should: Speak to your Manager and take some time to review and reflect on the feedback. If you still do not agree with the result or you cannot reach agreement, speak to Frank Tearle or Justin Epstein. A Dynamic Process Performance management at OIG is a dynamic and evolving process, and will be subject to ongoing changes and improvements. General Performance reviews must be: Conducted in a professional manner. There should be no interruptions and ample time should be allocated to their conduct. Objective specific examples should be cited to demonstrate a point. 22 April 2024 CONFIDENTIAL 21 Constructive and positive, giving consideration to both strengths and areas for improvement. Training, Education Assistance & Professional Development Purpose OIG encourages and supports all employees, including its responsible managers, who wish to undertake further education and training which will be of benefit to their current or future employment at OIG. OIG’s Training Policy recognises that ongoing education and professional development is primarily the responsibility of each employee. However, because the group benefits from well-educated staff, OIG will support employees in their ongoing education and professional development. Details of staff training and educational assistance are set out in OIG’s Training Policy. This financial assistance is an investment by OIG in its staff and accordingly if you leave OIG within 12 months of OIG having paid or reimbursed you for the training and development expense, you may be asked to reimburse OIG for all or part of the costs incurred. 22 April 2024 CONFIDENTIAL 22 Workplace Health & Safety Purpose OIG is committed to ensuring the health, safety and welfare of all its employees, contractors, clients, visitors and other persons at its workplace. Policy We are committed to providing a safe work environment including: minimising psychosocial risks in the workplace (being anything that could cause an employee psychological harm (e.g. harm someone’s mental health); providing equipment and substances which are safe and free from risks to health; systematically identifying hazards as they arise and assessing and minimising risks a rising from those hazards; providing adequate information, instruction, training and supervision to ensure health and safety at work; consulting employees in relation to matters affecting their health and safety; establishing measurable objectives and targets to ensure continued improvement aimed at eliminating work-related injury and illness; and complying with all relevant WHS legislation, Codes of Practice, Australian Standards and industry standards. This policy will be reviewed on a regular basis to ensure that it is appropriately implemented and continues to improve our WHS performance. OIG’s CEO is responsible for implementation and monitoring of the policy. Complaints Management Investors and other clients may complain about OIG’s services and products. While OIG acknowledges the importance of complaints and encourages investors and other clients with genuine grievances to bring these to OIG’s attention, OIG does not tolerate unreasonable conduct by complainants where this amounts to bullying or harassment of our staff involved in complaints handling. Where staff involved in complaints handling are subjected to unreasonable behaviour that they are concerned may amount to bullying or harassment they should alert their Manager who will assist in managing the complaint. Drugs and Alcohol Introduction As part of OIG’s commitment to ensuring a safe and healthy workplace for all employees, contractors and visitors, OIG has developed the following policy on the use of drugs (including both prescription and illegal drugs) and alcohol in the workplace. The use of drugs and alcohol may impair a person's ability to perform their job safely and efficiently with respect to other employees, visitors and contractors. The use of such substances may result in the risk of injury or a threat to the well-being of the impaired employee, other employees, visitors and/or contractors. As such, One Investment Group believes it is important to implement a drug and alcohol policy in order to protect its employees, visitors and contractors and to ensure that the workplace is a safe environment. Employees of One Investment Group must also take reasonable care for their own and others’ health and safety and to cooperate with One Investment Group in respect to action taken to protect their own and others health and safety. 22 April 2024 CONFIDENTIAL 23 Prohibited Conduct Cigarettes, Tobacco and Vaping All OIG premises are no smoking areas and smoking or vaping by anyone is not permitted. Alcohol No employee is to attend for duties when under the influence of alcohol. If an employee attends for duties and in the opinion of their manager, is unfit to perform those duties as a result of being alcohol impaired, they will be asked to leave the premises. Presenting for work while under the influence of alcohol will be cause for disciplinary action and in appropriate circumstances may lead to immediate termination of the employee's employment. No employee may drive any vehicle for OIG purposes whilst under the influence of alcohol. Illegal Substances Any substance that is illegal, unlawful, prohibited or banned is not to be taken onto OIG’s premises in any circumstances whatsoever. Any employee who brings an illegal substance into the workplace will be