1.1 This Employment Ethics Policy defines the ethical standards and behavioral expectations that govern the employment relationship between the Organization and its workforce at every stage of the employee lifecycle, from recruitment and onboarding through performance management, career development, and separation. The policy is intended to ensure that all employment decisions and practices are grounded in fairness, transparency, and respect for the dignity and rights of every individual. It complements the Organization's Code of Ethics by providing specific guidance on ethical conduct within the employment context.

1.2 This policy applies to all employees, managers, supervisors, HR professionals, and senior leaders across all departments, business units, and geographic locations of the Organization. It covers ethical obligations in all employment-related decisions and processes, including hiring, compensation and benefits administration, performance evaluation, promotion and career advancement, training and development, workplace accommodations, disciplinary action, and termination. Third-party staffing agencies and contractors engaged in employment-related services on behalf of the Organization shall be contractually required to adhere to the ethical standards set forth herein.

1.3 The Head of Human Resources, or such senior HR leader as designated by the Chief Executive Officer, shall serve as the policy owner and shall bear accountability for the consistent application, interpretation, and enforcement of this policy across the Organization. The policy owner shall provide guidance to managers and employees on ethical dilemmas arising in the employment context, maintain a confidential channel for reporting concerns, and report compliance metrics and material incidents to the executive leadership team and the Board on a quarterly basis. Day-to-day administration shall be delegated to the HR Business Partners within each division.

2.1 All employment decisions, including but not limited to hiring, promotion, transfer, compensation adjustment, performance rating, disciplinary action, and termination, shall be based exclusively on legitimate, job-related criteria such as qualifications, skills, experience, performance, and business need. Decisions shall be free from bias, favouritism, nepotism, or discrimination based on race, color, gender, sexual orientation, gender identity, religion, national origin, age, disability, marital status, or any other protected characteristic. Managers shall document the rationale for all significant employment decisions and retain such documentation in accordance with the Organization's records retention policy.

2.2 The Organization is committed to ensuring pay equity across its workforce and shall conduct formal compensation audits at least annually to identify and remediate any unjustified disparities in pay or benefits based on gender, race, ethnicity, age, or other protected characteristics. The audit shall compare compensation for employees performing substantially similar work, controlling for legitimate differentiating factors such as experience, education, performance, and geographic location. Where unjustified gaps are identified, the HR department shall develop and implement a remediation plan within 90 calendar days, subject to approval by the Chief Financial Officer. Audit findings and remediation actions shall be reported to the executive leadership team and the Board's compensation committee.

2.3 Performance evaluations shall be conducted fairly, transparently, and consistently across all departments using standardised evaluation criteria and rating scales approved by the HR department. Managers shall provide employees with regular performance feedback throughout the evaluation period and shall base final ratings on documented evidence of performance against pre-established objectives. Employees shall be afforded the opportunity to provide self-assessment input, review their evaluation, and formally contest any rating they believe to be inaccurate, biased, or inconsistent with documented performance. The HR department shall maintain an appeals process for disputed evaluations, with final adjudication by the HR Business Partner and the next-level manager.

2.4 All terminations of employment, whether voluntary or involuntary, shall be handled with dignity, professionalism, and full compliance with applicable employment law and the terms of the employee's contract. Involuntary terminations shall be supported by clear, contemporaneous documentation of the grounds for dismissal, which may include sustained performance deficiency following the Organization's progressive discipline process, serious misconduct, redundancy, or other legitimate business reasons. The HR department shall review and approve all involuntary termination decisions before they are communicated to the employee, and shall ensure that the employee receives all statutory and contractual entitlements, including notice, severance, and benefits continuation where applicable. Exit interviews shall be offered to all departing employees to gather feedback and identify potential systemic issues.

3.1 The Organization is committed to maintaining a workplace environment where every individual is treated with respect, dignity, and fairness, regardless of their role, seniority, or background. The Organization values diversity of thought, experience, and perspective, and expects all personnel to engage with colleagues and stakeholders in a manner that is courteous, professional, and inclusive. Behaviors that undermine psychological safety, such as bullying, public humiliation, exclusion, microaggressions, or the abuse of positional authority, are inconsistent with the Organization's values and shall not be tolerated.

