2025 Announcements

Published in Publications
Date Title

Size
16 December 2025 Central Iron Ore Rights Issue 287 KB
27 November 2025 Results of Meeting 182 KB
27 October 2025 CIO Mineral Resource Estimate 8.8 MB
27 October 2025 Quarterly Activities for period ended 30 September 2025 172 KB
27 October 2025 Quarterly Cashflow for period ended 30 September 2025 289 KB
9 October 2025 Notice of Annual General Meeting 371 KB
9 October 2025 Proxy Form 318 KB
9 October 2025 Notice and Access Letter 201 KB
22 September 2025 Full Year Statutory Accounts 4.9 MB
22 September 2025 Drilling Results Central Iron Ore 4.3 MB
29 July 2025 Quarterly Activities for period ended 30 June 2025 181 KB
29 July 2025 Quarterly Cashflow for period ended 30 June 2025 297 KB
21 July 2025 Change of Director's Interest Notice DD 259 KB
8 July 2025 Change of Director's Interest Notice DD 283 KB
4 July 2025 Change of Director's Interest Notice THR 330 KB
4 July 2025 Change in Substantial Holding THR 135 KB
2 May 2025 CIO Drilling Commences 624 KB
30 April 2025 Quarterly Cashflow for period ended 31 March 2025 288 KB
30 April 2025 Quarterly Activities for period ended 31 March 2025 173 KB
9 April 2025 Appendix 3A.1 Notification of Dividend Distribution 17 KB
4 April 2025 Maiden Dividend 200 KB
21 March 2025 CIO Mineral Resource Estimate 8.6 MB
12 March 2025 Half Year Accounts 1.3 MB
11 Mar 2025 Change of Director's Interest Notice DD 202 KB
04 Feb 2025 Appendix 3G 20 KB
29 Jan 2025 Quarterly Activities for period ended 31 December 2024 188 KB
29 Jan 2025 Quarterly Cashflow for period ended 31 December 2024 295 KB
17 Jan 2025 Press Release: Drilling Results Central Iron Ore 2.5 MB
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Annexure A – Board Skills Matrix

Published in Company Written by

Gullewa Limited

ACN 007 547 480

(Company)

Current as at 30 June 2024

Skill Requirements Overview [Weighting (High/medium/low)] Director
1 2 3
Risk & Compliance Identify key risks to the organisation related to each key area of operations. Ability to monitor risk and compliance and knowledge of legal and regulatory requirements.
Financial & Audit Experience in accounting and finance to analyse statements, assess financial viability, contribute to financial planning, oversee budgets, oversee funding arrangements.
Strategy Ability to identify and critically assess strategic opportunities and threats to the organization. Develop strategies in context to our policies and business objectives.
Policy Development Ability to identify key issues for the organisation and develop appropriate policy parameters within which the organization should operate.
Technology Knowledge of IT governance including privacy, data management and security.
Executive Management Experience in evaluating performance of senior management, and oversee strategic human capital planning. Experience in industrial relations and organizational change management programmes.
Industry Specific Skills [To be completed depending on your specific industry]
Leadership Make decisions and take necessary actions in the best interest of the organisation, and represent the organisation favourably. Analyse issues and contribute at board level to solutions.
Ethics and Integrity Understand role as director and continue to self educate on legal responsibility, ability to maintain board confidentiality, declare any conflicts.
Contribution Ability to constructively contribute to board discussions and communicate effectively with management and other directors.
Negotiation Possess excellent negotiation skills, with the ability to drive stakeholder support for board decisions.
Crisis Management Ability to constructively manage crisis, provide leadership around solutions and contribute to communications strategy with stakeholders.
Diversity Equal gender representation should be a priority as diversity leads to better board outcomes.
Previous Board Experience The board’s directors should have extensive director experience and have completed formal training in governance and risk.
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Schedule 16 – Privacy Policy

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Gullewa Limited (Company, “we”, “us”, “our”) respects your privacy. We are committed to ensuring all information we collect or hold is handled respectfully and in accordance with relevant privacy las including the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). This policy explains how and why we collect, use, hold and disclose your personal information together with your rights to access and correct that information or make a complaint about our handling of personal information.

You consent to us collecting, holding, using and disclosing your personal information in accordance with this policy.

1. What is personal information?

Personal information is any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether it is true.

2. What personal information do we collect and hold?

The Company will only collect personal information from individuals as required to conduct our business operations. This includes when individuals use our website, apply for a position, work with us, invest in us or engage with us in other ways. Generally, the types of personal information we collect will include name, contact details and records of communications with us including your history of purchases and use of our products and services and details of enquiries or complaints you make.

In addition, we collect personal information relating to:

  1. shareholders: information about the shareholding, banking details and tax file numbers for payment of dividends and other amounts; and

  2. job applicants: employment and academic histories, the names of referees and in some cases, limited health information based on testing undertaken by or for us. We will collect this information directly from organisations that provide recruitment related services to us and from third parties who provide job applicants with professional or personal references.

We may collect information about how you access, use and interact with the website. This information may include:

  1. the location from which you have come to the site and the pages you have visited; and

  2. technical data, which may include IP address, the types of devices you are using to access the website, device attributes, browser type, language and operating system.

We use cookies on the website. A cookie is a small text file that the website may place on your device to store information. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of our website for any of your future visits to the website. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on the website. You may refuse to use cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of the website.

3. Why do we collect, hold and use your personal information?

We may use personal information for the primary purpose for which it is collected (e.g. provision of our services, including administration of our services) or for secondary purposes which are related (or directly related to the case of sensitive information) to the primary purpose.

We collect, hold and use your personal information so that we can:

  1. comply with our legal obligations and assist government and law enforcement agencies or regulators;

  2. communicate with, and comply with our legal obligations to, our shareholders, and to process payments to them;

  3. enable third party service providers to produce us and our related companies with services such as information technology, auditing, legal advice, printing and mailing services, and services related to our share register;

  4. correspondence with people who have contacted us, and deal with feedback;

  5. provide services to, and manage, our related companies;

  6. consider applications from prospective employees or contractors;

  7. maintain and update our records;

  8. conduct or participate in investigations or due diligence;

  9. facilitate transactions involving the Company or any of our affiliates;

  10. manage our operations (including safety and security).

Where appropriate, we will confirm your express consent before collecting such information.

If you do not provide us with your personal information, we may not be able to provide you with our services, communicate with you or respond to your enquiries.

4. How do we collect your personal information?

We will collect your personal information directly from you whenever you interact with us.

We may collect information from third parties – for instance, information regarding shareholders is collected from our share registrar, and information about job applicants is collected in the manner set out above.

5. How do we store and hold personal information?

We store most information about you in computer systems and databases operated by either us or our external service providers.

We implement and maintain processes and security measures to protect personal information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure. Processes including taking steps to restrict access to databases, maintaining firewalls, encrypting data, using secure servers in controlled facilities and only allowing access by those entrusted with authority and computer network passwords. We also require all employees to comply with information security policies and attend training. In addition, we monitor and regularly review our practices against industry best practice.

We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs.

However, the internet is not a secure environment and no computer system is perfectly secure. Although all care is taken, we cannot guarantee the security of information provided to us. This means that there is always a risk that your personal information may be accessed or used without authorisation.

6. Who do we disclose your personal information to, and why?

We may transfer or disclose your personal information to our related companies.

We may disclose personal information to external service providers (including IT service providers, auditors, legal advisors, mail houses and our share registrar) so that they may perform services for us or on our behalf.

We may also disclose your personal information to others outside our group of companies where:

  1. we are required or authorised by law to do so;

  2. you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or

  3. we are otherwise permitted to disclose the information under the Privacy Act.

If the ownership or control of all or part of our assets or business changes, we may transfer your personal information to the prospective or new owner.

7. Do we disclose personal information to overseas recipients?

We do not disclose your personal information to recipients which are located outside Australia.

8. Do we use your personal information for marketing?

We will use your personal information to offer you products and services we believe may interest you, but we will not do so if you tell us not to.

Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.