disciplined and if appropriate, the employee's employment may be immediately terminated. Legal authorities will be notified. One Investment Group's policy is zero tolerance for any employee who manufactures, uses, distributes or sells an illegal substance on or from the workplace or during the course of their employment. Any employee who engages in the manufacture, distribution, selling or use of an illegal substance (even for a first offence) will have their employment immediately terminated. Legal authorities will be notified. Exceptions Work Functions From time to time One Investment Group may organise a work function or work-related social function for employees where alcoholic beverages are available. Any employee participating in an approved, work-related activity or event where alcohol is served, should at all times be conscious of the fact that they are representing the organisation, whether directly or indirectly, and responsible consumption is expected. Furthermore, if driving a vehicle, employees attending these functions must comply with legal requirements in relation to their blood alcohol level and should arrange alternative transportation if they have been consuming alcohol. Employees at all times must also ensure their conduct and behaviour towards other employees and third parties is appropriate and does not contravene requirements in this Handbook including our Code of Conduct and Harassment and Bullying provisions, if under the influence of alcohol at such events. Prescribed or Legal Medication This Policy is not intended to prevent an employee taking a legal therapeutic substance to treat a medical condition. Individuals who are taking medication should ensure that such medication is taken strictly as directed by their medical practitioner. It is the individual’s responsibility to ensure that any medication does not have a detrimental impact upon the safe performance of their duties. 22 April 2024 CONFIDENTIAL 24 Any employee who is taking prescription drugs which are known to potentially affect their capacity to drive, use machinery or safely perform their required duties should inform their manager immediately so that appropriate steps can be taken to eliminate, control or reduce any potential risks. Any information given to the Manager must be in writing and will be kept strictly confidential. Disciplinary Action An employee who breaches any provision of this section will be subject to disciplinary action up to and including, inappropriate circumstances, termination of employment which may involve summary dismissal. 22 April 2024 CONFIDENTIAL 25 Employee Conduct & Related Matters Values Statement and Code of Conduct PURPOSE To provide global and domestic investment managers, sovereign wealth funds, Why we insurance groups, pension funds and private equity firms with market-leading exist responsible entity, trustee, custody, fund administration, registry and company secretarial services either as a complete turn-key solution or as discrete services. STRATEGIC Deliver a personalised and responsive service to accommodate our clients’ unique GOALS needs. Establish trusted relationships with all our stakeholders including our What we investment managers, investors in the funds we operate and our clients and to reflect hope to do passion and enthusiasm in everything that we do striving to achieve positive results for our stakeholders by aligning ourselves with their success. Integrity: We act with integrity in all we do including acting lawfully, ethically and responsibly. Partnership: Work in true partnership with our clients providing expert guidance not just on how to do things but also how they should be done. Exceptional Service: We are adaptable, agile and decisive providing exceptional VALUES How we service to our clients through experts in each service area to maintain our will do it industry-leading service standards. Passionate: We are committed to being always passionate and enthusiastic about our clients’ affairs. Diverse: We embrace our diverse backgrounds, experiences and perspectives working together to deliver superior outcomes. Open: We encourage everyone to speak-up about the things that matter. Purpose of our Code of Conduct It is important for all employees of OIG to maintain high moral and ethical standards consistent with OIG’s values. Some of these standards are set out in this Code of Conduct. This Code of Conduct is not intended to be exhaustive and cannot anticipate every situation which may morally or ethically compromise an employee or OIG. In this regard OIG expects its employees to use their common sense and sound judgement. If you are in any doubt as to how to act in any situation, please speak with your Manager and seek advice prior to taking any action. All requests for advice will be dealt with confidentially. You are required to do the following: Acting in accordance with OIG’s Values 1. To in a manner consistent with OIG’s values including acting honestly and with high standards of personal integrity. 2. Not to knowingly participate in any illegal or unethical behaviour. 3. Not to engage in conduct likely to discredit OIG. 4. To act responsibly and to respect the rights of, and obligations owed to, investors, clients, other employees, tenants, suppliers, outsource providers and the community at large. Conflicts of interest 5. To act in the best interests of investors and, if there is a conflict between the investor’s interests and the interests of OIG, give priority to the relevant investors’ interests. 