Boardroom Pty Limited (ABN 14 003 209 836) (“BoardRoom”, “we” or “us”) provides ClientOnline for use by persons (“users”, or “you”) who have been authorised by an entity (a “client”) who has appointed BoardRoom to provide services associated with securities registry maintenance and/or the administration of employee equity plans.

Through ClientOnline you are able to view information and request reports in relation to holdings of securities issued by the client of BoardRoom which authorised your access to ClientOnline (these securities are referred to collectively as “holdings”).

By accessing ClientOnline, you agree to be bound by these terms of use (“Terms”). If you do not accept these Terms, you must cease using this portal.

Please see our Privacy Policy for details of how we may collect and maintain personal information obtained through this web portal.

The headings in this document are provided for convenience and are not to be used in interpretation.

When you are authorised by a client to access ClientOnline, BoardRoom will provide you with a username (also referred to as a Login ID) and a password. You will be asked to change your password when you first log in. You cannot change your username.

By using ClientOnline with your Login ID and password, you warrant that you have been and continue to be duly authorised by that client to access information held in respect of that client’s securities register(s) and/or employee equity plan.

You agree to keep your account details (username and password) confidential and not to share them with any other person. You must notify us immediately if you become aware of any unauthorised use of your account details.

Through ClientOnline you can obtain and view certain information for holdings. This includes the following:

• You may query a client’s register(s) of securityholders or employee equity plan participants and obtain details in relation to securityholders or employee equity plan participants such as registered address, the election recorded in respect of any dividend plan or dividend payment method, and the number of securities held.
• You may produce reports in relation to holdings, and access reports that you have previously produced.

While BoardRoom takes reasonable care to ensure the information provided in this web portal is complete, current and correct, you may not hold BoardRoom liable or responsible for any errors or omissions. In particular, BoardRoom will not be responsible for:

• information in relation to security holdings that is provided to BoardRoom by third parties (such as information concerning the acquisition or disposal of a holding);
• verifying information provided by you or on your behalf; or
• your acting on information pertaining to the number of securities registered in holdings at the time you make an enquiry, where you have not taken into account any change to that number that is still to be recorded (for example, if a sale or purchase has been undertaken but has not yet been recorded in the register).

Links to other websites are provided as a matter of convenience only and do not constitute endorsement of a particular company, the products or services provided by that company, or any products or services advertised on a linked website.

Similarly, information provided through this web portal does not constitute a recommendation by BoardRoom with respect to dealing in securities. You should always obtain independent financial advice before buying or selling securities.

You are solely responsible for any use you choose to make of this web portal and you accept liability for any and all losses, damages, costs or otherwise resulting directly or indirectly from the use of this portal. BoardRoom specifically disclaims all liability for any losses, claims or damages that may be incurred as a consequence of the use of this web portal, or the use of information obtained through this web portal, including the unauthorised disclosure or misuse of securityholder reference numbers (SRNs) and/or holder identification numbers (HINs).

While we strive to provide constant, uninterrupted access to our web portals, BoardRoom cannot guarantee that this portal will be available at all times, and we accept no responsibility or liability for any interruption or delay to our services. Further, we cannot guarantee that access to specific client-related information will always be available; for example, an issuer of securities who is a client of BoardRoom may ask us to restrict access to information in relation to any or all of their securities.

BoardRoom will not be held responsible for and disclaims all liability for any loss or damage sustained by you as a result of illegal or improper access to this service.

These terms and conditions are governed by and shall be construed in accordance with the law applicable in New South Wales. If any part of these terms is found not to be legally enforceable, the remainder of the terms shall remain valid and enforceable.

You agree to defend, indemnify and hold harmless BoardRoom from and against any and all claims, damages, costs and expenses, including legal fees, arising from or related to your use or misuse of our web portals.

BoardRoom reserves the right to modify these terms of use from time to time at our sole discretion.

This Privacy Policy is current as of 6^th November 2023.

This Policy has been adopted by and applies to, each of the BoardRoom Group Australian companies¹ (hereinafter "BoardRoom", "we" or "us") . BoardRoom provides a comprehensive range of services to public companies (both listed and unlisted), managed investment schemes and trusts (both listed and unlisted),, proprietary limited companies and and some member-based organisations. In providing these services we collect information from and about you. This information is essential for us to deliver our services; if you choose not to provide it, we will not be able to provide our services to you.

