This policy outlines the Yurra policy for workplace Health and Safety and applies to the Yurra Group; hereafter referred to as Yurra.

Yurra is committed to achieving the highest performance standards of its Health, Safety and Environmental Management for its employees, contractors, visitors, and clients.  We recognise that safety is a key performance indicator and that if we are to achieve our operating and business objectives in the most effective and efficient way, adherence to high standards of health, safety and environmental performance is essential.

Scope

This policy applies to all employees, officers, contractors, consultants, temporary workers, and other people working on behalf of Yurra during on-site, off-site, or after-hours work, official work-related social functions, or official work-related training. This policy applies to all employees and contractors who are engaged by an entity of Yurra Group including:

• Yurra Pty Ltd;
• GBSC Yurra Pty Ltd; and
• Ngardimu Pty Ltd.

Policy Statement

It is our aim to protect workers from injury, illness, and hardship by establishing and complying with environmental standards that meet or surpass recognised standards and to demonstrate by our safety record that we are a caring company.

Yurra commits to:

• Providing safe and healthy working conditions for the prevention of work-related injury and ill health which are appropriate to the nature of the occupational health and safety risks to which workers and others may be exposed.
• Providing a framework for setting the occupational health and safety objectives.
• Fulfill legal and other requirements.
• Elimination of hazards and reduction of occupational health and safety risks.
• Continual improvement of the occupational health and safety management system.
• Consultation with and participation of workers, and, where they exist, workers representatives.

Our policy objectives will be achieved by:

• Giving due consideration to issues of health and safety management in all stages of planning, design, and construction to incorporate systems to eliminate for control hazards.
• Commit sufficient resources for the effective implementation of safety management systems in all areas of operation.
• Ensure all workers are competency and suitably skilled to undertake the duties for which they are employed in a productive and environmentally friendly and safe manner.
• Maintain the development of a program of education and training to enhance skills and increase health, safety, and environmental awareness.
• Collectively support and participate inn the promotion of proactive health, safety, and environmental management systems and strive for continual improvement through audit and evaluation programs.
• Ensure all workers understand and accept their health, safety, and environmental responsibilities and are held accountable for those matters within their control.
• Provide an effective system of injury and environmental rehabilitation.
• Only engage competent subcontractors who can demonstrate health safety, and environmental management systems that complement our own high standards.

The responsibility for continually upgrading the Health, Safety and Environment system and procedures sits with the relevant manager.  The responsibility for the implementation of this policy sits with the Chief Executive Officer.

This policy outlines the Yurra policy for workplace Modern Slavery and applies to the Yurra Group; hereafter referred to as Yurra.

1. Statement of Intent

The purpose of this policy is to set out how Yurra will deal with modern slavery within its operations and supply chain, provide awareness of what modern slavery is and encourage individuals to monitor and report suspected acts of modern slavery.  Yurra is committed to safe workplaces and to limiting the risk of modern slavery within its own operations and supply chains.  Yurra is dedicated to bringing positive change and opportunities within the communities which we operate and will in now way condone, support, or contribute, either directly or indirectly, to modern slavery.

2. Coverage

This policy applies to all employees, officers, contractors, consultants, suppliers of Yurra. This policy applies to all employees, officers, consultants, and contractors who are engaged by an entity of Yurra Group including:

• Yurra Pty Ltd;
• GBSC Yurra Pty Ltd; and
• Ngardimu Pty Ltd.

3. Definition

Modern Slavery is defined in the Modern Slavery Act (Cth) 2018 s conduct which could constitute:

1. An offence under Division 270 or 271 of the Criminal Code; or
2. An offence under either of those Divisions if the conduct tool place in Australia; or
3. Trafficking persons, as defined in Article 3 of the Protocol to Prevent, Suppress and Punish Trafficking in persons, especially women and children, supplementing the United Nations Convention against Transnational Organised Crime, done at New York on 15 November 2020 ([2005] ATS 27); or
4. The worst forms of child labour, as defined in Article 3 of the ILO Convention (No. 182) concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labour, done at Geneva on 17 June 1999 ([2007] ATS 38).