22 April 2024 CONFIDENTIAL 26 6. Not to make improper use of their position as an OIG Staff member to gain, directly or indirectly an advantage for themselves or for any person or to cause detriment to investors. 7. To avoid any conflicts between the OIG Staff member’s personal interests (including the interests of any family member) and the interests of any OIG entity, the One Investment Group and where relevant, investors. This includes avoiding any perceived conflicts of interests. 8. Not to take advantage of property, confidential information or position, or opportunity arising from any of these, for personal gain (which includes provision of such material to another person outside of OIG where they may take advantage of such material) or to compete with OIG. Information and property 9. Not to make use of information acquired through being an OIG Staff member in order to: a. gain an improper advantage for themselves or another person; or b. cause detriment to investors. 10. To respect the confidentiality of all information acquired in the course of their duties and not use or disclose to third parties, confidential information. Further obligations in relation to confidential information are set out in your employment agreement. Compliance 11. To take all reasonable steps to ensure that they and OIG comply with all laws and regulations that apply to the Group and its operations including: the Corporations Act (examples are given below) any condition imposed on an entity with an AFS Licence; the constitutions of any scheme for which a Group entity is the responsible entity; and the Compliance Plans of any scheme for which a Group entity is the responsible entity. 12. To report to the Group’s Compliance Officer or Compliance Committee any situation where they are concerned that there may be a breach of this code of conduct or any other breach of law, the Constitutions of any scheme, or the Compliance Plans of any scheme. 13. In addition to any of the duties set out above, to generally uphold the fiduciary responsibilities OIG Staff owe to investors and to comply with the spirit, as well as the letter, of the law and with the principles of this Code of Conduct. Fairness 14. To treat fellow staff members with respect and not to engage in bullying, harassment or discrimination. 15. To deal with investors, clients, suppliers and other stakeholders fairly. OIG Staff should request all key contractors acting on behalf of One Investment Group comply with a similar set of ethical standards and cease using any contractor who they consider is not complying with an ethical standard at least as rigorous as the standard set out above. Specific requirements to meet OIG’s Code of Conduct In order to meet OIG’s Ethical Standards, OIG’s Staff members must comply with this Code and the Group’s Policies and Procedures, some of which are highlighted below. 22 April 2024 CONFIDENTIAL 27 Privacy The issue of privacy is taken seriously at OIG. We collect personal information from employees, clients, suppliers and other stakeholders in various formats. You must take reasonable steps to ensure people’s privacy is protected and comply with OIG’s Privacy Policy (available on the Policy O Drive). Bribery, corruption and receiving gifts and benefits One Investment Group strictly prohibits, and does not condone any form of bribery or corruption. One Investment Group will not offer facilitation payments of any kind. To avoid the perception that a gift or other benefit could affect their judgement, OIG Staff must not seek, accept, offer or give (directly or indirectly) any significant benefit without the prior approval of their Manager. OIG Staff must, before making a donation, consider the ramifications for the Group of their making a donation to a cause, charity or political party that would conflict with their duties and obligations to One Investment Group including one of its Funds. Directors and Officers of a Group Entity must not make political donations to any political party. Details of OIG’s approach to bribery, corruption, facilitation payments, gifts and benefits are set out in OIG’s Anti-Bribery and Corruption Policy. Managing Conflicts of Interest OIG has a detailed Conflicts of Interest Policy and Staff must comply with that policy. The following is intended as a summary only. Conflicts of interest may arise: (a) between One Investment Group’s various legal structures and the capacities in which they act including acting as responsible entity to scheme where there is an inherent conflict between the responsible entity and investors, for example with regards to the payment of fees from scheme property to the responsible entity. Having multiple business units may give rise to certain conflicts of interest that will need to be managed (Business Conflict); or (b) if an OIG Staff member or their families, friends or business associates have a personal interest in a business decision involving One Investment Group (Staff Conflict). Managing Business Conflicts One Investment Group’s arrangements to manage conflicts of interest affecting its business involve the following mechanisms: controlling conflicts of interest; avoiding conflicts of interest; and disclosing conflicts of interest. (Controlling conflicts of interest) In controlling conflicts of interest, OIG will: identify the conflicts of interest relating to its