9. Access to and correction of your personal information

You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out below. We may need to verify your identify before giving you access to your personal information. There are some circumstances in which we are not required to give you access to your personal information (for example, where a legal exemption applies).

There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).

We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate and up to date.

10. Complaints

If you have a question about our policy or wish to make a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us in writing. Our contact details are set out below.

We will consider your complaint promptly and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.

It is our intention to use our best endeavours to resolve any complaints to your satisfaction. However, if you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC) for guidance on alternative courses of action which may be available.

Office of the Australian Information Commissioner
Phone: 1300 363 992
Mail: GPO Box 5218 SYDNEY NSW 2001
Website: www.oaic.gov.au

11. Contact details

If you have any questions, comments, requests or concerns, please contact us at:

This email address is being protected from spambots. You need JavaScript enabled to view it.

12. Changes to this policy

From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website.

You may obtain a copy of our current policy from our website or by contacting us at the contact details above.

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Schedule 15 – Environmental, Social and Governance Policy

Published in Company Written by

1. Introduction

Gullewa Limited (ACN 007 547 480) (Company) is committed to the sustainable mineral development. As a responsible participant, the Company must identify, assess and report responses to environment, climate change and social challenges. The Company acknowledges that it has a role to play in protecting the natural environment, reducing global greenhouse gas emissions and to improving people’s lives now and for generations to come.

This environmental, social and governance policy (ESG Policy) regulates and provide guidance for the management of activities to minimise adverse workforce, community or environmental impacts.

The Board has delegated to the ESG committee responsibility for implementing the ESG management system.

1.1. Purpose

A strong environmental, social and governance performance is essential for the success and growth of the Company’s business. The Company’s aim is to recognise its legal and other obligations to all legitimate stakeholders from time to time where and to the extent appropriate. With the recognised obligations in mind, the Company will manage its activities in a sustainable manner with respect to our workforce, our communities and the environment.

The Company is committed to managing its activities to minimise adverse workforce, community or environmental impacts.

1.2. Governing principles

  1. General governance principles

    The Company will achieve this by:

    1. implementing a systematic approach to ESG risk management;

    2. complying with and exceeding all relevant laws and regulations and applying responsible industry standards where laws do not exist;

    3. setting, measuring and reviewing objectives and targets that will drive continuous improvement in ESG performance;

    4. embedding ESG considerations in the Company’s business planning and decision making processes;

    5. integrating ESG requirements when designing, purchasing, constructing and modifying equipment and facilities;

    6. reviewing the ESG contingency planning process to ensure high risk activities identified in the ESG risk management have appropriate contingency plans in place;

    7. maintaining a culture in which stakeholders are aware of their ESG obligations and are empowered to intervene on ESG issues;

    8. providing continued education to all stakeholders to identify and act upon opportunities to improve the ESG performance;

    9. undertaking and supporting research to gain better understanding of ESG and using scientific approach to support impact assessments and evidence based decision making;

    10. taking a collaborative and pro-active approach with our stakeholders; and

    11. requiring directors, contractors and employees to comply with our ESG expectations in a mutually beneficial manner.

  2. Environment

    In relation to the environment, the Company will:

    1. ensure that, as a minimum, all policies and procedures comply with all applicable environmental laws and regulations, assessment and approval requirements, licences and conditions;

    2. commit to operate all business unit’s sustainably by:

      1. identifying, mitigating, managing and reporting on material environmental risks and impacts associated with the business unit’s activities;

      2. planning and implementing strategies to effectively manage and reduce key environmental risks and impacts such as greenhouse gas emissions, water management and waste reduction with the focus on reducing the Company’s environmental footprint;

      3. where relevant, protecting and respecting natural systems and associated biodiversity in areas where the Company operates; and

      4. efficiently using water and energy and maximising the value of existing resources.

    3. inform employees, customers and suppliers about this Policy and require compliance with such expectations as well as considering environmental performance of potential suppliers in decision-making;

    4. strive to improve environmental performance based on defined objectives and targets for monitoring, measuring and reporting performance; and

    5. report openly, honestly and in a timely manner to stakeholders on the Company’s environmental and sustainability performance.

  3. Climate change

    The Company will:

    1. take action to appropriately identify and manage climate change risks and opportunities, consistent with the objective to sustainably deliver superior returns to shareholders;

    2. seek opportunities to better understand the life-cycle of greenhouse gas emissions (GHG);

    3. seek to increase the transparency of the Company’s climate change reporting of performance metrics and targets to meet the needs of all stakeholders including shareholders, governments, lenders, insurers, customers and communities;

    4. ensure that measuring, reporting and verification processes are robust across all operating sites;

    5. pro-actively assess options to increase the use of renewable power and lower emission energy technologies to reduce the Company’s GHG emissions intensity;

    6. focus on opportunities to improve energy efficiency to reduce energy used and reduce direct mining costs;

    7. continue to assess climate change scenarios and projected future energy prices in medium and long term analysis to ensure that the cost of carbon informs business decision; and

    8. partner with or engage experts and research organisations to identify potential physical threats of climate change at current and planned operating sites and invest in appropriate adaption responses to build resilience.

  4. Social

    The Company will:

    1. provide and maintain a safe workplace so that its employees, contractors and visitors go home safe and well;

    2. identify and manage risks, impacts and opportunities within our operations and host communities;

    3. create shared value with the Company’s stakeholders and deliver sustainable and long-term benefits in a manner that supports and respects the rights and aspirations of the communities in which the Company operates;

    4. respect and promote human rights and will not engage in or condone forced or compulsory labour or other forms of modern slavery and will work to ensure these are not present in the Company’s supply chain; and

    5. uphold ethical business practices and comply with all legal requirements in all jurisdictions in which the Company operates.

1.3. Application

Responsibility for the application of this policy rests with, but not limited to, all Company employees and contractors engaged in activities under the Company’s operational control.

Each department of the Company is responsible for the development of its own internal policies to implement the principles set out in section 1.2 above (Department Policy).

The Company’s managers are also responsible for promotion the ESG and Department Policy.

1.4. Monitoring and review

  1. Material breaches of this ESG Policy will be reported to the Company’s board of directors (Board) or a committee of the Board.

  2. The Board will monitor the content, effectiveness and implementation of this ESG Policy on a regular basis. There may also be independent reviews taken from time to time. Any findings, updates or improvements identified will be addressed as soon as possible.

  3. Personnel are invited to comment on this ESG Policy and suggest ways in which it may be improved. Comments, suggestions and queries should be addressed to the Board.

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Schedule 14 – Shareholder Communications Strategy

Published in Company Written by

The Board of the Company aims to ensure that the shareholders are informed of all major developments affecting the Company’s state of affairs.

Information is communicated to shareholders through:

  1. the Annual Report delivered by post or via email (if requested by the shareholder) and which is also released to ASX and placed on the Company’s website;

  2. the half yearly report which is released to ASX and also placed on the Company’s website;

  3. the quarterly reports which are released to ASX and also placed on the Company’s website;

  4. disclosures and announcements made to the ASX, copies of which are placed on the Company’s website;

  5. notices and explanatory statements of Annual General Meetings (AGM) and General Meetings (GM), copies of which are released to ASX and placed on the Company’s website;

  6. the Chairperson of the Board’s address and the Managing Director’s address made at the AGMs and the GMs, copies of which are released to ASX and placed on the Company’s website;

  7. the Company’s website on which the Company posts all announcements which it makes to the ASX as well as materials distributed at investor or analyst presentations; and

  8. the auditor’s lead engagement partner being present at the AGM to answer questions from shareholders about the conduct of the audit and the preparation and content of the auditor’s report.

As part of the Company’s developing investor relations program, shareholders can register with the Company to receive email notifications of when an announcement is made by the Company to the ASX, including the release of the Annual Report, half yearly reports and quarterly reports. Links are made available to the Company’s website on which all information provided to the ASX is immediately posted.

