Whistleblower Policy

Purpose

This policy aims to reinforce Talent’s culture of open communication, as well as encourage and support staff to speak up and report corrupt, illegal or unacceptable conduct.

Talent has established this policy in order to promote a healthy and balanced culture of compliance throughout all areas of our business, to demonstrate our commitment to our corporate governance obligations and protect whistleblowers from retaliation or adverse action as a result of disclosing reportable conduct.

Scope

This policy applies to all Talent employees, contractors, volunteers, interns and consultants.

This policy complements Talent’s Code of Conduct, which serves as a guide to what is expected of everyperson that works at Talent.

What is reportable conduct?

Reportable conduct includes but is not limited to activities that are in breach of Talent’s Code of Conduct, or that are otherwise:

• illegal
• corrupt;
• fraudulent;
• dishonest;
• unethical;
• unlawful;
• any activity that puts the health or safety of an individual in danger;
• constituting misconduct or an improper state of affairs or circumstances;
• having the potential to cause financial or non-financial loss to Talent; or
• might otherwise be detrimental to the interest of Talent, the public or the financial system.

Examples of reportable conduct include bribery, money laundering, improper use of company property or funds, or the use of improper accounting, internal control, actuarial, audit or tax methods.

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Disclosing reportable conduct

In the event you become aware of reportable conduct at Talent, you may disclose this by speaking with your manager, Managing Director, CFO or People and Culture- whomever you feel most comfortable speaking with.

All requests for anonymity will be respected, however there may be instances where disclosure of your identity is required by law.

Your report will then be assessed and referred to the appropriate person or regulator for investigation as per the Investigating Reportable Conduct procedure below. You may communicate with regulators at any time in relation to reportable conduct.

Talent is committed to protecting whistleblowers from retaliation or adverse action asa result of making a report. All whistleblowers will be protected to the full extent required by law.

Talent’s Board will review the effectiveness of this Whistleblowers Policy, and will hold the Chief Financial Officer accountable for its implementation and effectiveness.

Investigating reportable conduct

Your report will be allocated to the most appropriate person or business unit for investigation, this may include People and Culture, the CFO or external advisors.

It will then be handled in a confidential manner, having regard to any potential conflicts of interest or concerns you may have. You may be contacted to provide further information.

The allocated investigator will be responsible for ensuring investigations are carried out in a thorough and effective manner.

You may express any concerns about the process or the possibility of retaliation at any time. Retaliation against a whistleblower is unlawful and will not be tolerated. Support is also available via our Employee Assistance Program.

All investigations will be conducted in a lawful and respectful manner, free from prejudice against all parties, and anyone that discloses reportable conduct will be given feedback, subject to any privacy, confidentiality or legal concerns.

Protection for Whistleblowers

Talent is committed to protecting all whistleblowers from retaliation or adverse action as a result of reporting a matter.

Where a whistleblower reports conduct in good faith and is eligible for protection under any laws, Talent will ensure this protection is provided.

Talent will ensure that this Whistleblower Policy is accessible to all staff on the Talent intranet, and will take reasonable steps to ensure all employees are aware of, and understand the Whistleblower Policy, and the behaviours that are reportable via induction procedures and training.