business; assess and evaluate those conflicts; and decide upon, and implement, an appropriate response to those conflicts (which may include disclosing and/or avoiding the conflicts). (Disclosing conflicts of interest) Where appropriate, OIG will disclose conflicts of interests to relevant investors. The disclosure should: be timely, prominent, specific and meaningful to the relevant investors; 22 April 2024 CONFIDENTIAL 28 occur before or when OIG provides a service to, or enters into a transaction with, the relevant investors and in any case allowing those investors sufficient time to assess the impact of the conflict; contain enough detail for the relevant investors to understand the potential impact on the service provided to them by the relevant OIG entity. The level of disclosure required may also depend on the type of unit holder (e.g. wholesale vs retail investors). (Avoiding Conflicts of Interest) In some cases conflicts cannot be adequately addressed by controls or disclosure. This may occur where, for example, the continuing presence of a conflict (even if disclosed) is not compatible with treating investors fairly and honestly. In this situation One Investment Group should either: ensure that the conflict is avoided entirely; or not provide the service to, or enter into a transaction with, the relevant client. Managing Staff Conflicts One Investment Group requires OIG Staff to disclose and wherever possible avoid conflicts or potential conflicts of interest. OIG has detailed policies governing the identification and management of these conflicts of interest including conflicts that may arise as a result of: outside employment or appointments (see Conflicts of Interest and Related Party Transactions Policy); staff trading in financial products during certain times, or when they are in possession of certain types of information (see Securities Trading Policy). Whistle blower Protections All OIG Staff are encouraged to bring concerns they have with any aspect of OIG’s operations or the trusts and schemes it operates to the attention of their manager, the Compliance Officer or to the attention of an Director. In order to encourage employees to report their concerns freely, the One Investment Group has adopted a Whistle-blower Policy that describes: the protections available to whistle-blowers; the people to whom protected disclosures may be made, and how they can be made; how the One Investment Group will support whistle-blowers and protect them from detriment; how the One Investment Group will investigate protected disclosures; and how the One Investment Group will ensure fair treatment of OIG employees who are mentioned in protected disclosures, or to whom those disclosures relate. OIG’s Whistle-blower Policy is available on the O Drive in the Policies folder. Media Comment Employees may not make statements or comments to the media or other external bodies regarding OIG, its business dealings, financial status, or its customers unless directed or authorised by OIG. You must direct all media enquiries to the CEO for approval. Return of OIG Property On termination of employment for any reason whatsoever, all OIG property must be returned immediately to your Manager. 22 April 2024 CONFIDENTIAL 29 Misuse of Company or Scheme Property, Information & Resources Generally, the use of the property, information, and resources of OIG for any purposes other than the business of OIG is prohibited, for instance, approving or making of a payment on behalf of OIG for something other than the stated purpose. Scheme property may only be used for the benefit of unitholders of the relevant scheme. Authority to Sign documents Employees cannot sign any documents on behalf of OIG or in any way commit OIG to any agreement unless they have been properly authorised in writing by OIG to do so. Intellectual Property One of OIG’s most important assets is its intellectual property, including its software, copyrights, patents, trademarks, trade secrets, and training manuals. Each employee is responsible for protecting OIG’s intellectual property rights by complying with OIG’s policies and procedures for the protection of these rights. Whilst employed by OIG, all intellectual property that is related to the affairs of OIG including patents, copyrights, inventions, programs and documentation generated by you will become the property of OIG. Further details of your obligations in relation to intellectual property are set out in your employment agreement. 22 April 2024 CONFIDENTIAL 30 Employee Behaviour Purpose As an employee of OIG you represent the Group at all times. The professional image of our Group is directly linked to the way we present ourselves, and so we all must maintain a high standard of conduct both in the office and elsewhere. Conduct that interferes with operations, discredits the Group, or is offensive to clients or co-workers will not be tolerated. Therefore in addition to the Code of Conduct, OIG provides you with the following guidelines for appropriate behaviour. Guideline We believe certain rules and regulations regarding employee behaviour are necessary for efficient business operations and for the benefit and safety of all employees. You are expected at all times to conduct yourself in a positive manner while at work. Conduct that is not in investors’ best interests, interferes with operations, discredits OIG, or is offensive to investors, customers, suppliers or colleagues will not