Examples of what constitutes as modern slavery is forms of slavery such as servitude, trafficking in persons, forced labour, debt bondage, forced marriages, sale of an/or sexual exploitation of women or sale of children for forced labour exploitation, and where victims are forced to work out of fear of violence or intimidation.

4. Action Yurra will take to eradicate Modern Slavery within its Supply Chains

Yurra is committed to make sure it does not engage suppliers that breach modern slavery legislation by regularly reviewing supply agreements. We are committed to holding suppliers accountable to their commitment of eradicating modern slavery and will not knowingly engage suppliers or subcontractors that do not align with its position of enforcing basic human rights.

To ensure compliance with modern slavery legislation, Yurra will conduct due diligence with suppliers.  If non-compliance is suspected or identified, Yurra will take the following actions:

• Warning and Investigation: a formal warning will be issued, and an internal investigation will be initiated.
• Corrective Action Plan: the supplier or subcontractor will be required to develop and implement a corrective action plan within an agreed timeframe.
• Auditing and Monitoring: additional audits and continuous monitoring may be applied to the supplier’s operations.
• Contract Suspension or Termination: for serious or unresolved violations, Yurra reserves the right to suspend or terminate contracts with the supplier or subcontractor.

Yurra’s commitment to upholding human rights includes not engaging with supplies or subcontractors that fail to meet compliance standards.

All Yurra major and minor supply contracts will include a clause pertaining to modern slavery requiring the supplier or subcontractor to:

• Provide commitments to eradicate modern slavery in their own operations and supply chains;
• Warranting that it has not been convicted of a modern slavery offence; and
• Have completed its own due diligence on its supply chain.

Yurra includes questioning regarding modern slavery compliance in our subcontractor prequalification application which is reviewed and assessed for compliance.

5. Training

Yurra will provide training to inform employees of this policy and what is considered modern slavery.

6. Reporting and Whistleblower Protection

Yurra will protect those individuals that report or identify modern slavery occurring within the organisation and supply chains.  If an employee, subcontractor, or related person to Yurra is aware of Yurra person or a supplier or service provider that is breaching modern slavery laws, the individual should report the breach to their direct manager or if not able to do so, the next individual that is appropriate in the reporting chain of command. Yurra is committed to protecting whistleblowers under protections provided by Australian Whistleblower Protection Act 2019.  Individuals who report concerns in good faith will be protected from any form of retaliation, including dismissal, disciplinary action, or discrimination.

7. Breaches of this Policy

Any breach of this policy by Yurra employee, subcontractor, consultant, director, or officer will be managed in accordance with the legislative requirements and relevant disciplinary policy.  All employees, subcontractors, consultants, suppliers, directors, and officers of Yurra or its subsidiaries will be expected to cooperate fully in any investigation into suspected breaches of this policy or any related processes or procedures.  Outcomes of breaches may result in corrective action plans to resolve any violations or may result in the company reserving its right to terminate the relationship with employees or organisations in our supply chain if the breach warrants.

8. Policy Review

Yurra is committed to ensuring that this modern slavery policy remains relevant and effective. The policy will be reviewed regularly and updated as required if there are significant changes in modern slavery legislation or operational requirements. Any updates will be made available to all employees, subcontractors, and suppliers.

This policy outlines the Yurra policy for Anti-Bribery and Corruption and applies to the Yurra Group; hereafter referred to as Yurra.

1. Purpose

Yurra is committed to ensuring that all aspects of its business and operations are carried out in a fair, honest and ethical manner always.  We will strive to ensure that all persons working for the Yurra maintain the highest standards of business practice by acting fairly and with integrity in all business dealings and relationship, and by not engaging in any practice that may be designed to influence persons to act dishonestly in the performance or discharge of their duty.

2. Coverage

This policy applies to all employees, officers, contractors, consultants, suppliers of Yurra. This policy applies to all employees, officers, consultants, and contractors who are engaged by an entity of Yurra Group including:

• Yurra Pty Ltd;
• GBSC Yurra Pty Ltd; and
• Ngardimu Pty Ltd.

Yurra expects all third parties including subcontractors, consultants, and suppliers to comply with this policy.  Contracts with third parties must include anti-bribery and corruption clauses, and due diligence must be conducted to ensure adherence to ethical business practices.

