CoinPort Pty Ltd
Workplace Health & Safety & Code of Conduct Policy
Document Number: CP-GOV-001
Version: 3.0
Effective Date: 12-May-2025
Review Date: 12-May-2026

1.0 POLICY STATEMENT

CoinPort is committed to providing a safe, healthy, inclusive, and professional work environment that respects the dignity and rights of all individuals. This integrated policy affirms our dual commitment to the physical and psychological health and safety of our people, and to the highest standards of ethical and professional conduct. All employees, contractors, directors, and visitors are expected to uphold these principles in all business activities.

2.0 PURPOSE & SCOPE

This policy applies to all CoinPort personnel, regardless of location (including offices, remote work locations, and business travel), and to all third parties representing the company. It outlines our obligations under the Work Health and Safety Act 2011 (Cth) and relevant state regulations, and establishes the behavioural standards required to maintain trust, integrity, and a positive workplace culture.

PART A: WORKPLACE HEALTH & SAFETY (WHS)

3.0 WHS COMMITMENT & FRAMEWORK

CoinPort will, so far as is reasonably practicable:

  • Provide and maintain a work environment without risks to health and safety.
  • Provide safe systems of work, equipment, and substances.
  • Implement procedures for effective hazard identification, risk assessment, and control.
  • Provide necessary information, instruction, training, and supervision.
  • Monitor the health of workers and conditions at the workplace.
  • Maintain a process for consultation and resolution of WHS issues.

4.0 ROLES & RESPONSIBILITIES

  • CEO & Senior Management: Accountable for providing leadership, resources, and fostering a proactive safety culture.
  • Managers & Team Leads: Responsible for implementing WHS procedures within their teams, ensuring safe work practices, and addressing hazards promptly.
  • All Personnel (Employees & Contractors): Must:
    • Take reasonable care for their own health and safety and that of others.
    • Follow WHS instructions, policies, and procedures.
    • Report hazards, incidents, near-misses, and injuries immediately.
    • Participate in WHS consultation and training.
  • Designated WHS Officer: Coordinates WHS activities, maintains records, and facilitates consultation.

5.0 KEY PROCEDURES

  • 5.1 Hazard Reporting: All hazards (e.g., faulty equipment, ergonomic issues, security concerns, psychosocial risks) must be reported immediately via the internal Hazard Report Form or to a manager.
  • 5.2 Incident Reporting & Investigation: All injuries, illnesses, near-misses, and security incidents must be reported within 24 hours. All incidents will be investigated to determine root cause and prevent recurrence.
  • 5.3 Ergonomic Assessments: All employees are entitled to a workstation ergonomic assessment upon commencement and upon request. Remote employees must comply with the Remote Work Safety Protocol.
  • 5.4 Mental Health & Psychosocial Safety:
    • We are committed to preventing workplace bullying, harassment, and undue stress.
    • Managers are trained to identify signs of psychological distress.
    • All employees have access to the Employee Assistance Program (EAP) for confidential counselling.
  • 5.5 Emergency Procedures: All personnel must familiarise themselves with emergency evacuation plans, assembly points, and warden roles for their location.

PART B: CODE OF CONDUCT

6.0 CORE VALUES & EXPECTATIONS

All CoinPort representatives must act with:

  • Integrity: Be honest, ethical, and trustworthy in all dealings.
  • Respect: Treat everyone with dignity, fairness, and courtesy, valuing diversity and inclusion.
  • Accountability: Take responsibility for your actions, decisions, and performance.
  • Professionalism: Demonstrate competence, diligence, and a commitment to quality.
  • Compliance: Adhere to all applicable laws, regulations, and company policies.

7.0 SPECIFIC STANDARDS OF BEHAVIOUR

7.1 Workplace Relationships & Harassment

  • We maintain a workplace free from harassment, bullying, discrimination, and victimisation based on race, gender, age, disability, sexual orientation, religion, or any other protected attribute.
  • Prohibited Conduct: Includes offensive jokes, derogatory comments, intimidation, unwelcome sexual advances, inappropriate physical contact, and the display of offensive materials.

7.2 Conflicts of Interest

  • Employees must avoid situations where personal interests conflict, or appear to conflict, with their duties to CoinPort.
  • Disclosure: Any actual or potential conflict (e.g., external employment, financial interest in a client/competitor, close personal relationship with a client) must be disclosed in writing to your manager and the Chief Compliance Officer immediately.

7.3 Confidentiality & Intellectual Property

  • Employees must safeguard all confidential information belonging to CoinPort, its clients, and partners, both during and after employment.
  • Intellectual Property created in the course of employment is the sole property of CoinPort.

7.4 Protection of Company Assets

  • Company assets (physical, financial, digital, and intellectual) are to be used responsibly, primarily for business purposes, and protected from loss, theft, or misuse.

7.5 External Communications & Social Media

  • Public statements on matters related to CoinPort must only be made by authorised spokespersons.
  • Employees must not disclose confidential information or make derogatory, defamatory, or misleading comments about the company, colleagues, or clients on social media.
  • Personal social media use must not imply company endorsement.

7.6 Gifts, Entertainment, & Anti-Bribery

  • The offering or acceptance of gifts, hospitality, or benefits that could influence, or appear to influence, business decisions is strictly regulated.
  • Procedure: Gifts or entertainment exceeding AUD $100 in value must be declared and require approval from the CCO. Bribes, kickbacks, or facilitation payments are absolutely prohibited.

7.7 Regulatory Compliance & Reporting Misconduct

  • All personnel must comply with the specific policies governing our regulated activities: AML/CTF, Market Conduct, Privacy, and Cybersecurity.
  • Whistleblower Protection: CoinPort has a Whistleblower Policy that provides protections for eligible whistleblowers who report misconduct in good faith. Reports can be made anonymously via the secure hotline or to designated officers.

8.0 BREACHES OF POLICY & DISCIPLINARY ACTION

  • Adherence to this policy is a fundamental condition of employment.
  • Suspected breaches will be investigated promptly, fairly, and confidentially.
  • Depending on the severity, breaches may result in disciplinary action, up to and including termination of employment, and may be reported to relevant authorities.

9.0 ACKNOWLEDGEMENT & TRAINING

All employees must confirm they have read, understood, and agree to abide by this policy. Mandatory training on WHS and the Code of Conduct is provided during onboarding and through annual refreshers.

EMPLOYEE ACKNOWLEDGEMENT

I, [Employee Name], acknowledge that I have received, read, and understood the CoinPort Workplace Health & Safety & Code of Conduct Policy. I agree to comply fully with its terms and understand that failure to do so may result in disciplinary action.

Signature: ________ Date: _____

Approvals:

Chief Executive Officer: KentKingsley Date: 12-May-2025

Chief Financial Officer: Peter Cooney Date: 12-May-2025