be tolerated. Appropriate conduct includes, but is not limited to: Compliance with published policies, practices and procedures. Competent performance of all job related activities. Treating all clients, visitors, suppliers and colleagues in a courteous manner. Complying with all company safety and security regulations. Minimising unplanned absences and providing proper advance notice whenever unable to work or report on time. Maintaining cleanliness and order in the workplace. Reporting to management any suspicious, unethical or illegal conduct by colleagues, clients, visitors, or suppliers. Refraining from behaviour or conduct that is offensive, discriminatory, harassing, or which is contrary to OIG’s best interest. Dress Code We are all expected to present a business-like image to clients, suppliers and each other, that reflects the nature of our business. What we mean by this is you should be well groomed when meeting investors, clients and suppliers. Typically, men are required to wear business suits. Women are required to dress professionally in any of business suits, tailored business pants and shirts or dresses. At other times, casual business dress is considered appropriate, and we would expect you to present in a neat and professional way. This does not include ripped or dishevelled clothes, beach or sportswear, revealing clothes or any other inappropriate clothing. In line with our policy to prevent harassment, clothes, buttons/pins, hats or other personal articles that contain risqué or offensive words, language or pictures are considered inappropriate and should not be worn. If you are unsure about appropriate dress code, please speak with your Manager. 22 April 2024 CONFIDENTIAL 31 Diversity and Inclusion Policy Purpose This Policy describes OIG’s approach to diversity and inclusion and how this is embedded in our work. One Investment Group respects and values the diversity of our employees, clients, investors and other stakeholders and we support, encourage, and celebrate our diverse workforce and inclusive workplace. OIG’s values include diversity and we embrace diverse backgrounds, experiences and perspectives to deliver superior outcomes. We believe that diversity and inclusion across gender, ethnicity, culture, sexuality, physical or mental ability, educational background, socioeconomics, and other individual characteristics will help create an environment that reflects our community and enhances our organisation. OIG recognises that a diverse and inclusive workplace is attractive to potential employees and clients and provides OIG with an advantage when competing for talent and retaining talented people as well as meeting OIG’s legislative obligations. Guideline This Diversity and Inclusion Policy provides a framework to support OIG’s commitment to a diverse workforce and inclusive workplace for all our people. A diverse workforce provides a workplace where decisions, processes and practices are fair, clearly defined and based on merit. To ensure this occurs, it is necessary to identify, discourage and prevent any occurrence of discrimination, harassment, bullying or victimisation within the workplace. Diversity and inclusion definitions and principles This section outlines OIG’s overall commitment to diversity and inclusion; and how OIG embeds these in its workplaces. Definitions Diversity is the term for including all individuals from various backgrounds and characteristics such as demographic, personal or any other characteristic of an individual. Some examples of these include such characteristics as gender, marital status, physical impairment, national or ethnic origin, age, religion, race or sexuality. A full list of these characteristics is included in our EEO Policy below. Inclusion is the term for providing equal access of resources and opportunity for all individuals, which includes those individuals who might otherwise be considered marginalised. Indirect discrimination occurs where there is a requirement (or condition, policy, practice, procedure) that, although applying to everyone, may have a discriminatory effect on one group. Direct discrimination occurs when a person is treated less favourable than another due to an attribute or characteristic they may have. (for example: not offering employment to a person on the basis that they are ‘too old for the job’) This includes activity which permeates or colours OIG’s working environment with discriminatory innuendo or jokes. Unacceptable behaviour includes: poster displays, telling discriminatory jokes, or making racially derogatory remarks about a person. It can include sending email, or postcards, displaying or discussing material or constantly making comments with double meaning. 22 April 2024 CONFIDENTIAL 32 Principles OIG’s principles of an inclusive workplace are based on the pillars of our Values Statement. OIG is committed to ensuring that its employees, colleagues and visitors do not suffer any form of unlawful discrimination and that policies, practices and procedures in the workplace are fair and do not unlawfully discriminate against any group of employees. Compliance This policy should be read in conjunction with other OIG policies that support OIG’s commitment to a diverse and inclusive workplace and the expected behaviour and conduct of our people, including our Equal Employment Opportunity Policy, our Grievance Policy and our Training Policy. These policies support OIG’s compliance with laws and its commitment to diversity and inclusion by describing behaviours, including discrimination, harassment and bullying, that are unlawful and unacceptable at OIG and the obligation of all Staff to ensure a workplace free from unacceptable and unlawful behaviours. 