3. Policy Statement

Bribery and corruption are illegal.  Yurra prohibits all forms of bribery and corruption in its business dealings.  Employees and third parties acting on behalf of Yurra must not:

• Offer, give, request, or accept bribes, kickbacks, or any other improper payments; or
• Make facilitation payments, even if they are customary in certain jurisdictions; or
• Offer or provide gifts, entertainment, or hospitality that could be perceived as influencing a business or government decision; or
• Use company funds for illegal or unethical purposes.

4. Definitions

Bribery and corruption are illegal.  Yurra prohibits all forms of bribery and corruption in its business dealings.  Employees and third parties acting on behalf of Yurra must not:

• Bribery:  offering, giving, receiving, or soliciting something of value (e.g. money or gifts or favours) to influence a decision or gain improper advantage in business or government matters.  Bribery can include:
  
  • Cash or cash equivalent; or
  • Entertainment or other hospitality; or
  • Gifts; or
  • Sponsorships or donations; or
  • Travel and accommodation; or
  • Favours or decision regarding award o jobs, offer of employment contracts, or projects contracts.
• Connected Persons: in relation to a director, employee, or contractor:
  
  • Their spouse or domestic partner or child or immediate family or
  • A relative who has shared a household for at least 12 months as at the date of the relevant conduct; or
  • Companies in which they are a director, or a senior executive concerned in, or taking part in the management of the company.
• Contractor: an individual, company or other business that carries out work, performs services or provides material or equipment for Yurra under a contract and includes subcontractors and suppliers.
• Corporate Hospitality: the provision of hospitality and entertainment for official company purposes to corporate clients, key stakeholders, and interest groups.
• Corruption: dishonest or fraudulent conduct by a person in power, typically involving bribery or other forms of unethical behaviour to gain advantage in the contravention of duty and the law.
• Facilitation Payments: small, unofficial payment made to secure or expedite routine government actions (e.g. permits or approvals).
• Gifts: any tangible items of value including money, alcohol, favours, hospitality, entertainment, tickets to sporting events, travel, and accommodation, which is provided to a director, employee, or contractor, that recipient does not pay fair market value.  This is also where a director, employee, or contractor has presented such tangible item of value to an external party.
• Public Officials: include public servants, employees of government owned or controlled enterprises, and any person who is standing for public office or is elected or appointed to any public office.

5. Responsibilities

The company will:

• Keep appropriate internal records that will evidence the business reason for making any payments to third parties.
• Encourage employees to raise concerns about any issues or suspicion of corruption or malpractice at the earliest possible stage.
• Ensure that anyone raising a concern about bribery or corruption does not suffer any detriment as a result.

Directors, employees, and contractors will:

• Not solicit or request any gift or benefit in connection with your position with the company.
• Take all reasonable steps to prevent any of your connected persons from soliciting or accepting gifts and benefits from external parties, particularly where they do not comply with this policy or anti-bribery laws.
• Notify the relevant manager in writing upon receiving or offering a gift of $300 AUD or more, to obtain approval.
• Notify in writing if you have given an offer, gift, or benefit to a client or third party.
  Immediately report any suspected or actual violations of this policy.

6. Gifts, Benefits and Hospitality

Gifts, benefits, and hospitality are provided or received as part of business relationships must be modest, infrequent, and transparent.  Offering and accepting gifts, benefits and hospitality is a legitimate contribution to building good business relationships.   While some gifts and benefits are acceptable, others have the potential to appear to compromise the integrity of the company, its directors, employees, and contractors. All directors, employees and contractors must exercise care when offering and accepting gifts, benefits, or hospitality to maintain the reputation of the company against allegations of misconduct and to ensure that anti0bribery and corruption laws are not breached.

