Supplier Code of Conduct

Table of Contents

1. Purpose and Scope

This Supplier Code of Conduct ("Code") sets out the minimum standards that all suppliers of ("Estia Health") are expected to meet and adhere to, reﬂecting our commitment to conduct business ethically, responsibly, and with the utmost respect for human rights.

This Code applies to all suppliers, contractors, consultants, agents and other providers of goods and services ("Suppliers") who do business with Estia Health.
By entering into a contract with Estia Health, Suppliers agree to make all reasonable endeavours to:

comply with this Code and
ensure that their employees, subcontractors, and agents also adhere to its principles.

Suppliers are expected to read and consider Estia Health's core values, policies, and guidelines outlined on the website.

The expectations outlined in this Code do not supersede or alter a Suppliers’ legislative, policy, regulatory or other contractual obligations or create any contractual rights for Suppliers or third parties. In the event of any inconsistency, the terms of the applicable contract or law prevail.

2. Legal and Regulatory Compliance

2.1 Suppliers must comply with all applicable laws, regulations, and standards, including but not limited to the Aged Care Act 2024 (Cth), Aged Care Rules 2025 (Cth), the Statement of Rights and those relating to privacy, competition, taxation, anti-corruption, environment, Modern Slavery legislation, Work Health and Safety (WHS) legislation, discrimination laws, employment laws, and if appropriate ASX and ASIC reporting requirements, Task Force on Climate-Related Financial Disclosures (TCFD) reporting, and best practice sustainability commitments.

2.2 Suppliers shall promptly inform Estia Health of any changes in legal requirements that may impact their compliance obligations under this Code or of any regulatory investigation, enforcement notice or material breach relevant to this Code.

3. Ethical Conduct and Integrity

3.1 Suppliers shall maintain the highest standards of ethical conduct and integrity in all aspects of their business activities.

3.2 Suppliers are encouraged to align with ESG principles proportionate to their size and risk profile, including environmental stewardship, ethical labour practices, inclusion and transparent governance.

3.3 Suppliers shall avoid any actual or potential conﬂicts of interest, including personal, financial or business relationships that may compromise their ability to act in the best interests of Estia Health or their ability to fulﬁl their contractual obligations. Where conﬂicts do arise, Suppliers should disclose them promptly in writing to Estia Health and work to resolve them responsibly and to Estia Health’s reasonable satisfaction.

3.4 Suppliers shall not engage in any form of bribery, corruption, or unethical business practices. Suppliers must commit to fair competition and business practices. This includes compliance with all applicable laws and regulations related to competition and trade practices, and avoiding any form of anti- competitive behaviour, such as collusion, cartel behaviour, or abuse of market power.

3.5 Suppliers must ensure timely and fair payment of subcontractors and comply with applicable security of payment and fair contracting legislation.

4. Human Rights, Labour and Fair Work Practices

4.1 Suppliers must ensure that no modern slavery, forced labour, child labour, or any form of human traﬃcking, abuse or exploitation exists within their operations or their supply chains and take proactive measures to assess and address modern slavery risks.

4.2 Suppliers shall provide fair and safe working conditions, including fair wages, reasonable working hours, and adequate health and safety measures, in compliance with applicable laws and regulations.

4.3 Suppliers should maintain policies and support mechanisms to assist employees affected by domestic and family violence, including awareness training and confidential reporting channels.

4.4 Suppliers must respect and uphold human rights in all of their operations, including freedom of association and the right to collective bargaining. Suppliers should promote equal opportunities for all and support diversity and inclusion.

4.5 Suppliers must undertake due diligence to identify, assess and address modern slavery risks in their operations and supply chains, and report suspected cases to Estia Health.

5. Health, Safety and Wellbeing

5.1 Suppliers shall prioritise the health, safety, and welfare of their employees and take proactive measures to ensure a safe working environment. This includes having appropriate systems in place to prevent accidents and harm to health arising out of, linked with, or occurring in the course of work, including incident reporting, training and continuous safety improvement.

5.2 Suppliers shall implement policies and procedures to prevent bullying, harassment, and discrimination in the workplace based on factors such as race, colour, religion, gender, sexual orientation, age, disability, or any other protected characteristic.