22 April 2024 CONFIDENTIAL 33 Anti- Discrimination Purpose OIG is committed to meeting its legislative obligations relating to discrimination, and will take all reasonable, practicable steps to provide and maintain a working environment free from behaviours and actions that are discriminatory. An internal grievance resolution process assists employees to raise issues of concern, and all complaints will be treated seriously and sympathetically. No employee will be penalised or disadvantaged as a result of raising any genuine concern or complaint. Relevant and appropriate disciplinary action will be taken against anyone found to have breached this policy. Guideline What is Discrimination? Discrimination occurs when a person is treated less favourably in employment situations as a result of that person's individual characteristics, or because that person belongs to a particular group. Discrimination on the basis of the following characteristics is unlawful: race (including colour, nationality, religion, ethnic or ethno-religious origin); sex (including marital status, pregnancy or potential pregnancy, breastfeeding); sexuality (including sexual preference, transgender status or homosexuality); disability (including physical, psychiatric or intellectual disabilities); age; illness or injury; parental status or responsibilities as a carer; or membership or non-membership of a union. Discrimination is described as direct and indirect. 1. Indirect discrimination occurs where there is a requirement (or condition, policy, practice, procedure) that, although applying to everyone, may have a discriminatory effect on one group. 2. Direct discrimination occurs when a person is treated less favourable than another due to an attribute or characteristic they may have. (for example: not offering employment to a person on the basis that they are ‘too old for the job’) This includes activity which permeates or colours OIG’s working environment with discriminatory innuendo or jokes. Unacceptable behaviour includes: poster displays; telling discriminatory jokes, or making racially derogatory remarks about a person. It can include sending email, faxes or postcards, displaying or discussing material or constantly making comments with double meaning. Employees must not discriminate against other employees, prospective employees, contract workers or visitors at the workplace, or in provision of goods, services and facilities on unlawful grounds. Discrimination at work is an unpleasant part of many people's working lives. OIG is determined it will not happen in our business. Accordingly, any forms of discrimination mentioned above will not be tolerated under any circumstances, as it can make a working environment uncomfortable, hostile or even dangerous. An employee who is found to have breached any terms of this policy will be disciplined and may be dismissed. Complaints and victimisation Any employee or other person who makes a complaint of discrimination in the workplace, in good faith will be treated with consideration and their complaint/s will be taken seriously and investigated or otherwise dealt with sympathetically and fairly, as confidentially as reasonably possible. Complaints to OIG will be attended to promptly and discretely. They will be investigated impartially and reasonable action will be taken to ensure that any misconduct ceases. Victimisation occurs when an employee is treated or threatened that they will be treated in an adverse manner as a result of making, or threatening to make or supporting a discrimination complaint. OIG takes very seriously any effort at retribution for making a complaint or victimisation of a person who has made a complaint. If you think you are being unlawfully discriminated against, you should not ignore the conduct, hoping it will go away. If you can, you should speak to the person responsible for the conduct and ask that person to stop. If you do not feel that you can do this, or it doesn't work, you should talk to your Manager or the CEO. Any complaints will be treated as confidentially as reasonably possible. Please refer to the Grievances Policy for further details in relation to out grievance procedure. Your Manager or the CEO may be contacted at any time to discuss any complaint or enquiry. You may approach them for general advice or to discuss any issue. They may also investigate complaints or arrange an independent person to investigate the complaints. Depending on what you want and on the nature of the complaint, it might be appropriate for OIG make a formal determination about what has happened, and to decide about what the consequences should be. Conduct which breaches this policy Conduct which breaches this policy is unacceptable and, depending on the severity and circumstances, may lead to disciplinary action. OIG will take appropriate disciplinary action against an employee who is responsible for, or engages in, any form of unlawful discrimination. Disciplinary action might include any of: a requirement to provide a written or verbal apology; a formal warning; a requirement to attend training or counselling; and dismissal, with or without notice or payment in lieu of notice. False Complaints Making an allegation of discrimination is a serious matter. Employees who knowingly or without good faith, make a false complaint will be subject to disciplinary action, which may include dismissal. 