Shareholders are encouraged to participate at all GMs and AGMs of the Company. Upon the despatch of any notice of meeting to shareholders, the Company Secretary shall send out material with that notice of meeting stating that all shareholders are encouraged to participate at the meeting. The Company will ensure that appropriate technology is used to facilitate the participation of shareholders at such meetings and that meetings will be held at a reasonable time and place. Shareholders who are unable to attend meetings may ask questions or provide comments ahead of meetings.

Historical Annual Reports of the Company are provided on the Company’s website.

Shareholders queries should be referred to the Company Secretary in the first instance. Any significant comments or concerns will be conveyed to the Board and relevant senior executives.

Annexure A – Definition Of Independence

Examples of interests, positions and relationships that might raise issues about the independence of a director include if the director:

  1. is, or has been, employed in an executive capacity by the Company or any of its child entities and there has not been a period of at least three years between ceasing such employment and serving on the Board;

  2. receives performance-based remuneration (including options or performance rights), or participates in an employee incentive scheme of the Company;

  3. is, or has been within the last three years, in a material business relationship (eg as a supplier, professional adviser, consultant or customer) with the Company or any of its child entities, or is an officer of, or otherwise associated with, someone with such a relationship;

  4. is, represents, or is or has been within the last three years an officer or employee of, or professional adviser to, a substantial holder of the Company;

  5. has close personal ties with any person who falls within any of the categories described above; or

  6. has been a director of the Company for such a period that their independence from management and substantial holders may have been compromised.

In each case, the materiality of the interest, position or relationship needs to be assessed by the Board to determine whether it might interfere, or might reasonably be seen to interfere, with the director’s capacity to bring an independent judgement to bear on issues before the Board and to act in the best interests of the Company as a whole rather than in the interests of an individual shareholder or other party.

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Schedule 13 – Anti-Bribery and Anti-Corruption Policy

Published in Company Written by

1. Background

The Company is committed to conducting all of its business activities fairly, honestly with integrity, and in compliance with all applicable laws, rules and regulations. Its Board, management and employees are dedicated to high ethical standards and recognise and support the Company’s commitment to compliance with these standards.

In particular, the Company is committed to preventing any form of Corruption and Bribery and to upholding all laws relevant to these issues, including the Anti-Corruption Legislation. In order to support this commitment, the Company has adopted this Anti-Bribery and Anti-Corruption Policy (ABC Policy) to ensure that it has effective procedures in place to prevent Corruption and Bribery.

This ABC Policy applies globally. To the extent that local laws, codes of conduct or other regulations (Local Laws) in any countries are more rigorous or restrictive than this ABC Policy, those Local Laws should be followed by any subsidiary operating in that country. Where a country has specific bribery and corruption Local Laws which are less rigorous than this ABC Policy, this ABC Policy prevails. The Company may, from time to time, provide country-specific directions for subsidiaries operating in countries outside of Australia.

This ABC Policy sets out the Company’s requirements in relation to interactions with Officials and Third Parties. This ABC Policy does not prohibit interactions with Officials, rather it forbids corrupt interactions with those individuals.

2. Definitions

In this ABC Policy the following words or phrases mean the following:

Anti-Corruption Legislation includes many laws such as the Criminal Code Act 1995 (Cth) and any applicable anti-corruption laws and regulations applicable to the location in which the Company operates.

Bribery is the act of offering, promising, giving or accepting a benefit with the intention of influencing a person who is otherwise expected to act in good faith or in an impartial manner, to do or omit to do anything in the performance of their role or function, in order to provide the Company with business or a business advantage that is not legitimately due (whether in respect of an interaction with an Official or any commercial transaction in the private sector).

Business Associates means third party companies and individuals (such as joint venture partners, consultants and agents) acting on the Company’s behalf, whether directly or indirectly, by representing the Company’s interests to foreign governments in relation to international business development or retention of business opportunities.

Corruption is the abuse of entrusted power for private gain.

Facilitation Payment means payments of nominal amounts or other inducement made to persons in order to secure or expedite the performance of a Government Official’s routine governmental duties or actions.

Gifts, Entertainment and Hospitality includes the receipt or offer of presents, meals or tokens of appreciation and gratitude or invitations to events, functions, or other social gatherings, in connection with matters related to the Company’s business unless they:

  1. fall within reasonable bounds of value and occurrence;

  2. do not influence, or are not perceived to influence, objective business judgement; and

  3. are not prohibited or limited by applicable laws or applicable industry codes.

Government Official means:

  1. any politician, political party, party official or candidate of political office;

  2. any official or employee of a domestic or foreign government (whether national, state/provincial or local) or agency, department or instrumentality of any domestic or foreign government or any government-owned or controlled entity (including state-owned enterprises);

  3. any official or employee of any public international organisation;

  4. any person acting in a private or public official function or capacity for such domestic or foreign government, agency, instrumentality, entity or organisation;

  5. any person who holds or performs the duties of any appointment created by custom or convention or who otherwise acts in an official capacity (including, some indigenous or tribal leaders who are authorised and empowered to act on behalf of the relevant group of indigenous peoples and members of royal families);

  6. any person who holds themselves out to be an authorised intermediary of a government official.

Item of Value includes, amongst other things, cash, travel, meals, Gifts, Entertainment and Hospitality, other tangible or intangible benefits or anything of value.

Money-laundering means the process by which a person or entity conceals the existence of an illegal source of income and then disguises that income to make it appear legitimate.

Official means a Government Official, political party, official or officer of a political party or candidate for political office.

Personnel means all persons acting (whether authorised or unauthorised) on behalf of the Company at all levels, including officers, directors, temporary staff, contractors, consultants and employees of the Company.

Secret Commissions means offering or giving a commission to an agent or representative of another person that is not disclosed by that agent or representative to their principal to induce or influence the conduct of the principal’s business.

Secure an improper advantage includes obtaining any commercial or financial benefit.

Third Party means any individual or organisation other than Officials, with whom Personnel come into contact during the course of their employment or business relationships associated with the Company.

3. Purpose

The purpose of this ABC Policy is to:

  1. set out the responsibilities of the Company and its management and Personnel in upholding the Company’s commitment to preventing any form of Bribery or Corruption; and

  2. provide information and guidance to Personnel on how to recognise and deal with any potential Bribery and Corruption issues.

4. Scope and authority

The Company requires all Personnel to comply with this ABC Policy as well as the Anti- Corruption Legislation. The prevention, detection and reporting of Bribery and other forms of Corruption are the responsibility of all those working for the Company or under its control.

This ABC Policy applies to all Personnel, including directors, temporary staff and contractors, and Business Associates of the Company.

5. Responsibility for policy compliance and training

  1. The Company’s Board is responsible for the overall administration of this ABC Policy. The Board will monitor the implementation of this ABC Policy and will review on an ongoing basis the ABC Policy’s suitability and effectiveness. Internal control systems and procedures will be audited regularly to ensure that they are effective in minimising the risk of non-compliance with this ABC Policy.

  2. A copy of this ABC Policy will be made available to all Personnel and in such other ways as will ensure the ABC Policy is available to Personnel wishing to use it.

  3. All Personnel are required to understand and comply with this ABC Policy and to follow the reporting requirements set out in this ABC Policy. To this end, regular and appropriate training on how to comply with this ABC Policy will be provided to all senior managers and other relevant Personnel by the Board for each business. However, it is the responsibility of all Personnel to ensure that they read, understand and comply with this ABC Policy.

  4. All Business Associates are required to be made aware of this ABC Policy and to undertake to comply with this ABC Policy in relation to any of their dealings with, for or on behalf of the Company.

  5. The prevention, detection and reporting of Bribery and other improper conduct addressed by this ABC Policy are the responsibility of all those working for or engaged by the Company. All Personnel should be vigilant and immediately report any breaches or suspicious activity to the officer responsible for compliance.

6. Consequences of breaching this ABC policy

  1. Bribery and the related improper conduct addressed by this ABC Policy are very serious offences that will be taken seriously, reviewed and thoroughly investigated by the Company. Depending on the circumstances, the incident may be referred to regulatory and law enforcement agencies.

  2. A breach of this ABC Policy may also expose Personnel and the Company to criminal and/or civil penalties, substantial fines, exclusion from tendering for government or private contracts, loss of business and reputational damage.

