Code of Conduct

1. Purpose

This Code of Conduct establishes the minimum standards of professional behaviour and ethical conduct expected of all people working at or for ASI AI Solutions. It provides a framework for decision-making that reflects our values: Integrity, Innovation, Collaboration, Accountability, and Respect.

The Code supports our obligations under the Fair Work Act 2009 (Cth) and underpins a safe, inclusive, and productive workplace.

2. Scope

This policy applies to all directors, officers, employees (permanent, fixed-term, and casual), contractors, consultants, work experience participants, and volunteers of ASI AI Solutions (collectively, "Workers"). It applies during all work-related activities, including travel, social events, client engagements, and online interactions connected to the Company.

3. Professional Behaviour

3.1 General Expectations

All Workers are expected to:

• Act honestly, ethically, and with integrity in all professional dealings.
• Treat colleagues, clients, partners, and members of the public with courtesy, dignity, and respect.
• Perform their duties with care, skill, and diligence to the best of their ability.
• Comply with all applicable laws, regulations, industry standards, and Company policies.
• Raise concerns and report wrongdoing through the appropriate channels without fear of retaliation.
• Maintain a professional standard of dress and presentation appropriate to their role and work context.

3.2 Respectful Workplace

ASI AI Solutions is committed to maintaining a workplace free from bullying, harassment, discrimination, and victimisation. All Workers must:

• Refrain from behaviour that is offensive, intimidating, humiliating, or threatening.
• Respect individual differences, including cultural, religious, gender, and neurological diversity.
• Use inclusive and respectful language at all times, including in digital communications.
• Comply with the Anti-Discrimination & Harassment Policy.

4. Conflicts of Interest

4.1 Obligation to Disclose

Workers must avoid situations where their personal interests conflict, or could reasonably appear to conflict, with the interests of the Company. A conflict of interest arises where a personal relationship, financial interest, or outside activity could impair, or be perceived to impair, a Worker's objectivity or loyalty.

4.2 Examples

• Having a direct or indirect financial interest in a client, supplier, or competitor of the Company.
• Engaging in outside employment or business activities that compete with the Company.
• Participating in procurement or hiring decisions involving a family member or close personal associate.
• Accepting favours, commissions, or inducements from third parties in connection with Company business.

4.3 Disclosure and Management

Workers must promptly disclose any actual, potential, or perceived conflict of interest in writing to their manager and the People & Culture team. Conflicts will be assessed on a case-by-case basis. Management strategies may include reassignment of duties, exclusion from decision-making, or divestment of the conflicting interest.

5. Use of Company Resources

5.1 General

Company resources — including but not limited to equipment, IT systems, email, internet, software, cloud infrastructure, premises, vehicles, stationery, and corporate credit cards — are provided for business purposes. Limited reasonable personal use is permitted, provided it:

• Does not interfere with work duties or productivity.
• Does not incur unreasonable cost to the Company.
• Does not compromise the security or integrity of Company systems.
• Does not breach any law or Company policy.

5.2 IT and Cybersecurity

Workers must comply with the Company's IT Acceptable Use Policy and Cybersecurity Policy. In particular:

• Passwords must be unique, complex, and never shared.
• Multi-factor authentication must be enabled on all Company systems.
• Suspicious emails, messages, or system activity must be reported immediately to the IT Security team.
• Company data must not be stored on unapproved personal devices or cloud services.
• AI models and training data must only be accessed through authorised channels and environments.

5.3 Financial Responsibility

Workers entrusted with Company funds or financial authority must exercise prudent stewardship. All expenditure must be properly authorised, documented, and in accordance with the Delegations of Authority framework.

6. Social Media Policy

6.1 Personal Use

Workers are free to engage in personal social media activity, but must not:

• Represent their personal views as those of the Company.
• Disclose confidential or proprietary information about the Company, its clients, or employees.
• Post content that could damage the Company's reputation or commercial interests.
• Engage in conduct that would breach this Code, the Anti-Discrimination & Harassment Policy, or any applicable law.

6.2 Official Company Accounts

Only authorised Workers may post content on official ASI AI Solutions social media channels. All official posts must be approved by the Marketing team and comply with the Social Media Style Guide.

6.3 Identifying as an Employee

Where a Worker identifies themselves as an ASI AI Solutions employee on social media (e.g., LinkedIn), they should include a disclaimer such as: "Views are my own and do not represent the views of ASI AI Solutions."

7. Gifts, Entertainment & Hospitality

7.1 Receiving Gifts

Workers may accept gifts, meals, or entertainment of modest value (up to $150 AUD per occasion) where the offer is:

• Made in the normal course of business and is proportionate.
• Not intended or perceived to influence a business decision.
• Not cash or cash equivalents (e.g., gift cards are not permitted).

Gifts exceeding $150 must be declared to the People & Culture team and recorded in the Gifts Register. Where appropriate, they may be donated to a team or charity.

7.2 Giving Gifts

Workers must not offer gifts, entertainment, or hospitality to any government official or client representative that could constitute or be perceived as a bribe or inducement. All gifts offered on behalf of the Company must comply with the Company's Anti-Bribery and Corruption obligations and the Criminal Code Act 1995 (Cth).

7.3 Government Officials

Any engagement or hospitality involving government officials must be pre-approved by the General Counsel or Chief Operating Officer.

8. Reporting Violations

8.1 Obligation to Report

All Workers have a responsibility to report any breach or suspected breach of this Code. Reports can be made to:

• The Worker's direct manager.
• The People & Culture team (people@asiaisolutions.com.au).
• A member of the Executive Leadership Team.
• The Company's confidential Whistleblower Service (details available on the Company intranet).

8.2 Whistleblower Protection

The Company is committed to protecting Workers who make reports in good faith. In accordance with the Corporations Act 2001 (Cth) and the Treasury Laws Amendment (Enhancing Whistleblower Protections) Act 2019, no Worker will be subjected to retaliation, detriment, or disadvantage for making a protected disclosure. Refer to the Company's Whistleblower Policy for further information.

8.3 Investigation

All reports will be treated seriously and investigated promptly, impartially, and confidentially to the extent reasonably practicable. Workers involved in an investigation are required to maintain confidentiality and cooperate fully.

9. Consequences of Breach

Potential consequences include:

• Informal counselling — for minor or first-time breaches, a conversation and written record.
• Formal written warning — documented warning placed on the personnel file.
• Final written warning — issued for repeated or more serious breaches.
• Demotion, transfer, or loss of responsibilities — where continued placement is inappropriate.
• Summary dismissal — for serious misconduct, including fraud, theft, violence, serious harassment, or gross negligence, in accordance with the Fair Work Act 2009.

The Company's disciplinary process will be procedurally fair. The Worker will be given the opportunity to respond to any allegations before a final decision is made, and may bring a support person to any disciplinary meeting.

10. Responsibilities

11. Review

This Code of Conduct will be reviewed annually, or sooner if required by changes to legislation, best practice, or business operations. The People & Culture team is responsible for coordinating the review.