22 April 2024 CONFIDENTIAL 35 Harassment & Bullying Purpose OIG is committed to providing a workplace that is free of harassment and bullying, as prescribed by Commonwealth and state legislation. Harassment and bullying take different forms which will be covered later in this policy. OIG is committed to meeting its legislative obligations relating to harassment and bullying, and will take all reasonable, practicable steps to provide and maintain a working environment free from these behaviours. An internal grievance resolution process assists workers to raise issues of concern. All complaints will be treated seriously and sympathetically. No worker will be penalised or disadvantaged as a result of raising any genuine concern or complaint. Harassment and bullying of colleagues, clients or visitors at work is unacceptable behaviour and OIG will not tolerate it. Relevant and appropriate disciplinary action will be taken against anyone found to have breached this policy. Guideline What is Harassment? Harassment is unwelcome, uninvited behaviour, which offends, humiliates or intimidates a person or is likely to offend, humiliate or intimidate another person. It does not matter that there is no intention to harass. Examples of conduct that may constitute harassment include but are not limited to: a) activities which permeate or create a hostile work environment at OIG; b) swearing in the workplace; c) gossiping about a person; d) making, circulating or displaying jokes containing inappropriate or offensive content; e) intrusive enquiries into another person's personal life, including his or her religion, family or private matters; f) constantly monitoring what someone else is doing, giving negative criticism or ‘nit-picking’; g) openly displaying pictures, posters, graffiti or written materials which might be offensive to some; and h) communications via phone, email or computer networks which are threatening, abusive or offensive to others. It is important to distinguish between unwelcome, unreciprocated behaviour and mutually acceptable behaviour. For example, harassment does not usually include genuine compliments. What is Sexual Harassment? Sexual harassment occurs when a person makes an unwelcome sexual advance, an unwelcome request for sexual favours or engages in any other unwelcome conduct of a sexual nature in relation to another person. Sexual harassment may take various forms, such as: a) uninvited requests or demands from a person for sexual or social contact, especially with the implication that refusal might adversely affect conditions or opportunity for promotions at work; b) inappropriate physical contact or unnecessary familiarity; c) sexual innuendo or jokes; d) offensive comments on physical appearance, dress or private life; e) lewd jokes; f) public display of pornography in the workplace, including on the internet by email, or on mobile phones; g) unsolicited physical contact, such as patting or pinching; and 22 April 2024 CONFIDENTIAL 36 h) sexual violence, indecent or sexual assault. Some of the above may also amount to a criminal offence. Sexual harassment often relates to a misuse of power to create an unequal working relationship. This policy is not about prohibiting friendships at work or genuine consenting relationships. What is Bullying? Workplace bullying is a psychological hazard. OIG believes all workers should work in an environment free from bullying where everyone is treated with dignity and respect. Workplace bullying is defined as repeated, unreasonable behaviour that demeans, intimidates, victimises, threatens or humiliates people, either as individuals or as a group. It may create a risk to health and safety. Repeated behaviour refers to the persistent nature of the behaviour and can refer to a range of behaviours over time. Bullying is not necessarily related to an attribute of a person. Bullying may involve a risk to the work, health and safety of workers. Unreasonable behaviour means behaviour that a reasonable person, having regard for the circumstances, would see as unreasonable, including behaviour that is victimising, humiliating, intimidating or threatening. Examples of behaviour that may be considered to be workplace bullying include: abusive, insulting or offensive language or comments unjustified criticism or complaints deliberately excluding someone from workplace activities withholding information that is vital for effective work performance setting unreasonable timelines or constantly changing deadlines setting tasks that are unreasonably below or beyond a person’s skill level denying access to information, supervision, consultation or resources such that it has a detriment to the worker spreading misinformation or malicious rumours changing work arrangements, such as rosters and leave, to deliberately inconvenience a particular worker or workers excessive scrutiny at work. This list is not exhaustive. Other types of behaviour may also constitute bullying. Single incidents can also present a risk to health and safety and will not be tolerated. One Investment Group and its workers have a responsibility to ensure workers are not exposed to bullying and must not engage in this behaviour. Bullying does not cover situations