The following guidelines apply:

• Prohibited Gifts and Benefits:‍
  
  • Monetary gifts or equivalent such as cash, cheques, gift cards and bank transfers; or
  • Any gift or benefit that is intended for favourable treatment in the future; or
  • Any gift or benefit for any duties performed or not performed by the recipient particularly where acceptance may give rise to an actual, potential, or perceived conflict of interest; or
  • Offer of travel and/or accommodation (including for your spouse or partner); or
  • Gifts, hospitality or entertainment of an inappropriate nature or value or at an inappropriate venue; or
  • Hospitality or entertainment that is primarily the consumption of alcohol only; or
  • Offering or accepting gifts of excessive monetary value; or
  • Gifts or benefits to or by anyone involved in any stage of a tendering process from any organisation involved in a bid or tender with Yurra; or
  • Any gift or benefit that is solicited or requested in connection with the person’s position at Yurra.
• Permissible Gifts and Benefits:
  
  • Modest gifts and benefits may be accepted or offered of they are not intended to influence a decision or create an obligation.  Gifts under $300 AUD may be accepted without manager approval; any gifts must be given a nominal value in accordance with below:
    
    • Token Gifts: are modest gifts offered in business situations (not as personal gifts) and as common courtesy business accessories associated with general commercial practice, usually company-branded and with a nominal value of less than $300 AUD.
    • Ceremonial Gifts: with a nominal value of less than $300 AUD and used to express gratitude during the conduct of business between Yurra and an external party.
    • Seasonal or Occasional Gifts: given primarily during festive season or in appreciation for exemplary performance of duties or specific task and has a nominal value of less than $300 AUD.
• Seeking Prior Approval:‍
  
  • Provided the gift or benefit complies with the provisions of this policy you are not required to seek approval to give or accept.  However, where any gif or benefit exceeds the nominal values or does not meet the guidelines for suitability, you must seek written approval from the Chief Financial Officer or Chief Executive Officer.  If the gift is approved, it will be recorded in the Gift Register.  
  • Additionally, approval must be obtained if:
    
    • You are unsure if the gift or benefit meets suitability criteria: or
    • The person you are giving to or receiving from is a public official: or
    • The same external party has offered or provided a gift or benefit in the previous six (6) months.
• Reporting Requirements:‍
  
  • Any gift or benefit that is given, offered, or accepted is required to be reported in writing to the Chief Financial Officer or to admin@yurra.com.au within 24 hours of giving, offering, or receiving.  This includes where the gift or benefit meets the nominal value.
• Recording Gifts and Benefits:‍
  
  • An accurate and auditable record of all gifts, benefits and entertainment to clients, public officials, employees, and contractors must be kept in accordance with accounting principles and this policy.

Yurra considers breach of this policy a serious matter and reports of any breaches will be investigated.  Disciplinary action, including termination of employment or services may be taken against any director, employee, consultant, or contractor who contravenes this policy.  It is important to note that any director, employee, consultant, or contractor may be personally liable for breach of this policy.  Depending on the nature and severity of the breach, the contravention may be referred to the relevant authorities.

This policy outlines the Yurra policy for Anti-Discrimination, Harassment and Bullying and applies to the Yurra Group; hereafter referred to as Yurra.

1. Purpose

Yurra is committed to creating a workplace where every individual is treated with respect and dignity, free from unlawful or other inappropriate behaviour.  We will not tolerate any form of harassment, bullying or discriminatory behaviour.

2. Coverage

This policy applies to all employees, officers, contractors, consultants, suppliers of Yurra including working on behalf of Yurra during on-site, off-site, or after-hours work, official work-related social functions, official work-related training and in the use of social media or other online communication platforms:

• Yurra Pty Ltd;
• GBSC Yurra Pty Ltd; and
• Ngardimu Pty Ltd.

3. Policy Statement

Yurra is committed to:

• Promoting and maintain a culture of respect and fair treatment, where individual differences are recognised and valued.
• Encouraging reporting of behaviour or actions that breach this policy and providing protection from victimisation or vilification.
• Ensuring that all complaints of harassment, discrimination or bullying are treated confidentially, professionally, promptly, and fairly.
• Implementing training and awareness for all employees to understand their rights and responsibilities and to have the self-assurance to act in circumstances of inappropriate behaviour.
• Ensuring that all aspects of employment including recruitment, promotion, training, career development, redundancy and termination are based on merit, competence, and business requirements.
• Promoting and modelling appropriate standards of behaviour that minimise any risk of psychological or physical harm.

This policy outlines the Yurra Code of Conduct and applies to the Yurra Group; hereafter referred to as Yurra.