  3. Breach of this ABC Policy by Personnel will be regarded as serious misconduct, leading to disciplinary action which may include termination of employment.

7. Policy

7.1. General

  1. Personnel must:

    1. understand and comply with this ABC Policy and attend all relevant training;

    2. not engage in Bribery or any other form of Corruption or improper conduct;

    3. not make Facilitation Payments;

    4. not offer, pay, solicit or accept Secret Commissions;

    5. not engage in Money-laundering;

    6. not give or accept Items of Value where to do so might influence, or be perceived to influence, objective business judgement or otherwise be perceived as improper in the circumstances.

    7. obtain required approvals for political contributions and charitable donations;

    8. maintain accurate records of dealings with Third Parties; and

    9. be vigilant and report any breaches of, or suspicious behavior related to, this ABC Policy.

  2. This ABC Policy does not prohibit the giving of normal and appropriate hospitality to, or receiving it from, Third Parties.

7.2. Prohibition against Bribery and Corruption

  1. The Company strictly prohibits Personnel engaging in or tolerating Bribery or any other form of Corruption or improper conduct.

  2. The Company’s corporate values require that in all aspects of business all Personnel act honestly, adhere to the highest ethical standards, and act in compliance with all relevant legal requirements. In this respect Personnel must not engage in Bribery or any other form of Corruption.

  3. The prohibition of Bribery under this ABC Policy includes the provision or conveying of an Item of Value to any Third Party, Official or family members of Officials, whether directly or indirectly, to secure any improper advantage or to obtain or retain business. This means that Personnel must not:

    1. offer, promise or give an Item of Value with the intention of influencing an Official or Third Party who is otherwise expected to act in good faith or in an impartial manner, to do or omit to do anything in the performance of their role or function, in order to provide the Company with business or an improper advantage; or

    2. authorise the payment or provision of Items of Value to any other person, if it is known, or reasonably should have been known, that any portion of that payment or Item of Value will be passed onto an Official or Third Party to secure an improper advantage or obtain or retain business; or

    3. engage, or procure, a third party to make a payment or provide an Item of Value to an Official or Third Party, (or to procure another person to make such payment or provision), in order to secure an improper advantage or obtain or retain business.

  4. The prohibition of Bribery under this ABC Policy also includes the request or acceptance of (or the agreement to accept) an Item of Value from an Official or Third Party either:

    1. intending that, in consequence, a function or activity should be performed improperly (whether by the requestor/acceptor or another person); or

    2. where the request, agreement or acceptance itself constitutes the recipient’s improper performance of a function or activity; or

    3. as a reward for the improper performance of a function or activity (whether by the recipient or another person).

7.3. Prohibition on Facilitation Payments, Secret Commissions and

Money-laundering

  1. The Company does not condone the making of Facilitation Payments, Secret Commissions and Money Laundering.

  2. Personnel are prohibited from:

    1. making Facilitation Payments;

    2. offering, paying, soliciting or receiving Secret Commissions; and

    3. engaging in Money-laundering.

7.4. Political Contributions and Charitable Donations

  1. Political Contributions

    The Company prohibits Personnel from making political contributions to Officials on behalf of the Company. Any donations above a level determined in Federal legislation must be disclosed annually to the Australian Electoral Commission and will be published on its website.

    This ABC Policy does not seek to curtail an individual’s freedom to make political contributions in their personal capacity.

    The context of any other political contributions is key in determining their appropriateness. For instance, it is permissible for the Company to make a payment to attend a political function in circumstances where such payment could not be construed as an attempt to influence the political party.

    If you are in any doubt as to the appropriateness of any political contribution, you should consult the Board before it is given or accepted or otherwise as soon as possible.

  2. Charitable Donations

    The Company can only make charitable donations that are legal and ethical under Local Laws and practices. In order to ensure that donations made by the Company to charitable organisations are for proper charitable purposes, Personnel must only make donations on behalf of the Company to charitable organisations previously approved by the Company and within approved financial limits.

    A list of approved charitable organisations is to be maintained by the Board and provided upon request.

7.5. Interactions with Officials and Third Parties must be Compliant

  1. All interactions with Officials, Third Parties and Business Associates must comply with this ABC Policy, and the Company and Personnel must not take any actions, whether direct or indirect, which create the appearance of impropriety regardless of whether there is any improper intent behind their actions.

  2. The prohibitions under this ABC Policy include a prohibition on Personnel using personal funds to undertake any interaction or transaction that is prohibited under this ABC Policy.

7.6. Documentation and Recordkeeping

  1. As part of the Company’s commitment to open and honest business practice the Company requires all of its businesses to maintain accurate books of account and records.

  2. The Company and its subsidiaries must keep accurate and complete records of all business transactions:

    1. in accordance with generally accepted accounting principles and practices;

    2. in accordance with the Company’s accounting and finance policies; and

    3. in a manner that reasonably reflects the underlying transactions and events.

  3. It is the responsibility of all Personnel to ensure that all business transactions are recorded honestly and accurately and that any errors or falsification of documents are promptly reported to the appropriate member of the senior management team of the relevant business, and corrected. No accounts are to be kept “off the books” to facilitate or conceal improper payments.

7.7. Compliance with Local Laws Required

If Local Laws in a particular country or region are more restrictive than this ABC Policy, then any Personnel, including any Business Associates operating in that country or region must fully comply with the more restrictive requirements.

7.8. Reporting Violations and Suspected Misconduct

  1. Any Personnel or stakeholder who believes that a violation of this ABC Policy or any laws has been committed, is being committed, or is being planned, should report the matter immediately to the Board.

  2. If anyone is unsure whether a particular act constitutes Bribery, a Facilitation Payment, Secret Commission, Money-laundering or an improper Item of Value, or has any other queries, they should ask the Board.

7.9. Protection

  1. The Company prohibits retaliation against anyone reporting such suspicions.

  2. Personnel who wish to raise a concern or report another’s wrongdoing, or who have refused pressure to either accept or offer a bribe, should not be worried about possible repercussions. The Company encourages openness and will support any Personnel who raises genuine concerns in good faith under this ABC Policy.

  3. If you are not comfortable, for any reason, with speaking directly to the Board, the Company has a Whistleblower Protection Policy which affords certain protections against reprisal, harassment or demotion for making the report.

8. Monitoring and Review

  1. Material breaches of this ABC Policy will be reported to the Board or a committee of the Board.

  2. The Board will monitor the content, effectiveness and implementation of this ABC Policy on a regular basis. There may also be independent reviews taken from time to time. Any findings, updates or improvements identified will be addressed as soon as possible.

  3. Personnel are invited to comment on this ABC Policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Board.

Appendix – Items Of Value Register

1. Definitions

Gifts, Entertainment and Hospitality includes the receipt or offer of presents, meals or tokens of appreciation and gratitude or invitations to events, functions, or other social gatherings, in connection with matters related to the Company’s business unless they:

  1. fall within reasonable bounds of value and occurrence;

  2. do not influence, or are not perceived to influence, objective business judgement; and

  3. are not prohibited or limited by applicable laws or applicable industry codes.

Item of Value includes, amongst other things, cash, travel, meals, Gifts, Entertainment and Hospitality and other tangible or intangible benefits or anything of value.

2. Completing the Items of Value Register

The following information is required in completing the Items of Value Register:

Receiving Items Of Value

Date Received

Name, Position & Business Unit of Recipient

Name of Giver (Who is giving you the gift / entertainment)

Description of gift / entertainment

Value $

Reason for acceptance

Decision on what will happen to gift / entertainment

Name and Position of Approving Manager (e.g. GM)
Offering Items Of Value

Date Offered

Name, Position & Business Unit of Offeror

Name of Receiver (Who are you offering the gift / entertainment too)

Description of gift / entertainment

Value $

Reason for offering

Decision on what will happen to gift / entertainment

Name and Position of Approving Manager (e.g. GM)
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Schedule 12 – Whistleblower Protection Policy

Published in Company Written by

1. Background and Purpose

Gullewa Limited (ACN 007 547 480) (Company) is committed to conducting all of its business activities fairly, honestly with integrity, and in compliance with all applicable laws, rules and regulations. Its board of directors (Board), management and employees are dedicated to high ethical standards and recognise and support the Company’s commitment to compliance with these standards.

