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FORTUNA IDENTITY PTY. LTD.

LABOUR POLICY

Version 1.0

1. PURPOSE

Fortuna Identity Pty. Ltd. ("Fortuna" or the "Company") is committed to maintaining a lawful, safe, inclusive, and productive workplace. This Labour Policy establishes the minimum standards, rights, responsibilities, and workplace practices applicable to all employees, contractors, temporary workers, interns, and consultants engaged by the Company in Australia.

This Labour Policy shall be read in conjunction with:

• Fair Work Act 2009 (Cth);

• National Employment Standards (NES);

• Applicable Modern Awards;

• Victorian Equal Opportunity Act 2010 (Vic);

• Occupational Health and Safety Act 2004 (Vic);

• Privacy Act 1988 (Cth);

• Company Policies and Employment Agreements.

Where any provision of this Labour Policy conflicts with applicable legislation, the legislation shall prevail.

2. SCOPE

This Labour Policy applies to:

• Full-time employees;

• Part-time employees;

• Casual employees;

• Fixed-term employees;

• Labour hire personnel;

• Contractors and consultants where expressly incorporated into their engagement terms.

3. EQUAL EMPLOYMENT OPPORTUNITY

Fortuna is an equal opportunity employer.

Employment decisions including recruitment, promotion, remuneration, training, transfer, discipline, and termination shall be based solely on merit, qualifications, skills, experience, and business requirements.

Discrimination, harassment, victimisation, bullying, or adverse action based on any protected attribute is strictly prohibited.

Protected attributes include, but are not limited to:

• Age;

• Sex;

• Gender identity;

• Sexual orientation;

• Race;

• Nationality;

• Disability;

• Pregnancy;

• Marital status;

• Family responsibilities;

• Religion;

• Political opinion;

• Union membership.

Any employee who experiences or witnesses discrimination or harassment must promptly report the matter.

4. EMPLOYMENT CLASSIFICATION

Workers shall be classified in accordance with:

• Applicable employment agreements;

• Relevant Modern Awards;

• Fair Work Act requirements.

The Company shall ensure proper classification of employees and contractors to avoid worker misclassification.

Independent contractors shall not be engaged where the actual nature of the relationship constitutes employment.

5. RECRUITMENT AND ONBOARDING

The Company shall:

• Conduct fair recruitment processes;

• Verify identity and work rights;

• Conduct background verification where permitted by law;

• Obtain required employment documentation;

• Issue written employment contracts before commencement.

Employees must provide accurate information during recruitment and onboarding.

Providing false information may constitute serious misconduct.

6. HOURS OF WORK

Unless otherwise agreed in writing:

• Full-time employees work 38 ordinary hours per week;

• Part-time employees work agreed hours;

• Casual employees work as rostered.

Reasonable additional hours may be required where permitted by law.

Employees may refuse unreasonable requests to work additional hours.

Working arrangements shall comply with:

• NES;

• Applicable Awards;

• Enterprise Agreements.

7. WAGES AND REMUNERATION

Fortuna shall:

• Pay employees at least the applicable minimum wage;

• Comply with Award rates where applicable;

• Provide legally required payslips;

• Make superannuation contributions in accordance with law;

• Maintain accurate payroll records.

Unauthorised deductions from wages are prohibited.

Intentional wage underpayment is strictly prohibited and may result in disciplinary action against responsible personnel.

8. LEAVE ENTITLEMENTS

Eligible employees are entitled to leave in accordance with applicable legislation.

These may include:

8.1 Annual Leave

Paid annual leave accrues in accordance with the NES.

8.2 Personal / Carer's Leave

Employees may access personal leave when ill or caring for an immediate family member.

8.3 Compassionate Leave

Employees are entitled to compassionate leave where applicable.

8.4 Parental Leave

Eligible employees may access parental leave in accordance with statutory requirements.

8.5 Family and Domestic Violence Leave

Employees shall receive entitlements prescribed by law.

8.6 Long Service Leave

Long service leave shall be provided in accordance with Victorian legislation.

9. FLEXIBLE WORK ARRANGEMENTS

Eligible employees may request flexible working arrangements.

Requests shall be considered reasonably and in accordance with the Fair Work Act.

Flexible work arrangements may include:

• Remote work;

• Flexible start and finish times;

• Compressed work schedules;

• Part-time arrangements.

10. WORKPLACE HEALTH AND SAFETY

The Company is committed to providing a safe and healthy workplace.

