Ethical Conduct Policy

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

The Ethical Conduct Policy is to encourage suppliers, contractors, customers or any other party to raise any concerns and report instances of unethical, illegal, fraudulent or undesirable conduct, where there are reasonable grounds to suspect such conduct, without fear of intimidation, disadvantage or reprisal.

SWD relies on the parties that it does business with to help the company achieve its commitment to a culture of honest and ethical behaviour, corporate compliance, and good corporate governance. For SWD, the failure to report actual or suspected incidents of Unethical Conduct will be treated seriously and may adversely affect the ongoing business relationship.

Unethical Conduct covered by this Policy includes any conduct of a director, officer, employee, contractor or third party, whether actual or suspected, including:

Ethical Conduct Policy  dishonest, fraudulent, corrupt or illegal conducts;

Ethical Conduct Policy  unethical actions or behaviours (including bribe, facilitation payment or other kickbacks,

Ethical Conduct Policy  inappropriate gifts; falsifying documents or other unacceptable or unethical behaviour);

Ethical Conduct Policy  actions that have the potential to damage SWD property, people, or reputation or that of another party (such as unsafe work practices, environmental damage, health risks or substantial wasting of company resources); or

Ethical Conduct Policy  abuse of authority, threats, intimidation, or harassment.

Reporting Unethical Conduct

While the person reporting the issues may wish to remain anonymous, if contact details are not provided, sufficient details will need to be included in the report to allow the matter to be investigated. SWD will investigate all reports of Unethical Conduct on a timely, thorough, confidential, objective, and fair manner (subject to considerations of the privacy of those against whom allegations are made).

Unethical Conduct can be reported to:

Ethical Conduct Policy  the employee’s immediate supervisor

Ethical Conduct Policy  the employee’s manager

Ethical Conduct Policy  another senior person

These matters will be confidentially referred to the SWD Managing Director.

DOCUMENT NO. 210303-003