The Company has adopted this Whistleblower Policy to:

  1. encourage and support people to feel confident to speak up safely and securely if they become aware of wrong-doing or illegal or improper conduct within the Company;

  2. provide information and guidance on how to report such conduct, how reports will be handled and investigated in a timely manner and the support and protections available if a report is made;

  3. set out the responsibilities of the Company and its management in upholding the Company’s commitment to reporting any illegal, unethical or improper conduct; and

  4. promote ethical behaviour and a culture of speaking up to deter wrong-doing.

2. Definitions

In this Whistleblower Policy the following words or phrases mean the following:

AFP means the Australian Federal Police.

APRA means the Australian Prudential Regulation Authority.

ASIC means the Australian Securities and Investments Commission.

Commissioner means the Commissioner of Taxation.

Corporations Act means the Corporations Act 2001 (Cth).

Discloser means a person disclosing a Reportable Matter under this Whistleblower Policy and includes an individual who is, or has been, one of the following in relation to the entity:

  1. an officer or employee of the Company (and includes current and former employees who are permanent, part-time, fixed term or temporary, interns, secondees, managers and directors);

  2. a supplier of services or goods to the entity (whether paid or unpaid), including their employees (and includes current and former contractors, consultants, service providers and business partners);

  3. an associate of the Company,

or a relative or dependant of one of the above (or of their spouse).

Personnel means all persons (whether authorised or unauthorised) acting on behalf of the Company at all levels, including officers, directors, temporary staff, contractors, consultants and employees of the Company, as the context requires.

Recipient has the meaning set out in clause 6.2(a).

Reportable Matter has the meaning set out in clause 6.1.

Taxation Act means the Taxation Administration Act 1953 (Cth).

3. Who the whistleblower policy applies to

  1. The Company requires all Personnel to comply with this Whistleblower Policy and any applicable whistleblower laws and regulations, including the provisions under the Corporations Act and Taxation Act.

  2. The Whistleblower Policy applies to all Disclosers of Reportable Matters. However, additional disclosures may be protected under other legislation.

  3. This Whistleblower Policy applies globally. To the extent that laws and regulations in any country are more rigorous or restrictive than this Whistleblower Policy, those laws and regulations should be followed by any subsidiary operating in that country. Where a country has specific whistleblower laws which are less rigorous than this Whistleblower Policy, this Whistleblower Policy prevails. The Company may, from time to time, provide country-specific directions for subsidiaries operating in countries outside of Australia.

4. Responsibility for compliance and training

  1. The Company’s Board is responsible for the overall administration of this Whistleblower Policy. The Board will monitor the implementation of this Whistleblower Policy and will review on an ongoing basis its suitability and effectiveness. Internal control systems and procedures will be audited regularly to ensure that they are effective in minimising the risk of non-compliance with this Whistleblower Policy.

  2. The Board may appoint a Whistleblower Protection Officer who will be responsible for:

    1. protecting Disclosers and applying this Whistleblower Policy;

    2. monitoring the effectiveness of relevant policies and reporting to the Board accordingly; and

    3. ensuring compliance with whistleblower training and programs.

  3. A copy of this Whistleblower Policy will be made available on the Company’s website and intranet and in such other ways as will ensure the Whistleblower Policy is available to those wishing to use it.

  4. All Personnel are required to understand and comply with this Whistleblower Policy and to follow the reporting requirements set out in this Whistleblower Policy. To this end, regular and appropriate training on how to comply with this Whistleblower Policy will be provided to all Personnel (including recipients and potential investigators and those with specific responsibility under this Whistleblower Policy) to ensure everyone is aware of their rights and obligations under this Whistleblower Policy and under applicable whistleblower laws. However, it is the responsibility of all Personnel to ensure that they read, understand and comply with this Whistleblower Policy.

5. Consequences of breaching this Whistleblower Policy

  1. A breach of this Whistleblower Policy may expose Personnel and the Company to damage, including but not limited to criminal and/or civil penalties, substantial fines, loss of business and reputational damage.

  2. A breach of this Whistleblower Policy by Personnel will be regarded as a serious misconduct, leading to disciplinary action which may include termination of employment.

6. Whistleblower Policy

6.1. Reportable Matters

Personnel are encouraged to speak up and report Reportable Matters under this Whistleblower Policy to a Recipient listed in clause 6.2(a).

What Are Reportable Matters?

Reportable Matters involve any actual or suspected misconduct or an improper state of affairs in relation to the Company or a related body corporate or an officer or employee of the Company.

You must have reasonable grounds for reporting such conduct but you should speak up even if you are unsure if something is a Reportable Matter.

Reportable Matters may or may not include a breach of law or information that indicates a danger to the public or to the financial system.

Examples of Reportable Matters include, but are not limited to, conduct which:

  1. is dishonest, fraudulent, corrupt or involves bribery or any other activity in breach of the Company’s Anti-Bribery and Anti-Corruption Policy;

  2. is illegal (such as theft, dealing in or use of illicit drugs, violence or threatened violence and criminal damage to property) or involves criminal conduct or other breaches of law or regulatory requirements;

  3. is unethical or breaches any of the Company’s policies, charters or Code of Conduct;

  4. is potentially harmful or damaging to the Company, an employee or person, such as unsafe work practices, environmental damage or substantial wasting of Company resources;

  5. may cause financial loss or damage in any way to the Company’s reputation or be otherwise detrimental to the Company’s interest;

  6. involves actual or threatened harassment (including sexual harassment), discrimination, victimisation or bullying, or any other type of detrimental action (other than disclosures that solely relate to personal work-related grievances as defined in the Corporations Act); or

  7. amounts to an abuse of authority.
What Conduct Is Not Covered?

Reportable Matters do not generally include personal work-related grievances.

Personal work-related grievances are those that relate to current or former employment and have, or tend to have, implications for the Discloser personally but do not have any other significant implications for the Company (or any other entity) or do not relate to conduct or alleged conduct, about a Reportable Matter.

Personnel can discuss personal work-related grievances with the Company Secretary. Alternatively, Personnel may wish to seek legal advice about their rights and protections under employment law and ways to resolve personal work-related grievances.

However, in some cases, these grievances may qualify for legal protection (See Annexure 1).

Examples of personal work-related grievances include:

  1. an interpersonal conflict between the Discloser and another employee; and

  2. a decision that does not involve a breach of workplace laws;

  3. a decision concerning the engagement, transfer or promotion of the Discloser;

  4. a decision concerning the terms and conditions of engagement of the Discloser; or

  5. a decision to suspend or terminate the engagement of the Discloser, or otherwise to discipline the Discloser.

6.2. Making a Report

  1. Who to report to?

    The Company encourages reports of Reportable Matters to be made to any of the following recipients (as appropriate in the circumstances) (Recipients):

    1. any member of the Board; or

    2. the Company Secretary;

    The Company recognises that there may be issues of sensitivity whereby a Discloser does not feel comfortable to make a report to an internal recipient. In such cases, the Discloser may feel more comfortable making an anonymous disclosure to an external recipient.

    Nothing in this Whistleblower Policy (including anonymous reporting) should be taken in any way as restricting someone from reporting any matter or providing any information to a regulator (such as ASIC, the APRA, Commissioner), the Company’s auditor or a member of the audit team, a lawyer (to obtain advice or representation) or any other person in accordance with any relevant law, regulation or other requirement. Information in relation to whistleblowing is available from such regulators and can generally be downloaded on their website.

  2. Anonymous reports

    The Company also appreciates that speaking up can be difficult. Reports can be made anonymously or using a pseudonym and still be protected. A Discloser can refuse to answer questions that could reveal their identity. While reports can be made anonymously, it may affect the ability to investigate the matter properly and to communicate with the Discloser about the report. Anonymous Disclosers should therefore attempt to maintain two-way communication as far as possible.