5.3 Suppliers shall promptly address and investigate any reported incidents of bullying, harassment, or discrimination and take appropriate corrective actions.

5.4 Suppliers shall provide training and awareness programs to their employees to promote a respectful and inclusive work environment.

6. Worker Screening and Suitability at Estia Health Sites

6.1 Suppliers must comply with all WHS/OHS requirements applicable to Estia Health sites.

6.2 Suppliers must ensure that all personnel who may access Estia Health sites or residents are appropriately screened and cleared under all applicable aged care worker screening, police check and suitability assessment requirements. Suppliers must ensure that personnel are not subject to exclusion decisions or banning orders under the Aged Care Act 2024 or Aged Care Rules 2025.

6.3 Suppliers must comply with all infection control requirements, immunisation directives, and public health orders and ensure that all personnel undertake infection prevention training consistent with Estia Health policy when visiting an Estia Health site.

7. Environmental Responsibility and ESG

7.1 Suppliers shall implement environmentally responsible practices throughout their operations and supply chain, including responsible sourcing, waste management, natural resource use, energy eﬃciency, and emissions reduction.

7.2 Suppliers shall comply with all applicable environmental laws and regulations and work towards continuous improvement in their environmental performance. Where feasible, Suppliers should also strive to use renewable resources, promote biodiversity, and support the transition to a low-carbon economy.

7.3 Suppliers should actively contribute to Estia Health’s environmental sustainability objectives, including the transition to a low carbon economy, waste reduction, energy efficiency, climate resilience and responsible sourcing.

7.4 Suppliers must establish and maintain a documented contingency plan addressing climate-related risks that could impact sourcing and delivery. This plan should identify potential climate risks, outline mitigation and adaptation strategies, and ensure continuity of supply. Suppliers must review and update this plan annually and provide a copy to Estia Health upon request.

8. Product Quality and Safety

8.1 Suppliers should ensure that their products and services are safe, reliable, ﬁt for purpose, and meet all relevant regulatory requirements and industry best practices. They should be transparent and proactive in reporting any quality issues or defects that could impact Estia Health and should take prompt action to resolve them.

8.2 Suppliers shall promptly address any product quality or safety issues and cooperate with Estia Health in implementing eﬀective recall procedures and product safety processes and cooperate with Estia Health on open disclosure where quality or safety issues affect residents or services, if necessary.

8.3 Where relevant, Suppliers must comply with applicable animal welfare legislation and ensure humane treatment and ethical sourcing of animal products.

9. Privacy, Data Protection and Cybersecurity

9.1 Suppliers shall maintain the conﬁdentiality and security of all sensitive information or data, including conﬁdential, proprietary, and personal information relating to Estia Health.

9.2 Suppliers should implement robust systems and processes to secure such information, prevent unauthorised access or disclosure, and ensure compliance with all applicable privacy and data protection laws, ensuring that sensitive is collected, processed, stored, transferred, and disposed of securely and appropriately.

9.3 Suppliers must comply with Estia Health’s Privacy Policy, available on our website at Privacy Policy | Estia Health and ensure that all handling of personal and sensitive information aligns with that Policy and the Privacy Act 1988 (Cth).

9.4 Suppliers should only use sensitive information for the purpose for which it was provided and should not be used for personal gain or any other improper purpose.

9.5 Suppliers must segregate Estia Health data from other client data, store personal information in Australia and not allow offshore access without Estia Health’s prior written approval.

9.6 Any access to Estia Health data, systems or digital environments must be secure and protected from cyber incidents, unauthorised access or data breaches. Suppliers must notify Estia Health immediately of any suspected or actual data breach or cyber security incident affecting Estia Health information and cooperate in containment, assessment and notification steps.

10. Artificial Intelligence, Data Ethics and Emerging Technologies

10.1 Suppliers must ensure that any use of artificial intelligence, machine learning, data analytics or automated decision-making tools in connection with Estia Health is conducted lawfully, transparently and ethically.

10.2 Suppliers must not use Estia Health data or resident information to train or test AI systems without Estia Health’s prior approval in writing.

10.3 All AI driven or automated solutions must include human oversight, accountability and explainability measures consistent with Estia Health’s data governance and privacy requirements.