where a worker feels aggrieved about legitimate and reasonable: a) performance management processes; b) disciplinary action in line with company policy; and c) allocation of work in compliance with systems and role requirements. One Investment Group aims to respond swiftly and proactively to deal with workplace bullying. All reports will be treated seriously and dealt with promptly, impartially and as confidentially as is reasonably possible. If you think you are being harassed or bullied or both, you should not ignore the conduct, hoping it will go away. If you can, you should speak to the person responsible for the conduct and ask that person to stop. If you do not feel that you can do this, or it doesn’t work, you should talk to your Manager or the CEO. 22 April 2024 CONFIDENTIAL 37 Your Manager or the CEO may be contacted at any time to discuss any complaint or enquiry. You may approach them for general advice or to discuss any issue. They may also investigate complaints or arrange an independent person to investigate the complaints. Depending on what you want and on the nature of the complaint, it might be appropriate for OIG make a formal determination about what has happened, and to decide about what the consequences should be. Conduct which breaches this policy Conduct which breaches this policy is unacceptable and, depending on the severity and circumstances, may lead to disciplinary action. OIG will take appropriate disciplinary action against an employee who is responsible for, or engages in, any form of unlawful discrimination. Disciplinary action might include any of: a requirement to provide a written or verbal apology; a formal warning; a requirement to attend training or counselling; and dismissal, with or without notice or payment in lieu of notice. False Complaints Making an allegation of discrimination is a serious matter. Employees who knowingly or without good faith, make a false complaint will be subject to disciplinary action, including dismissal. 22 April 2024 CONFIDENTIAL 38 Grievances Purpose OIG is committed to providing a work environment that is safe, fair and free from unlawful harassment, discrimination or bullying for all employees. OIG has a responsibility under State and Federal legislation seek to ensure staff are not subjected to behaviour that may constitute unlawful discrimination, harassment, vilification or victimisation. OIG is required to take reasonable and proportionate measures to eliminate unlawful sex discrimination, including: sexual harassment, victimisation, and hostile work environments, so far as possible, and take all reasonable steps to prevent the sexual harassment. This policy should be read in conjunction with the OIG Code of Conduct and the policies on Employee Behaviour, Discrimination, Harassment & Bullying, which provide guidance on the standards of behaviour expected of staff at OIG. Guidelines All grievances will be treated seriously and sensitively, having due regard to procedural fairness, confidentiality and privacy. Requirements relating to confidentiality and privacy extend to the use and storage of any information and records related to a grievance. OIG will give reasons in writing for decisions and actions taken as part of the grievance resolution procedure if requested by the complainant and/or the respondent. Staff will be made aware of this procedure at their induction, including how to access the procedure and how to apply it. This process will be reinforced on a regular basis. While the parties to the grievance attempt to resolve the matter in accordance with this policy, work must continue as normal, other than with respect to bona fide health and safety issues, while the matter is being dealt with in accordance with this policy. In some instances, an employee may be directed not to attend work or to work from a different location, pending resolution of the grievance. The Manager will deal with complaints from staff of discrimination, bullying and/or harassment by other staff members unless it relates to them in which case it will be dealt with by the Business Unit Managing Director or their nominee. You are encouraged to approach other staff members, if you consider that other staff members are more appropriate to assist with a particular situation. Whilst this staff member can listen to the initial complaint and provide support to you, the complaint should be referred on to the appropriate manager or the CEO as soon as possible. Procedures Informal Grievance Resolution Employees are encouraged to attempt informal grievance resolution prior to resorting to a more structured process. This informal process does not require documentation. However, notes may be taken in the process. Grievances should be handled quickly and as close as possible to their source. This may be modified by the nature of the grievance and the employee’s wishes. Employees should raise concerns as early as possible after the incident/s occurred, where they are either uncomfortable seeking to resolve the matter with the person to whom the grievance relates or it is impractical to do so. Parties to the grievance should endeavour to: amicably discuss the matter; identify all perspectives of the issue at hand; and come to a mutually agreeable conclusion. If the Manager believes that the complaint may be appropriately resolved through discussion, they may attempt to resolve the compla

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