The Company shall:

• Identify and manage workplace risks;

• Provide safe systems of work;

• Provide necessary training;

• Investigate incidents;

• Maintain emergency procedures.

Employees must:

• Follow safety instructions;

• Use safety equipment appropriately;

• Report hazards immediately;

• Cooperate with workplace safety measures.

Serious safety breaches may result in disciplinary action.

11. WORKPLACE CONDUCT

Employees shall:

• Act honestly and professionally;

• Treat colleagues, clients, and stakeholders respectfully;

• Avoid conflicts of interest;

• Comply with Company policies;

• Protect Company assets and information.

The following conduct may constitute misconduct:

• Bullying;

• Harassment;

• Discrimination;

• Insubordination;

• Unauthorised disclosure of confidential information;

• Theft or fraud;

• Workplace violence.

12. CONFIDENTIALITY AND DATA PROTECTION

Employees shall maintain strict confidentiality regarding:

• Client information;

• Candidate information;

• Employee records;

• Commercial information;

• Trade secrets;

• Security information.

Confidential information shall not be disclosed except where authorised or legally required.

Employees must comply with:

• Privacy Act 1988 (Cth);

• Company Privacy Policy;

• Information Security Policies.

Confidentiality obligations survive termination of employment.

13. USE OF COMPANY SYSTEMS

Company technology resources shall be used primarily for legitimate business purposes.

Employees shall not:

• Access unlawful content;

• Circumvent security controls;

• Install unauthorised software;

• Share credentials.

The Company reserves the right to monitor systems to the extent permitted by law.

14. PERFORMANCE MANAGEMENT

Fortuna is committed to supporting employee performance and development.

Where performance concerns arise, the Company may implement:

• Coaching;

• Training;

• Performance Improvement Plans (PIPs);

• Formal warnings.

Employees shall be afforded procedural fairness before disciplinary decisions are made.

15. DISCIPLINARY ACTION

Disciplinary action may include:

• Verbal warnings;

• Written warnings;

• Final warnings;

• Suspension;

• Termination of employment.

Serious misconduct may result in summary dismissal.

Examples include:

• Fraud;

• Theft;

• Assault;

• Serious safety breaches;

• Deliberate confidentiality breaches.

16. GRIEVANCE PROCEDURE

Employees may raise workplace concerns without fear of retaliation.

Grievances should be raised with:

1. Immediate Supervisor;

2. Human Resources;

3. Senior Management.

All grievances shall be investigated fairly and confidentially.

Victimisation of employees who raise concerns is prohibited.

17. WHISTLEBLOWER PROTECTION

Employees who report misconduct in good faith shall be protected from retaliation.

Reports may relate to:

• Fraud;

• Corruption;

• Safety breaches;

• Legal non-compliance;

• Financial misconduct.

The Company shall maintain confidentiality to the extent permitted by law.

18. CONSULTATION ON MAJOR WORKPLACE CHANGE

Where required by applicable Awards, Enterprise Agreements, or legislation, the Company shall consult affected employees regarding significant workplace changes.

Such changes may include:

• Restructures;

• Redundancies;

• Technological changes;

• Major operational changes.

19. TERMINATION OF EMPLOYMENT

Employment may end through:

• Resignation;

• Redundancy;

• Retirement;

• Expiry of fixed-term employment;

• Termination by the Company.

Minimum notice periods shall comply with:

• Fair Work Act;

• Applicable Awards;

• Employment Agreements.

Accrued statutory entitlements shall be paid upon termination.

Company property must be returned before final separation.

20. REDUNDANCY

Where a position becomes genuinely redundant, the Company shall comply with all consultation, notice, and redundancy obligations imposed by law.

Redeployment opportunities shall be considered where reasonably available.

21. RIGHT TO DISCONNECT

Employees are generally not required to monitor, read, or respond to work communications outside ordinary working hours unless:

• Their role reasonably requires after-hours availability;

• Emergency circumstances exist;

• On-call arrangements apply.

Managers must respect employees' personal time and avoid unreasonable out-of-hours contact.

22. RECORD KEEPING

The Company shall maintain employment records as required by law.

Employees may access personal employment records in accordance with applicable legislation and Company policies.

23. BREACHES OF THIS LABOUR POLICY

Any breach of this Labour Policy may result in disciplinary action up to and including termination of employment.

24. REVIEW

This Labour Policy shall be reviewed at least annually or whenever legislative changes require amendment.

Approved By:
Board of Directors
Fortuna Identity Pty. Ltd.

Effective Date: July 2026
Review Date: June 2027
Version: 1.0

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