10.4 Suppliers must promptly disclose to Estia Health any use of AI or algorithmic tools that may influence service delivery, decision making or data management.

11. Supply Chain Integrity

11.1 Suppliers should strive to promote the principles of this Code within their own supply chains. Suppliers are encouraged to engage with their suppliers in a constructive and collaborative manner, to improve their social, environmental, and ethical performance.

11.2 They should monitor their direct suppliers for compliance with applicable laws and ethical standards and should take appropriate action where non-compliance is identiﬁed.

11.3 Suppliers must promptly report and cooperate in investigations concerning any actual or suspected non-compliance, including reportable incidents, breaches of law or unethical conduct.

12. Business Continuity

Suppliers must maintain business continuity, disaster recovery and crisis management plans appropriate to the nature and scale of their goods or services. These plans must ensure continuity of supply during significant disruptions, including but not limited to, natural disasters, pandemics, cyber incidents or supply chain interruptions.

13. Monitoring

13.1 Suppliers should establish appropriate management systems and controls to ensure compliance with this Code.

13.2 Estia Health or an agent acting on its behalf, reserves the right to monitor Supplier compliance with this Code through audits, assessments, or any other reasonable means.

13.3 Suppliers must cooperate with Estia Health's monitoring activities, audits or assessments including providing access to relevant facilities, records, and personnel.

13.4 Suppliers must report any non-compliance with this Code to Estia Health immediately. In the event of non-compliance, the Supplier must develop and implement a corrective action plan to remediate the issue promptly.

13.5 Non-compliance with this Code may result in various consequences, depending on the nature and severity of the violation. This may include requests for corrective action, suspension of current work, termination of the business relationship, and potential legal action.

14. Incident Reporting, Complaints and Whistleblowing

14.1 Suppliers shall maintain an appropriate means for their employees and other relevant parties to raise concerns or queries relating to the conduct of the business. Suppliers should create an environment where employees feel comfortable raising concerns without fear of retaliation.

14.2 Suppliers shall implement appropriate measures to promptly address any reported concerns and take appropriate corrective actions.

14.3 Suppliers, employees of Suppliers or sub-contractors are able raise concerns about any actual or suspected breach of this Code by email to procurement@estiahealth.com.au
Estia Health will treat all reports conﬁdentially, investigate them thoroughly and impartially, and take appropriate corrective action.

14.4 Estia Health also operates a conﬁdential “Say Something” whistleblower Hotline Service as an additional method of support to raise whistleblowing concerns of suspected or actual misconduct, including breaches of the Code. This service is run by an independent third-party provider. Concerns can also be raised anonymously without giving any personal information.

Concerns can be raised via email, online through the website, by phone or by email to:

Phone: 1300 304 550
Email: estiahealth@stopline.com.au
Website: https://saysomething.stoplinereport.com/
Postal address: Attention: Estia Health, c/o Stopline, PO Box 403, Diamond Creek, VIC 3089, Australia

15. Conclusion

By doing business with Estia Health, Suppliers conﬁrm their acceptance of this Code and commit to uphold its principles. Estia Health believes in fostering a transparent, ethical, and sustainable supply chain. This Code serves as a guide to our values and expectations, and we appreciate our suppliers' commitment to upholding these standards.

This Code is a living document and Estia Health reserves the right to periodically review and amend the Code to ensure it continues to align with evolving societal expectations, legal requirements, and best practices in corporate responsibility and sustainability. When we make changes, we will upload the revised Code to our website. The updated version will be effective from the time it is posted (unless stated otherwise). We will include a “last updated” date on the Code for reference.

We encourage Suppliers to review the Code to periodically to stay informed If you have any questions or concerns about any changes, please contact us.

Within the context of this Code references to "Estia Health" and "we," "us" and "our" are references to entities in the Estia Health Group. These include:
Estia Health Pty Ltd, Estia Investments Pty Ltd, Estia Finance Pty Ltd, Estia Health Residential Aged Care Pty Ltd, Estia Health BidCo Pty Ltd, Estia Health HoldCo Pty Ltd, Estia Health MidCo Pty Ltd and Estia Health TopCo Pty Ltd