    Anonymous reports can be made by email. Alternatively, you may consider sending an anonymous email using a temporary or disposable email address available from the internet.

  3. Information to include in the report

    As much information should be included in the report as possible including details of the Reportable Matter, people involved, dates, locations and whether more evidence may exist.

    Disclosers will be expected to have reasonable grounds to believe the information being disclosed is true (which will be based on the objective reasonableness of the reasons for the Discloser’s suspicions) but the Discloser will not be penalised and may still qualify for protection if the information turns out to be incorrect should they have such reasonable grounds. However, any deliberate false reporting will not qualify for protection under this Whistleblower Policy and will be treated as a serious matter and may be subject to disciplinary action.

  4. Questions

    Personnel who are unsure about how this Whistleblower Policy works, what is covered by the Whistleblower Policy or how a disclosure may be handled are encouraged to speak with the Company Secretary in the first instance.

6.3. Investigating a Report

  1. Who will investigate?

    An appropriate investigator (or investigators) may be appointed to investigate any reports made under this Whistleblower Policy. An investigator will be independent of the Discloser and individuals who are the subject of the disclosure and the department or business unit involved. Possible investigators include:

    1. any member of the Board; or

    2. the Company Secretary.

    Where a Reportable Matter relates to the managing director, or a director of the Company, the matter will be referred directly to the Company Secretary.

  2. How will the investigation be conducted?

    Any matters reported under this Whistleblower Policy will be considered and a determination will be made as to whether the disclosure falls within the scope of this Whistleblower Policy. If so, the matter will be investigated as soon as practicable after the matter has been reported. The investigation process will be conducted in a thorough, fair, objective and independent manner (while preserving confidentiality) and will depend on the precise nature of the conduct being investigated. Due care and appropriate speed will be taken and reported information will be verified and relevant personnel interviewed as part of the investigative process. The Company may seek independent advice as necessary.

    The Discloser may be asked for further information, will be given regular and appropriate updates in the circumstances and will be advised of any outcomes from the investigation (subject to considerations of privacy and confidentiality). Any updates or outcomes will be advised by reasonable means.

    Anonymous reports will be investigated based on the information provided and may be limited if the Discloser has refused or omitted to provide contact details.

    At the end of the investigation, the relevant investigating officer will report their findings to the Chairperson of the Board who will determine the appropriate response. This may include rectifying any unacceptable conduct and taking any action required to prevent future occurrences of the same or similar conduct as well as disciplinary action if necessary. The identity of the Discloser will be redacted from any written investigation reports unless they have consented to disclosure of their identity.

    The Discloser may lodge a complaint with a regulator if they are not happy with an outcome of the investigation or if they consider that this Whistleblower Policy has not been adhered to adequately.

6.4. Support and Protections

  1. Identity Protection (Confidentiality) for Disclosers

    The identity of and information likely to lead to the identification of a Discloser will be kept confidential, however a disclosure can be made:

    1. if the Discloser consents;

    2. to ASIC, APRA, the Commissioner or a member of the AFP;

    3. to a lawyer for the purpose of obtaining legal advice or representation; or

    4. if the disclosure is allowed or required by law.

    During the course of an investigation, the Company will take reasonable steps to reduce the risk of disclosing information that could identify the Discloser (including redacting all personal information or references to the Discloser, restricting the number of people involved in handling and investigating the disclosure and ensuring secure and confidential email communication in relation to the investigation). Note however, that in practice, people may be able to guess the Discloser’s identity if the Discloser has mentioned their intention to make a disclosure; the Discloser is one of a very small number of people with access to the information; or the disclosure relates to information that a Discloser has previously been told privately and in confidence.

    Unauthorised disclosure of:

    1. the identity of a Discloser who has made a report of a Reportable Matter; or

    2. information from which the identity of the Discloser could be inferred,

    may be an offence under Australian law, will be regarded as a disciplinary matter and will be dealt with in accordance with the Company’s disciplinary procedures.

    A Discloser may lodge a complaint about a breach of confidentiality with the Company or a regulator.

  2. Protection from detriment for Disclosers

    A Discloser who makes a report under this Whistleblower Policy shall not suffer detriment (either actual or threatened). Examples of actual or threatened detriment include:

    1. harassment (including sexual harassment), intimidation, victimisation, bias or discrimination;

    2. dismissal of an employee or varying an employee’s position or duties;

    3. causing physical or psychological harm or injury; or

    4. damage to a person’s property, reputation, business or financial position or any other damage.

    Certain actions will not constitute detrimental conduct such as:

    1. administrative action that is reasonable for the purpose of protecting a Discloser from detriment (eg moving a Discloser who has made a disclosure about their immediate work area to another area to prevent them from detriment); and

    2. managing a Discloser’s unsatisfactory work performance, if the action is in line with the Company’s performance management framework.

    The Company will take all steps to protect Disclosers from any form of detrimental treatment and may ensure that a risk assessment is carried out to determine the risk of detriment.

    Anyone who retaliates against someone who has reported a possible violation may be subject to discipline by the Company or penalties under the Corporations Act, Taxation Act or other Australian law.

    Anyone who is subjected to detriment as a result of making a report under this Whistleblower Policy should report it in accordance with clause 6.2.

    A Discloser (or any other employee or person) can seek compensation or other remedies through the courts if:

    1. they suffer loss, damage or injury because of a disclosure; and

    2. the Company failed to prevent a person from causing the detriment.

    A Discloser may seek independent legal advice or contact a regulatory body if they believe they have suffered detriment.

  3. Fair treatment of those mentioned in a disclosure

    The Company will ensure fair treatment of officers and employees of the Company who are mentioned in any disclosure, and to whom any disclosures relate. The disclosure will be handled confidentially and will be assessed and may be subject to investigation. If an investigation is required, it will be conducted in an objective, fair and independent manner. Such employees will be advised of the subject matter of the disclosure at the appropriate time and as required by law and will be advised of the outcome of the investigation. An employee who is the subject of a disclosure may contact the Company’s support services.

  4. Files and Records

    The Company will ensure that any records relating to any reports made under this Whistleblower Policy are stored securely and only accessed by authorised personnel directly involved in managing and investigating the report. All those involved in handling and investigating reports will be reminded about confidentiality requirements including that an unauthorised disclosure of a Discloser’s identity may be a criminal offence.

  5. Special legal protections under the Corporations Act and the Taxation Act

Whilst this Whistleblower Policy deals with internal disclosures of information, additional legal protections are available for certain Disclosers under the Corporations Act and the Taxation Act provided the disclosure is about a “disclosable matter” or “tax affair” as defined under such legislation and certain conditions are met. These are summarised in Annexures 1 and 2 respectively. Disclosures that are not about “disclosable matters” or “tax affairs” will not qualify for protection under the Corporations Act or Taxation Act. For more information, see the information available on the ASIC website and the ATO website.

7. Monitoring and Review

  1. Material incidences reported under this Whistleblower Policy will be reported to the Board or a committee of the Board.

  2. The Board will monitor the content, effectiveness and implementation of this Whistleblower Policy on a regular basis. There may also be independent reviews taken from time to time. Any findings, updates or improvements identified will be addressed as soon as possible and circulated to all officers and employees

  3. Officers and employees are invited to comment on this Whistleblower Policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Board.

Annexure 1 – Summary Of Protections Under The Corporations Act

The Corporations Act sets out disclosures that are protected under the Corporations Act if certain conditions are met as well as the protections available to protected disclosures. A summary of such protections (as at the date of this policy) is set out below but you should refer to the Corporations Act itself for a full understanding of the conditions and protections available and the relevant definitions. You can also visit the ASIC website for more information.