As required by law, we comply with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). This Privacy Policy outlines how BoardRoom collects, manages, uses and safeguards your personal information. Protecting personal information provided to us is important and integral to our business philosophy and ethics.

By accessing the BoardRoom website (http://www.boardroomlimited.com.au), or by using our services, you are agreeing to be bound by the terms of this policy and by the Terms of Use.

BoardRoom provides the following services:

Securities registry management

• We maintain registers of securities, which includes maintaining registers of names and addresses of securityholders.
• We facilitate communications between issuers and securityholders.
• We facilitate payment of dividends and distributions to securityholders.
• We handle securityholder enquiries.

Employee equity plan management

• We administer employee equity plans on behalf of our clients.
• We facilitate communications between our clients and their employees in relation to employee equity plans.
• We facilitate payment of dividends and distributions to participants in an employee equity plan we administer.
• We handle enquiries from participants regarding the employee equity plans in which they participate.

Corporate secretarial and governance support

• We provide administrative support to incumbent corporate secretaries and governance professionals.
• BoardRoom staff can be named as company secretary for proprietary limited or public companies.
• We can undertake a review and, where applicable, make recommendations for improvement of, existing corporate secretarial and governance practices.

Payroll administration

• We provide a range of services in this area, from basic record keeping to processing employee payments.

In our capacity as a securities registrar, employee equity plan administrator, provider of company secretarial and governance services and payroll administrator, BoardRoom collects personal information including:

• name and address details;
• securityholding or plan participation details;
• securityholding balances;
• bank account details;
• tax file numbers;
• dates of birth;
• telephone numbers;
• email addresses;
• broker or advisor details;
• ID Documents; and
• Asset Documentation

We only collect personal information when we need it in order to provide our services. If you do not provide us with the information we need, we may not be able to provide services to you.

Personal information

In the course of maintaining securities registers and administering employee equity plans, we may receive personal information directly from securityholders or employee equity plan participants. This may be:

• during interactions with our customer service representatives
• on paper or electronic documents provided to us, such as application forms, advices of banking instructions or tax file numbers, or statutory declarations
• through our online internet-based facilities

We may also receive information from the following sources:

• issuers for who we provide security registrar or employee share plan administration services
• securities exchanges
• stockbrokers or financial advisors
• users of the internet-based facilities offered by BoardRoom
• clients who use our payroll administration services or the employees of those clients
• directors and/or other officers of companies to which we provide company secretarial services

The security, integrity, and confidentiality of your information is very important to us. Personal information we collect is stored in secure electronic databases which are managed by BoardRoom and, where applicable, on paper documents. Any information on paper documents is stored in secure, offsite storage facilities for a period of time determined by law or in accordance with our client's instructions.

The databases and offsite storage facilities are both located within Australia. BoardRoom has implemented technical, procedural and physical security measures that are designed to protect your information from misuse, interference and loss and from unauthorised access, modification or disclosure.

In addition to the measures noted above, BoardRoom has implemented policies which require employees to keep secure and confidential, any personal information they access as a result of their employment. BoardRoom also requires its employees to annually complete training in relation to privacy and information security.

We will not adopt as our own any identifiers (such as your Tax File Number) that you may provide to us.

The nature of the services we provide and the regulatory requirements applicable to some of the information we collect, does not allow us to enable the anonymisation of personal information we hold.

We use cookies and log files on our web portals to enhance their functionality. A cookie is a small text file that our websites may place on your computer to collect information such as your internet protocol address, your computer’s operating system, and the browser you are using. We use this information to monitor service usage and to optimise the delivery of our services to you. You may adjust your internet browser to disable cookies or to inform you when one is being used. If you choose to disable cookies, you may be unable to access certain areas of our website.

Sometimes our website contains links to external websites for convenience and information. These websites are not managed by BoardRoom and we cannot be responsible for their privacy practices. You should refer to the privacy policy of the provider of the external website for information concerning their privacy practices.

Providing services to you

Personal information is collected and used to provide additional services related to the initial purpose for which your personal information was collected. The services for which we require personal information include the following:

• maintaining security registers, which issuers of securities are obliged to maintain under the Corporations Act 2001 (Cth) ("Corporations Act")
• providing services related to registry and employee equity plan administration, including dividend and distribution payments and corporate communications
• providing services relating to voting management, including distribution of voting information, collection and recording of votes, and counting of votes
• facilitating BoardRoom's and our clients' compliance with legal and regulatory requirements.