3.2 Managers and supervisors bear a heightened responsibility to model ethical behavior and to create a team environment in which employees feel psychologically safe raising concerns, providing upward feedback, questioning decisions, and reporting potential policy violations without fear of reprisal or marginalisation. The Organization shall incorporate ethical leadership competencies into management training, performance evaluations, and promotion criteria. Managers who fail to address reported concerns, who create environments of fear or silence, or who retaliate against employees exercising their rights under this policy shall be subject to disciplinary action commensurate with the severity of the failure.

3.3 The Organization shall respect employees' right to privacy in personal matters, including personal communications, medical information, financial affairs, and off-duty conduct that does not affect job performance or the Organization's legitimate interests. Where the Organization conducts workplace monitoring, including email and internet usage monitoring, CCTV surveillance, or GPS tracking of company vehicles, such monitoring shall be conducted in compliance with applicable privacy laws, disclosed to employees through a clear and accessible monitoring policy, and limited to the minimum scope necessary to achieve the stated business purpose. Employee personal data shall be collected, stored, and processed in accordance with applicable data protection legislation, and access shall be restricted to authorised personnel on a need-to-know basis.

4.1 Employees who witness or become aware of unethical employment practices, including discriminatory conduct, unfair treatment, policy violations, or any behavior inconsistent with the standards set forth in this policy, are strongly encouraged to report their concerns promptly. Reports may be made through multiple channels, including direct communication with the employee's manager or HR Business Partner, the Organization's confidential ethics hotline, or the secure online reporting portal. Anonymous reporting shall be permitted where allowed by applicable law. All reports shall be treated with strict confidentiality to the extent possible, and the Organization shall investigate each report promptly and impartially.

4.2 Violations of this Employment Ethics Policy, whether committed by employees, managers, or senior leaders, shall result in disciplinary action proportionate to the nature, severity, and recurrence of the breach. Disciplinary measures may include formal counselling and written warning, mandatory retraining, suspension of management authority, demotion, suspension from employment, or termination of employment. Senior leaders and managers shall be held to a higher standard of accountability given their influence on organizational culture and their duty to model ethical behavior. All disciplinary actions shall be documented in the individual's personnel file and reviewed by the HR department for consistency and proportionality.

4.3 This policy shall be reviewed comprehensively at least once every 12 months by the policy owner in consultation with Legal Counsel, the Ethics and Compliance department, and senior HR leadership. Reviews shall assess the policy's effectiveness, alignment with current legislation and regulatory guidance, consistency with the Organization's evolving values and culture, and feedback received through employee surveys, exit interviews, and reported concerns. Amendments shall be approved by the Head of Human Resources and the Chief Executive Officer, communicated to all personnel at least 14 calendar days before the effective date, and acknowledged through the Organization's HR information system. A version history shall be maintained documenting all amendments.

5.1 All employees and managers shall complete mandatory employment ethics training within 30 calendar days of their hire date and on an annual basis thereafter. Training shall cover the key provisions of this policy, ethical decision-making frameworks for employment-related scenarios, unconscious bias awareness and mitigation strategies, reporting mechanisms and whistleblower protections, and case studies illustrating common ethical dilemmas in the employment context. The HR department shall track training completion rates and report compliance metrics to the executive leadership team quarterly. Employees who fail to complete training within the prescribed timeframe shall receive escalating reminders, and persistent non-compliance shall be reflected in the individual's performance evaluation.

5.2 The Organization shall maintain accessible resources to support employees and managers in navigating ethical challenges in the employment context. These resources shall include an employment ethics handbook summarising key principles and expectations, decision-making guides with practical scenarios and recommended actions, an FAQ document addressing common questions, and a dedicated point of contact within the HR or Ethics and Compliance department who can provide confidential guidance. Resources shall be available on the Organization's intranet and updated at least annually. The Organization shall also promote ethical awareness through periodic communications, town halls, and leadership messages that reinforce the importance of ethical conduct in all employment practices.

5.3 Managers and supervisors shall receive additional targeted training on their heightened ethical responsibilities under this policy, including fair and unbiased performance evaluation practices, equitable decision-making in hiring, promotion, and compensation, the obligation to create psychologically safe team environments, the duty to escalate reported concerns appropriately and without delay, and the consequences of managerial non-compliance. This additional training shall be completed within 60 calendar days of the individual's appointment to a management role and refreshed annually. The Organization shall incorporate ethical leadership metrics into the management competency framework and evaluate managers on their ethical conduct as part of the annual performance review process.