Whistle Blowing Policy

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2 Page: Page 2 of 5 1. PRINCIPLES AND PURPOSE This Whistleblower Policy documents Golden Circle Limited s commitment to maintaining a working environment in which employees and internal contractors are able to report suspected instances of unethical, unlawful or undesirable conduct without fear of intimidation or reprisal. The purpose of this Policy is to assist the Company in the detection and resolution of unacceptable conduct and to protect those persons who raise issues of potential unacceptable conduct. 2. CONDUCT COVERED BY THIS POLICY Unacceptable conduct covered by this Policy includes any conduct which potentially; Is dishonest, fraudulent or corrupt; Is criminal or breaches State or Federal Law; Is unacceptable under the Company s Code of Conduct; or Involves substantial risk to health and safety of employees or the public, and would, if proven, constitute either by the Company or its employees; An illegal act or omission; A criminal offence; or Reasonable grounds for dismissing or terminating the services of an employee that was engaged in the conduct. 3. APPLICATION OF POLICY This Policy applies to all employees, contractors and Directors of Golden Circle whether full time, part time or casual, of any level of seniority and employed or engaged as an internal staff member of the Company. 4. PROTECTION OF WHISTLEBLOWERS 4.1 Definition of Whistleblower For the purpose of this Policy, a Whistleblower is any employee, Director or internal contractor of Golden Circle who, whether anonymously or otherwise discloses or attempts to disclose allegedly unacceptable conduct in accordance with this Policy. 4.2 Protected Disclosure A Whistleblower will be protected under this Policy from reprisal or repercussions from the Company arising from the disclosure of alleged unacceptable conduct, provided that the disclosure is: made in good faith; is based on reasonable grounds; and, the disclosure is made in accordance with clause 4.3 below.

3 Page: Page 3 of Disclosing Information of Alleged Unacceptable Conduct A Whistleblower should report the alleged unacceptable conduct to the Legal Counsel, GM Human Resources or the Chairman of the Audit and Risk Committee. 4.4 Investigation Legal Counsel, GM Human Resources and the Chairman of the Audit and Risk Management Committee shall consider what further action, if any, is to be taken. If an investigation is required the investigators are independent of both the whistleblower and the person against whom the allegations have been made. If the disclosure involves allegations of criminal activity, the relevant law enforcement agency may also be involved. 4.5 Contact Details Legal Counsel can be contacted by telephone on (07) or at legalcounsel@goldencircle.com.au. GM Human Resources can be contacted by telephone on (07) or at hrmanager@goldencircle.com.au. The Chairman of the Audit and Risk Committee can be contacted by at chairauditcommittee@ goldencircle.com.au. 5. PROTECTING THE WHISTLEBLOWER Golden Circle is committed to the protection of Whistleblowers against action taken in reprisal for making protected disclosures. The Whistleblower will not be protected under this Policy if: They are involved in the unacceptable conduct, to the extent of the reasonable consequences flowing from their involvement, although an admission may be a mitigating factor when considering disciplinary or other action. The Whistleblower makes a knowingly false report regarding alleged unacceptable conduct. The giving of the knowingly false report will be considered a serious matter and render the person concerned subject to disciplinary proceedings including termination of employment. They disclose the information regarding the allegation of unacceptable conduct to anyone other than Legal Counsel, Human Resource Manager or the Chairman of the Audit and Risk Committee, except where required to disclose the information by law.

4 Page: Page 4 of 5 6. CONFIDENTIALITY 6.1 Protect Confidentiality of Identity of Whistleblower Golden Circle will use all reasonable efforts to protect the identity of the Whistleblower. 6.2 Disclosure in Certain Circumstances Golden Circle reserves the right however, to disclose: the identity of the Whistleblower; the information disclosed by the Whistleblower; and/or information that may lead to the identification of the Whistleblower, where: The Whistleblower has given their consent to the disclosure; The disclosure is required by law; The alleged unacceptable conduct relates to a contravention or possible contravention of the Corporations legislation (by reporting the alleged unacceptable conduct the Whistleblower is deemed to have given consent to the disclosure within the meaning of Section 1317AE of the Corporations Act 2001 (as amended)); The disclosure is necessary to prevent or lessen a serious threat to a person s health and safety; or it is necessary to protect or enforce legal rights or interest or to defend any claims. 6.3 Storage of Records and Access Golden Circle will ensure that all records relating to a report about unacceptable conduct are stored securely. 7. Reporting to the Audit and Risk Management Committee Any matter raised under this policy is to be reported at the next Audit and Risk Committee meeting by the Legal Counsel and or the Chairman of the Audit and Risk Committee and thereafter reported to the Committee on a quarterly basis until resolved. Any report detailing the activities under this Policy will not include the identity of the Whistleblower unless required under clause Reporting Outside of Golden Circle Limited The purpose of this Policy is to allow employees and internal contractors an avenue for the reporting of matters of concern regarding the Company within the internal structures of the Company. All employees and internal contractors are required to maintain their duties of confidentiality regarding Company information and specifically their obligation not to disclose confidential information of the Company to persons outside of the Company.

5 Page: Page 5 of 5 9. ANNUAL REVIEW This policy will be reviewed annually to ensure it complies with relevant laws and remains relevant and effective. Any proposed amendments recommended for approval must be submitted to the Audit Committee for approval.