At Yurra we require that all workers conduct themselves according to the highest standards of ethics, integrity, and behaviour when dealing with our clients, colleagues, and other stakeholders. This includes, but is not necessarily limited to, full compliance with all legal obligations imposed by statute or any other source of law. This Code establishes the standards of behaviour that must be met by all employees. Where these standards are not met, appropriate disciplinary action will be taken. In cases where the breach involves serious misconduct, this may result in summary dismissal. In cases where a breach of the policy involves a breach of any law, then the relevant government authorities or the police may be notified.

1. Coverage

This policy applies to all employees, officers, contractors, consultants, suppliers of Yurra. This policy applies to all employees, officers, consultants, and contractors who are engaged by an entity of Yurra Group including:

• Yurra Pty Ltd;
• GBSC Yurra Pty Ltd; and
• Ngardimu Pty Ltd.

2. Purpose

The purpose of this policy is to make it clear what the Employer expects from employees, and employees are required to be familiar with and always comply with the terms of this policy. Failure to do so may result in disciplinary action, including potentially termination of employment. In so far as this policy imposes any obligations on the Employer, those obligations are not contractual and do not give rise to any contractual rights. To the extent that this policy describes benefits and entitlements for employees, they are discretionary in nature and are also not intended to be contractual. The terms and conditions of employment that are intended to be contractual are set out in an employee’s written employment contract.

3. Standards of Conduct

The standards expected of employees include:

• Compliance with all Company and workplace policies, procedures, rules, regulations, and contracts.
  Compliance with all laws.
• Compliance with all reasonable and lawful instructions given by or on behalf of the Company.
• Devotion of the employee’s entire time, attention, and skill during normal working hours and at other times as reasonably necessary for the employee to perform their duties.
• To be honest and fair in dealings with customers, clients, co-workers, company management and the public, and to treat them with courtesy and respect.
• To be faithful and diligent and actively pursue the Company’s best interests at all times.
• To work in a safe and compliant manner, and to observe all workplace health and safety rules and responsibilities.
• Refraining from any discriminatory, bullying, or harassing behaviour toward customers, clients, coworkers, company management and the public.
• To not make any statements to the media about the Company’s business, unless expressly authorised in writing to do so by the Company (requests for media statements should be referred to CEO).
• To not make any statements about the Company on social media, or any other public platform, that may harm the Company’s reputation.
• To not, in connection with the employee’s employment, accept any financial or other benefit from any entity other than the Company – unless acceptance of such benefit is in accordance with the Company’s other workplace policies or is otherwise disclosed to the Company and expressly permitted by the Company.

• To not engage in any employment or provide any services to any person or entity other than the Company, except with the Company’s prior written consent.
• To not engage in any employment or provide any services to a supplier or competitor of the Company, except with the Company’s prior written consent.
• Immediately disclosing any potential, perceived or actual conflict of interest (whether direct or indirect) that may give rise to a conflict with the performance of the employee’s obligations to the Company, or the Company’s business, confidential information, or reputational interests. The Company may direct employees to take action to eliminate or reduce any such conflict, and employees must comply with such directions.
• To not engage in conduct, whether during or after work hours, that in the opinion of the Company causes damage or potential damage to the Company’s property or reputation.
• To not use or come to work while affected by use of prohibited drugs or alcohol.
• To not discriminate because of personal characteristics including (but not limited to) sex, race, disability, pregnancy, age, marital status, or sexual orientation.
• To ensure and maintain punctuality.
• To respect the Company’s property.
• To dress in an appropriate manner and to ensure that appearance is presentable, clean, neat, and tidy (including but not limited to wearing any uniform that is required of you by the Company).
• To not use Company internet to access and/or download sexually explicit material or other offensive material.
• To not use Company email to send sexually explicit or suggestive material, or other offensive or harassing material.
• To maintain both during employment and after termination of employment with the Company, the confidentiality of any confidential information, records or other materials acquired during employment.
• At all times, behave in a way that upholds the Company’s core values and the integrity and good reputation of the Company.
• Reporting any conduct of other workplace participants which is in breach of any of the above, or potentially in breach of any of the above, without delay.

This policy outlines the Yurra Quality Policy and applies to the Yurra Group; hereafter referred to as Yurra.

1. Purpose

To provide all workers with the procedures and responsibilities associated with systems and leadership that support quality outcomes.