1. Protected Disclosures

Disclosures will be protected if:

  1. the discloser is an Eligible Whistleblower, being an individual who is, or has been, any of the following:

    1. an officer or employee of the Company (eg current and former employees who are permanent, part-time, fixed-term or temporary, interns, secondees, managers and directors);

    2. an individual who supplies services or goods to the Company (whether paid or unpaid) or an employee of a person that supplies goods or services to the Company (eg current and former contractors, consultants, service providers and business partners);

    3. an associate of the Company;

    4. a relative, dependant or dependant of the spouse of any individual referred to at (i) to (iii) above; or

    5. any prescribed individual under the Corporations Act;

  2. and the disclosure is made to:

    1. the ASIC, APRA or a prescribed Commonwealth authority; or

    2. an Eligible Recipient, being:

      1. an officer or senior manager of the Company or a related body corporate of the Company;

      2. an auditor (or a member of the audit team) of the Company or a related body corporate of the Company;

      3. an actuary of the Company or a related body corporate of the Company;

      4. a person authorised by the Company to receive disclosures that qualify for protection under the Corporations Act;

      5. anyone prescribed under the regulations as being an eligible recipient; or

    3. a legal practitioner for the purposes of obtaining legal advice or legal representation in relation to the whistleblower provisions in the Corporations Act (even in the event such legal practitioner concludes that a disclosure does not relate to a disclosable matter under the Corporations Act);

  3. and the disclosure relates to a Disclosable Matter in that the discloser has reasonable grounds to suspect that the information concerns misconduct, or an improper state of affairs or circumstances in relation to the Company or a related body corporate of the Company. This includes any suspicion that the Company or its body corporate, or an officer or employee of the Company or its body corporate has engaged in conduct that:

    1. constitutes an offence against, or a contravention of, a provision of the Corporations Act, the Australian Securities Investments Commission Act 2001, the Banking Act 1959, the Financial Sector (Collection of Data) Act 2001, the Insurance Act 1973, the Life Insurance Act 1995, the National Consumer Credit Protection Act 2009, the Superannuation Industry (Supervision) Act 1993, or an instrument made under any such Act; or

    2. constitutes an offence against any other law of the Commonwealth of Australia that is punishable by imprisonment for a period of 12 months or more; or

    3. represents a danger to the public or the financial system; or

    4. is prescribed by regulation.

    (Note that the term “misconduct” is defined in the Corporations Act to include fraud, negligence, default, breach of trust and breach of duty.)

  4. Public interest and Emergency Disclosures

    Emergency or public interest disclosures (as defined under the Corporations Act) will also be protected if made to Journalists or Parliamentarians (each as defined in the Corporations Act) in extreme cases (excluding tax matters) in circumstances where at least 90 days have passed since an earlier protected disclosure has been made to ASIC, APRA or another Commonwealth body without reasonable steps having been taken to address the misconduct, or there will be substantial and imminent danger to someone’s health or safety. Note that before such public interest disclosure is made, the discloser must have given written notice to the relevant regulatory body. Such notice must include sufficient information to identify the previous disclosure and must state that the discloser intends to make the public disclosure if appropriate steps are not taken.

    Disclosers are advised to contact the Company Secretary or an independent legal adviser to ensure they understand the criteria for making an emergency or public interest disclosure that qualifies for protection.

  5. Personal work-related grievances

    Personal work-related grievances (as defined in the Corporations Act) will not be protected to the extent that the information disclosed does not concern a contravention, or an alleged contravention, of the prohibition on victimisation under the Corporations Act that involves detriment caused to the discloser or a threat made to the discloser.

    However, a personal work-related grievance will still qualify for protection if:

    1. it includes information about misconduct, or information about misconduct includes or is accompanied by a personal work-related grievance (mixed report);

    2. the Company has breached employment or other laws punishable by imprisonment for a period of 12 months or more, engaged in conduct that represents a danger to the public, or the disclosure relates to information that suggests misconduct beyond the Discloser’s personal circumstances;

    3. the Discloser suffers from or is threatened with detriment for making the disclosure; or

    4. the Discloser seeks legal advice or legal representation about the operation of the whistleblower protections under the Corporations Act.

2. Protections Available

  1. Protected disclosures will be given the following protections under the Corporations Act

    Protected disclosures not actionable

    1. the discloser will not be subject to any civil, criminal or administrative liability (including disciplinary action) for making the disclosure; and

    2. no contractual or other remedy may be enforced, and no contractual or other right may be exercised against the discloser on the basis of the disclosure; and

    3. if the disclosure qualified for protection under the Corporations Act (including public interest and emergency disclosure), the information is not admissible as evidence against the discloser in criminal proceedings for the imposition of a penalty, other than proceedings in respect of the falsity of the information;

    Victimisation Prohibited

    Anyone who causes or threatens to cause detriment (as defined in the Corporations Act) to a discloser or another person in the belief or suspicion that a report has been made, or may have been made, proposes to or could be made, may be guilty of an offence and may be liable for damages or subject to a court order. Examples of possible court orders include, but are not limited to:

    1. requiring compensation for loss or damage;

    2. an injunction to prevent, stop or remedy the effects of detrimental conduct;

    3. an order requiring an apology for engaging in detrimental conduct;

    4. if the detrimental conduct wholly or partly resulted in the termination of an employee’s employment, reinstatement of their position; and

    5. any other order the court thinks appropriate.

    Identifying information not to be disclosed

    Subject to applicable laws:

    1. a discloser’s identity cannot be disclosed to a Court or tribunal except where considered necessary; and

    2. the person receiving the report commits an offence if they disclose the substance of the report or the discloser’s identity, without the discloser’s consent, to anyone except an authorised disclosure to ASIC, APRA, the AFP or a lawyer for the purposes of obtaining legal advice or representation in relation to the report.

    Costs of proceedings

    A discloser may not need to pay costs of legal proceedings unless they have acted vexatiously or without reasonable cause and the unreasonable act caused the other party to incur the costs.

  2. Confidentiality

    In relation to a protected disclosure, the identity of a discloser (and any information likely to lead to the identification of a discloser) must be kept confidential unless expressly authorised in writing.

    A disclosure of the discloser’s identity will be authorised if made:

    1. to ASIC, APRA or a member of the AFP;

    2. to a legal practitioner for the purposes of obtaining legal advice or legal representation in relation to the whistleblower provisions in the Corporations Act;

    3. to a person prescribed by the regulations of the Corporations Act for this purpose;

    4. with the express written consent of the discloser; or

    5. by ASIC, APRA or a member of the AFP to a Commonwealth or State or Territory authority for the purpose of assisting the authority in the performance of its functions or duties.

    However, such confidentiality does not apply where the disclosure is not of the identity of the discloser and is reasonably necessary for the purposes of investigating a matter and all reasonable steps have been taken to reduce the risk that the discloser will be identified.

  3. Timing

    A discloser will qualify for protection from the time they make their disclosure, regardless of whether, at this time, the discloser or recipient recognises that the disclosure qualifies for protection.

  4. No immunity from misconduct

    Note that the protections do not grant immunity for any misconduct a discloser has engaged in that is revealed in their disclosure.

Annexure 2 – Summary Of Protections Under The Taxation Administration Act

The Taxation Act sets out disclosures that are protected under the Taxation Administration Act if certain conditions are met as well as protections available to protected disclosures. A summary of such protections (as at the date of this policy) is set out below but you should refer to the Taxation Administration Act itself for a full understanding of the conditions and protections available and the relevant definitions. You can also visit the ATO website for more information.