Disclosing personal information

BoardRoom does not sell, trade, lease or rent personal information.

We may be required or authorised by law to disclose information to law enforcement agencies, government agencies, and courts. This may happen for a number of reasons, including to prevent or investigate an actual or suspected crime or fraud.

We may also disclose personal information to organisations with whom we have professional relationships, including:

• the issuer of the securities you hold
• regulatory authorities, including the ATO
• authorised security brokers or financial advisors
• external service providers, such as printers and mail houses, who assist BoardRoom in providing services

If, in accordance with the provisions of the Corporations Act, the issuer of the securities you hold (including where you hold securities as a participant in an employee equity scheme) approves, you may be sent marketing material in addition to general corporate communications. You may elect not to receive marketing material by contacting BoardRoom.

Cross border data transfers

Unless we are required to by law, BoardRoom will not disclose personal information to an overseas recipient. However, if requested by one of our clients, a related party of BoardRoom wherever situated (including in Hong Kong, Malaysia, Singapore and China) may use personal information that we have collected in order to assist us in providing services to the client who made the request.

Your rights if you are in the EU

As provided for in the General Data Protection Regulation, you have the right to access your data; to correct or rectify your data; to delete your data subject to applicable law; to have your data processed only in accordance with applicable law; to have copies of your data to be moved to another controller; to object to our processing your data otherwise than in accordance with the law; and to withdraw any consent to our processing your data at any time. Please contact our Privacy Office to exercise any of those rights.

You have the right to access, correct and update the personal information that we hold about you. To protect the privacy and integrity of our records, BoardRoom may require you prove your identity before we can disclose, correct or update personal information.

Some personal information may be stored in our archives. These are not current records. If you wish to request information from our archives, you may be asked to complete a personal information request form. We may charge you a fee for this service, but we will inform you at the time of your request if a fee is required.

For updates to name and address details related to participant-sponsored CHESS holdings, you must contact your sponsoring participant.

We may amend this Privacy Policy from time to time in order to take account of changes to legislation, or if we make changes to any of our practices that affect how we collect and store information. BoardRoom reserves the right to change this Privacy Policy at any time without notification to you.

If you have any questions or comments about our Privacy Policy or if you wish to make a complaint about how we have handled personal information about you, please contact BoardRoom’s Privacy Officer who will try to resolve the matter within ten (10) business days. If we are unable to resolve the matter within that time, we will contact you to let you know how long it will take to resolve the complaint or, if more appropriate, suggest the matter be referred to the Privacy Commissioner. BoardRoom’s Privacy Officer contact details are:

privacyofficer@boardroomlimited.com.au

or

¹ The BoardRoom Group Australia companies are Boardroom Holdings Australia Pty Ltd ACN 145 369 295, Newreg Pty Ltd ACN 125 082 804, Boardroom Pty Limited ACN 003 209 836 AFSL No. 533383, Boardroom (Victoria) Pty Limited ACN 110 851 333, Boardroom Financial Services Pty Limited ACN 136 781 443 AFSL No. 338301, Boardroom Integrate Pty Limited ACN 097 300 377, Boardworx Pty Ltd ACN 144 036 911, Corporate Counsel Pty Ltd ACN 118 343 687], and Registries Pty Limited ACN 002 936 496.

Boardroom Pty Limited (“BoardRoom”) strives to act in accordance with the Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises.

A human right is a right to which all human beings are entitled. These rights are internationally defined and recognised.

For purposes of implementing this Policy, a human right shall be one recognised by the International Bill of Human Rights, or as otherwise identified or described in this Policy or any relevant implementing procedures.

Human rights violations frequently also violate domestic laws, which may include domestic criminal laws, labour laws, laws protecting property, laws protecting civil rights, and other legal provisions.

This Policy requires that the same respect be provided by all Boardroom employees (including affiliate or subsidiary employees) and third party service providers.

For the purposes of this Policy:

a “contractor” or “third party service provider” is defined as an entity or individual who provides, and receives payment for, services or goods related to any aspect of BoardRoom and includes subcontractors.

“external stakeholders” means residents of communities in which BoardRoom operations take place, employees of third party service providers and other non-employees whose human rights may be directly impacted by Boardroom operations.