2. Coverage

This policy applies to all employees, officers, contractors, consultants, suppliers of Yurra. This policy applies to all employees, officers, consultants, and contractors who are engaged by an entity of Yurra Group including:

• Yurra Pty Ltd;
• GBSC Yurra Pty Ltd; and
• Ngardimu Pty Ltd.

3. Policy Statement

Yurra is committed to high quality work and performance that minimises risk, severity of defects, non-confirming works, and rework.  It is the objective of Yurra to:

• Giving due consideration to issues of health and safety management in all stages of planning, design, and construction to incorporate systems to eliminate for control hazards.
• Strive for continuous improvement in all areas of our business.
• Comply with Australian and International standards relevant to our activities, products, and services, and to regularly evaluate compliance with such requirements.
• Proactively pursue the minimisation of non-confirming or defective works.
• Endeavour to eliminate the requirement for rework.
• Take proactive measures to monitor and manage quality service to our stakeholders, clients, and the wider community.
• Set objectives, targets, and programmes with aim of continuous improvement in quality performance.
• Create a positive cultural change by enhancing employee understanding of quality assurance.
• Monitor and measure our progress to facilitate continuous improvement.
• Train and instruct workers in sound quality practices.

Yurra shall participate in open consultation with interested stakeholders and ensure effective communication of thus quality policy to all persons working on behalf of the group.

This policy outlines the Yurra Whistleblower Policy and applies to the Yurra Group; hereafter referred to as Yurra.

1. Purpose

Yurra is committed to the highest standards of conduct and ethical behaviour in all our business activities and to promoting and supporting a culture of honest and ethical behaviour, corporate compliance, and good corporate governance.

Yurra encourages the reporting of any instances of suspected unethical, illegal, fraudulent, or undesirable conduct involving Yurra.  Yurra provides protections and measures so that those persons who make a report may do so confidentially and without fear of intimidation, disadvantage, or reprisal.

2. Coverage

This policy applies to all employees, former employees, contractors, suppliers or service providers, associate, or relative or dependent of any persons listed who are engaged by an entity of Yurra Group including:

• Yurra Pty Ltd;
• GBSC Yurra Pty Ltd; and
• Ngardimu Pty Ltd.

In addition to the protections under this policy:

• The Corporations Act 2001 (Cth) (Corporations Act) provides specific protections to whistle-blowers who disclose information concerning misconduct or an improper situation or circumstances in relation to Yurra or a related body corporate (See Annexure A).  This may include a breach of legislation including Corporations Act, an offense against the Commonwealth punishable by imprisonment for 12 months or more, or conduct that represents a danger to the public or financial system; and
• The Taxation Administration Act 1953 (Cth) (Taxation Administration Act) provides specific protections to whistleblowers on tax related matters (see Annexure B).

3. What is Reportable Conduct?

A report may be made under this policy if you objectively have reasonable grounds to suspect that a director, officer, employee, contractor, supplier, tenderer, or other person who has business dealings with Yurra has engaged in reportable conduct which:

• Is dishonest, fraudulent, or corrupt, including bribery or other activity in breach of Yurra Anti-Bribery and Corruption Policy;
• Is illegal activity (such as theft, violence, harassment or intimidation, criminal damage to property, breach of competition and consumer law, breach of privacy law or other breaches of state or federal law);
• Is unethical or in breach of Yurra policies (such as dishonestly altering company records or data, adopting questionable accounting practices or wilfully breaching Yurra’s Code of Conduct or other policies and procedures);
• Is potentially damaging to Yurra, an employee or a third party, such as unsafe work practices, environmental damage, health risks or abuse of company property and resources;
• Amounts to an abuse of authority or a conflict of interest;
• May cause financial loss to Yurra or damage its reputation or be otherwise detrimental to Yurra’s interests; or
• Involves any other kind of misconduct or an improper situation or circumstances.

Yurra expects that reports made under this policy are made honestly, ethically, and on reasonable grounds.  Persons making reports under this policy may still qualify for protection under this policy even if their disclosure turns out to be incorrect.

4. What is not Reportable Conduct?

This policy is not intended to apply to disclosures relating to conduct concerning a person’s individual employment or former employment (other than as set out in Reportable Conduct), such as:

• An interpersonal conflict at work;
• A decision relating to engagement, transfer, or promotion;
• A decision relating to terms and conditions of engagement; or
• A decision to suspend or terminate the engagement or to discipline the person.