1. Protected Disclosures

Disclosures will be protected if:

  1. the discloser is an Eligible Whistleblower, being an individual who is, or has been, any of the following:

    1. an officer (within the meaning of the Corporations Act) or employee of the Company;

    2. an individual who supplies services or goods to the Company (whether paid or unpaid) or an employee of a person that supplies goods or services to the Company;

    3. an associate (within the meaning of the Income Tax Assessment Act 1936) of the Company;

    4. a spouse, child or dependant of any individual referred to in (i) to (iii) above or of such an individual’s spouse; or

    5. any prescribed individual under the regulations under the Taxation Act;

  2. and the disclosure is made to:

    1. the Commissioner and the discloser consider that the information may assist the Commissioner to perform his or her functions or duties under a taxation law in relation to the Company or an associate of the Company; or

    2. an Eligible Recipient, being:

      1. a director, secretary or senior manager of the Company;

      2. an employee or officer of the Company who has functions or duties that relate to the tax affairs (within the meaning of the Taxation Act) of the Company;

      3. the Company’s auditor (or a member of that audit team);

      4. a registered tax agent or BAS agent (within the meaning of the Tax Agent Services Act 2009) who provides tax agent services or BAS services to the Company;

      5. a person authorised by the Company to receive disclosures that qualify for protection under the Taxation Act; or

      6. anyone prescribed under the Taxation Act regulations as being an Eligible Recipient;

      and the discloser has reasonable grounds to suspect that the information indicates misconduct, or an improper state of affairs or circumstances, in relation to the tax affairs of the Company or an associate of the Company (“tax affairs” means affairs relating to any tax imposed by or under, or assessed or collected under, a law administered by the Commissioner);

      and the discloser considers that the information may assist the Eligible Recipient to perform functions or duties in relation to the tax affairs of the Company or an associate of the Company; or

    3. a legal practitioner for the purposes of obtaining legal advice or legal representation in relation to the whistleblower provisions in the Taxation Act.

2. Protections Available

  1. Protected Disclosures will be given the following protections under the Taxation Act

    Protected disclosures not actionable

    1. the discloser will not be subject to any civil, criminal or administrative liability (including disciplinary action) for making the disclosure;

    2. no contractual or other remedy may be enforced, and no contractual or other right may be exercised against the discloser on the basis of the disclosure; and

    3. if the disclosure was a disclosure of information to the Commissioner, the information is not admissible as evidence against the discloser in criminal proceedings for the imposition of a penalty, other than proceedings in respect of the falsity of the information;

    (Note that in relation to (i) to (iii) above, the discloser has qualified privilege in respect of the disclosure and a contract to which the person is a party may not be terminated on the basis that the disclosure constitutes a breach of the contract.)

    Victimisation prohibited

    Anyone who causes or threatens to cause detriment (as defined in the Taxation Act) to a discloser or another person in the belief or suspicion that a report has been made, or may have been made, proposes to or could be made, may be guilty of an offence and may be liable for damages or subject to a court order. Examples of possible court orders include, but are not limited to:

    1. requiring compensation for loss or damage;

    2. an injunction to prevent, stop or remedy the effects of detrimental conduct;

    3. an order requiring an apology for engaging in detrimental conduct;

    4. if the detrimental conduct wholly or partly resulted in the termination of an employee’s employment, reinstatement of their position; and

    5. any other order the court thinks appropriate

    Identifying information not to be disclosed

    1. a discloser’s identity (or information likely to lead to the identity of the discloser) cannot be disclosed to a Court or tribunal except where considered necessary; and

    2. the person receiving the report commits an offence if they disclose the substance of the report or the discloser’s identity, without the discloser’s consent, to anyone except the Commissioner, the AFP or a lawyer for the purposes of obtaining legal advice or representation in relation to the report.

    Costs of proceedings

    A discloser may not need to pay the costs of legal proceedings unless they have acted vexatiously or without reasonable cause and the unreasonable act caused the other party to incur the costs.

  2. Confidentiality

    In relation to a protected disclosure, the identity of a discloser (and any information likely to lead to the identification of a discloser) must be kept confidential unless authorised.

    A disclosure of the discloser’s identity will be authorised if made:

    1. to the Commissioner or a member of the AFP;

    2. to a legal practitioner for the purposes of obtaining legal advice or legal representation in relation to the whistleblower provisions in the Taxation Act;

    3. to a person prescribed by the regulations of the Taxation Act for this purpose; or

    4. with the express written consent of the discloser.

    However, such confidentiality does not apply where the disclosure is not of the identity of the discloser and is reasonably necessary for the purposes of investigating a matter and all reasonable steps have been taken to reduce the risk that the discloser will be identified.

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2024 Announcements

Published in Publications
Date Title

Size
20 Dec 2024 Appendix 2A 20 KB
20 Dec 2024 Change of Director's Interest Notice DD 208 KB
19 Dec 2024 Appendix 4G 361 KB
19 Dec 2024 Change of Auditor 132 KB
2 Dec 2024 Change of Director's Interest Notice KHR 244 KB
2 Dec 2024 Appendix 3G 22 KB
28 Nov 2024 Results of Meeting 129 KB
11 Nov 2024

Appendix 2A

 20 KB

31 Oct 2024

Share Buyback Completed

 96 KB

31 Oct 2024

Appendix 3H

 16 KB

30 Oct 2024

Amended Notice of Annual General Meeting

 557 KB

28 Oct 2024

Notice and Access Letter

 148 KB

28 Oct 2024

Proxy Form

 303 KB

28 Oct 2024

Notice of Annual General Meeting

 413 KB

16 Oct 2024

Quarterly Activities for period ended 30 September 2024

 148 KB

16 Oct 2024

Quarterly Cashflow for period ended 30 September 2024

 247 KB

16 Oct 2024

Response to ASX 3Y Query

 620 KB

11 Oct 2024

Change in Substantial Holding THR

 79 KB

11 Oct 2024

Change of Director's Interest Notice THR

 230 KB

11 Oct 2024

Appendix 2A

 19 KB
02 Oct 2024  Share Holding In Central Iron Ore Increased 160 KB
30 Sept 2024 Full Year Statutory Accounts 2.7 MB 
30 Sept 2024 Reinstatement to Quotation 92 KB 
30 Sept 2024 Drilling Result Central Iron Ore 2.6 MB 
23 Sept 2024 Suspension from Quotation 408 KB
20 Sept 2024 Request for Trading Halt 322 KB
20 Sept 2024 Trading Halt 426 KB
20 Sept 2024 Pause in Trading 118 KB
13 Sept 2024 Disclosure Document - Minimum Holding Share Buy-Back 713 KB
23 July 2024 Quarterly Activities for period ended 30 June 2024 227 KB
23 July 2024 Quarterly Cashflow for period ended 30 June 2024 305 KB
26 June 2024 Appendix 3G 22 KB
19 April 2024 Quarterly Activities for period ended 31 March 2024 950 KB

19 April 2024

 Quarterly Cashflow for period ended 31 March 2024 211 KB

7 March 2024

 Half Yearly Accounts 1.1 MB
30 Jan 2024 Quarterly Activities for period ended 31 December 2023 214 KB
30 Jan 2024 Quarterly Cashflow for period ended 31 December 2023 213 KB
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2019 Announcements

Published in Publications
Date Title

Size
12 Dec 2019 Appendix 3B 272 KB
12 Dec 2019 Results of Meeting 217 KB
1 Nov 2019 Quarterly Activities 30 September 2019 180 KB
31 Oct 2019 Proxy Form 263 KB
31 Oct 2019 Notice of Annual General Meeting 559 KB
31 Oct 2019 Quarterly Cashflow 30 September 2019 180 KB
10 Sept 2019 Annual Report 1.4 MB
20 Aug 2019 Change in Substantial Holding Aliton 119 KB
30 July 2019 Quarterly Cashflow 30 June 2019 191 KB
30 July 2019 Quarterly Activities 30 June 2019 295 KB
5 June 2019 Change of Director's Interest THR 320 KB
5 June 2019 Change in Substantial Holding THR 159 KB
29 May 2019 Appendix 3B 265 KB
29 May 2019 Change of Director's Interest THR 313 KB
23 May 2019 Change of Director's Interest Amended THR 313 KB
22 May 2019 Change of Director's Interest THR 313 KB
9 May 2019 Change in Substantial Holding Aliton 79 KB
30 April 2019 Quarterly Cashflow 31 March 2019 191 KB
30 April 2019 Quarterly Activities 31 March 2019 229 KB
14 March 2019 Half Yearly Report and Accounts 895 KB
31 Jan 2019 Quarterly Cashflow 31 December 2018 153 KB
31 Jan 2019 Quarterly Activities 31 December 2018 256 KB
25 Jan 2019 Response to ASX Appendix 3Y Query 671 KB
24 Jan 2019 Change of Director's Interest DD 341 KB
18 Jan 2019 Change of Director's Interest THR 1 MB
18 Jan 2019 Change of Director's Interest EL 1 MB
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