The purpose of this Policy is to:

• set out BoardRoom’s policy with respect to human rights;
• provide guidance to employees and third-party service providers regarding their human rights responsibilities; and
• identify how BoardRoom’s human rights policy will be implemented.

The objectives of this Policy are to ensure respect for the human rights of all employees and third parties impacted by BoardRoom’s operations and maintain compliance with relevant BoardRoom rules and applicable legal regulations.

It is BoardRoom’s policy to respect the human rights of all individuals impacted by BoardRoom operations, including employees and external stakeholders.

While governments have the primary responsibility to protect against human rights violations, BoardRoom recognises its corporate responsibility to respect human rights. Accordingly the principles BoardRoom has adopted to meet its stated purpose, are:

• BoardRoom does not tolerate violations of human rights committed by its employees, affiliates, or any third parties acting on its behalf or related to any aspect of a Boardroom operation.
• BoardRoom does not tolerate the use of child labour, prison labour, forcibly indentured labour, bonded labour, slavery or servitude, and adheres to the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work.
• BoardRoom does not tolerate discrimination against individuals on the basis of race, colour, gender, religion, political opinion, nationality or social origin, or harassment of individuals freely employed.
• BoardRoom recognises and respects the freedom to join or refrain from joining legally authorised associations or organisations, and respects the safety and health of workers.
• BoardRoom does not tolerate threats, intimidation or attacks against human rights defenders.

In its relationship with host governments, contractors and third-party service providers, BoardRoom seeks to avoid being complicit in adverse human rights impacts.

In carrying out this Policy:

• BoardRoom will strive to conduct reasonable human rights due diligence to determine the actual and potential human rights impacts of its operations, and seek to employ reasonable measures to mitigate any such impacts.
• BoardRoom will institute procedures and mechanisms that specify how known or suspected human rights violations should be reported by employees and stakeholders, and how such reports are to be investigated.
• BoardRoom will strive to protect from retribution all employees who timely report suspected human rights violations.
• BoardRoom will seek to adhere to the requirements of the Voluntary Principles on Security and Human Rights in its dealings with private and public security providers, local communities, and potential victims of human rights violations.
• For relevant third-party service providers, BoardRoom will perform reasonable due diligence, require that human rights terms and conditions be included in contracts, and require periodic human rights reporting and certifications. BoardRoom will require that third party service party providers are aware of, and comply with, this Policy. Certain third-party service providers may be required to receive human rights training.
• In instances in which BoardRoom determines that its employees, affiliates or third parties acting on its behalf have caused adverse human rights impacts, it will consider appropriate mechanisms to mitigate such impacts and remediation. Where violations by employees are proven, BoardRoom will consider appropriate sanctions and remedies to victims.

Any employee implicated in human rights violations or other serious criminal acts may face termination of employment.

Any employee who has direct knowledge of but fails to report human rights violations, or other serious criminal acts, of employees or third-party suppliers or contractors may face termination.

Any employee who misleads or hinders investigators inquiring into human rights violations or serious criminal acts may face termination.

Any contractor implicated in human rights violations or serious criminal acts, who knows of and fails to report human rights violations or serious criminal acts, or who misleads investigators making inquiries into human rights violations or serious criminal acts, will be expected to take appropriate remedial actions and/or may have their contracts re- evaluated or terminated, depending on the circumstances.

This Policy is applicable to every employee of BoardRoom, including, members of the BoardRoom’s Board of Directors. The Policy and its reporting requirement are also applicable to BoardRoom’s contractors and suppliers.

This Policy is intended to supplement all applicable laws, rules, and other corporate policies.

Feel free to contact us. We're here to help.

Phone

Within Australia:

1300 737 760

Outside Australia:

+61 2 9290 9600

Fax

Within Australia:

1300 653 459

Outside Australia:

+61 2 9279 0664

Email

enquiries@boardroomlimited.com.au

Mail

Boardroom Pty Limited
GPO Box 3993
Sydney NSW 2001
Australia

Feel free to contact us. We're here to help.

Phone

Within Australia: 1300 737 760

Outside Australia: +61 2 9290 9600

Fax

Within Australia: 1300 653 459

Outside Australia: +61 2 9279 0664

Email

enquiries@boardroomlimited.com.au

Mail

Boardroom Pty Limited
GPO Box 3993
Sydney NSW 2001
Australia