These matters will not be deemed to be Reportable Conduct, do not fall within the scope of this policy, and will be investigated or addressed separately under Yurra’s workplace policies and procedures.

5. Who can I make a Report to?

If you become aware of any issue or behaviour which you consider to be Reportable Conduct and would like to report, please contact Yurra Independent Director Henry Thong, henry.t@yurra.com.au.

To qualify for protection, the disclosure must be made to the recipient outlined above, or any other recipient prescribed by law, such as an officer or senior manager of the company (includes a director or a senior manager who makes, or participates in making decisions that affect the whole, or a substantial part of the business or company, or who has the capacity to affect significantly the company’s financial standing), or the relevant regulator. Under the Corporations Act and the Taxation Administration Act, reports can also be made to Yurra’s auditors and actuaries as set out in Annexures A and B.

6. Investigation of Reportable Conduct

Yura will investigate reportable conduct under this policy as soon as practicable after the matter has been reported. The Yurra Independent Director may, with your consent, appoint a person to assist in the investigation of a report. Where appropriate, Yurra will provide feedback to you regarding the investigations progress and/or outcome (subject to considerations of the privacy of those against whom allegations are made). Any investigation will be conducted in an objective and fair manner, and otherwise as reasonable and appropriate having regard to the nature of the reportable conduct.  While the investigation process and enquiries adopted will be determined by the nature and substance of the report, in general, as soon as practicable upon receipt of the report, if the report is not anonymous, the Yurra Independent Director will contact you to discuss the investigation process, including who may be contacted and such other matters as are relevant to the investigation.  

When a report is submitted anonymously, Yurra may investigate based on the information provided.

7. Protection of Whistleblowers

Yurra is committed to ensuring confidentiality in respect of all matters raised under this policy and that those who make a report are treated fairly and do not suffer detriment.

1. Protection against detrimental conduct
   
   1. Detrimental treatment includes dismissal, demotion, harassment, discrimination, disciplinary action, bias, threats, or other unfavourable treatment connected with making a report. If you are subject to detrimental treatment because of making a report under this policy, you should:
      
      1. Inform a Protected Disclosure Officer, officer, or senior manager or Yurra immediately; or
      2. Raise it in accordance with this policy.
2. Protection of your identity and confidentiality
   
   1. Subject to compliance with legal requirements, upon receiving a report under this policy, Yurra will take reasonable steps to keep your identity confidential and reduce the risk of disclosure during an investigation and will only share your identity as a whistleblower or information likely to reveal your identity if:
      • You consent.
      • The concern is reported to the Australian Securities and Investments Commission (‘ASIC’), the Australian Prudentia Regulation Authority (‘APRA’), the Tax Commissioner or the Australian Federal Police (‘AFP’); or
      • The concern is raised with a lawyer for the purpose of obtaining legal advice or representation.‍
3. Protection of files and records
   
   1. All records and files created from an investigation will be retained securely.
   2. Unauthorised release of information to someone not involved in the investigation (other than senior managers or directors who need to know to take appropriate action, or for corporate governance purposes) without your consent as a whistleblower will be breach of this policy.
   3. Whistleblowers are assured that a release of information in breach of this policy will be regarded as a serious matter and will be dealt with under Yurra’s disciplinary procedures.

8. Duties of team members in relation to Reportable Conduct

It is expected that Yurra’s team members who become aware of actual or suspect on reasonable grounds, potential cases of reportable conduct, will make a report under this policy or under other applicable policies.

9. Reporting Procedures

Protected Disclosure Officers will report to the Yurra Board on the number and type of whistleblower incident reports annually, to enable Yurra to address any issues and trends are a department level. These reports will be made on a ‘no names’ basis, maintaining the confidentiality of matters raised under this policy. The Yurra Aduit & Risk Committee will receive copies of all Yurra whistleblower reports, and whistleblower reports from Protected Disclosure Officers (as appropriate).

10. Amendment and review of this policy

This policy cannot be amended without approval of the Yurra Board.  It will be reviewed form time to time to ensure that it remains effective and meets best practice standards and the needs of Yurra.