Code of Ethics

The Code of Ethics sets out ethical values and business principles applicable to all employees of NetLink NBN Trust and its subsidiaries (the "Trust Group"). All employees of the Trust Group are expected to observe values such as integrity, responsibility and accountability while carrying out their duties and responsibilities in their daily dealings.

The Code of Ethics also provides for standards of practice expected of all employees when dealing with conflicts of interests, confidential information, health, safety and environment concerns, and other matters.

Fraud Policy

In line with the Trust Group policy to maintain high ethical standards, we have adopted a fraud policy to facilitate the development of controls that will aid in the detection and prevention of fraud against the Trust Group. The fraud policy provides guidance on acts which may constitute fraudulent conduct and sets out procedures to be followed by the Trust Group and its employees when fraud is detected or suspected.

Whistle-blowing

The Trust Group has adopted a whistle-blowing procedure which provides a platform for employees, external parties such as customers, suppliers, contractors and applicants for employment, and the general public, to raise concerns in good faith about any perceived irregularity or misconduct within the Trust Group, without fear of retaliation.

Making a Report

External parties may express their concerns via an independent conduit, KPMG EthicsLine, through the following channels:

Confidentiality

All concerns raised or information received will be treated as strictly confidential and shared only with authorised persons on a 'need-to-know' basis. Every effort will be made to ensure that confidentiality is maintained throughout the process and that the identity of the whistleblower is protected, although there may be exceptional circumstances requiring the Trust Group to divulge the information to other parties. Exceptional circumstances include instances where the Trust Group is under legal obligation to disclose the information provided to the appropriate governmental or regulatory authority.

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