Policy Manual (EDP 001 PTY LTD)

1.) GOVERNANCE POLICY
This policy establishes the governance framework and ethical standards that guide the Company’s operations and decision-making processes.

1.1 Purpose and Scope
The Governance Policy applies to all Board members, senior management, employees, officers, consultants, contractors, and representatives of EDP 001 PTY LTD. It establishes a framework for ethical decision-making, accountability, and transparency in all business operations.

1.2 Core Governance Principles
• Transparency: All business transactions and decisions shall be conducted openly and documented appropriately
• Accountability: All personnel are responsible for their actions and decisions
• Integrity: All activities must be conducted with honesty and ethical behavior
• Compliance: All operations shall comply with applicable laws and regulations

1.3 Formal Company-wide Ethics and Anti-Bribery Policy
The Company maintains a formal, comprehensive Anti-Bribery and Corruption Policy that applies to all personnel. This policy is reviewed annually and updated as necessary to reflect changes in regulatory requirements and business practices. All personnel are required to acknowledge receipt and understanding of this policy upon hire and annually thereafter.

1.4 Reporting Hotline
The Company provides an ethics hotline managed by a qualified external party. Personnel may report suspected violations of Company policies or legal/regulatory requirements without fear of retaliation. The hotline will be answered by a trained staff member during office hours. Hotline: 0871352393

1.5 Reporting and Investigation Procedures
All reports of suspected policy violations are reviewed promptly and investigated thoroughly. The Company maintains confidentiality to the extent possible and prohibits any retaliation against good faith reporters. Investigations are documented and findings are communicated to relevant parties.

1.6 Training and Communication
The Company conducts regular training programmes to communicate this policy and related compliance requirements to all employees. Training covers ethics, anti-corruption principles, reporting procedures, and consequences of violations. All personnel are expected to participate in mandatory training.

1.7 Gifts, Hospitality, and Sponsorships Policy
The Company has established a comprehensive gifts, hospitality, and sponsorships policy. All gifts and hospitality offered to or received from business partners, government officials, clients, or other third parties must comply with this policy. Gifts of significant value require prior approval from management.
 
2) ANTI-CORRUPTION AND FRAUD POLICY
This policy establishes the Company’s commitment to maintaining ethical business practices and preventing corruption and fraudulent activities.

2.1 Prohibition on Bribery and Corruption
The Company strictly prohibits all forms of bribery and corruption. Personnel shall not, either directly or indirectly, offer, promise, give, authorize, or facilitate the provision of anything of value to any person with the intent to improperly influence any decision, action, or transaction to secure an improper advantage.

2.2 Compliance with Anti-Corruption Regulations
The Company complies with all national and international anti-bribery regulations and anti-corruption laws. Personnel must familiarize themselves with these requirements and ensure their conduct aligns with these standards at all times. Violations may result in criminal and civil liability.

2.3 Trade Regulations and Compliance
The Company complies with all applicable trade regulations, import regulations, sanctions, and embargoes. All transactions must comply with applicable trade law requirements, and any concerns regarding potential violations must be reported immediately.

2.4 Anti-Money Laundering Compliance
The Company complies with all applicable laws and regulations designed to combat money laundering activities. Personnel must not knowingly be party to any transaction or activity that facilitates money laundering or conceals the source of funds.

2.5 Financial Records and Documentation
The Company maintains complete and accurate financial records and reports in accordance with international laws and regulations. All transactions must be properly documented and recorded in a timely and accurate manner. Financial records must clearly reflect the true nature and business purpose of each transaction.

2.6 Fair Competition and Anti-Trust Compliance
The Company competes fairly and ethically in all markets. Personnel shall comply with all applicable competition and anti-trust laws. The Company prohibits illegal monopolistic behavior, price fixing, market allocation, bid rigging, and other anticompetitive practices.

2.7 Reporting and Consequences
Violations of this policy may result in disciplinary action, up to and including termination of employment or engagement. Additionally, violations may result in civil or criminal liability and referral to relevant authorities.
 
3) LABOUR & HUMAN RIGHTS POLICY
This policy establishes the Company’s commitment to respecting human rights and maintaining fair labour practices across all operations.

3.1 Human Rights Commitment
The Company is committed to respecting internationally recognised human rights. We recognise the importance of treating all individuals with dignity and respect and are dedicated to supporting and maintaining human rights throughout our organisation.

3.2 Non-Discrimination and Equal Opportunities
The Company is committed to providing equal opportunities and non-discrimination in employment. All personnel policies include:
• Policy on sexual, racial harassment, bullying, and threats
• Policy on non-discrimination and equal opportunities in recruitment, promotion, and treatment
• Commitment to creating a workplace free from discrimination based on race, colour, religion, gender, sexual orientation, national origin, or disability

3.3 Child Labour and Forced Labour
The Company has a strict policy against child labour and forced labour. We do not employ any person under the legal minimum working age and do not engage in or support any form of forced or compulsory labour.

3.4 Freedom of Association
Employees are free to join or form trade unions and workers’ organisations of their own choosing and engage in collective bargaining, in accordance with applicable laws. The Company respects workers’ rights to collective representation.

3.5 Working Hours and Overtime
The Company complies with all applicable laws regarding working hours and overtime. We maintain policies ensuring that working hours are reasonable and that overtime is compensated fairly. Employees are entitled to adequate rest periods.

3.6 Fair Compensation
The Company’s pay is equal to or above the legally regulated minimum wage for all employees in all countries of operation. We are committed to providing fair and equitable compensation.

3.7 Workplace Grievances
The Company maintains procedures to report and investigate workplace complaints. Mechanisms are in place to allow workers to collectively voice concerns related to labour conditions and other workplace grievances, including discrimination. All reports are handled confidentially and promptly.

3.8 Compliance Certifications
The Company maintains up-to-date SA8000 or ETI social compliance standard certifications to assure compliance with labour regulations and standards.
 
4) HEALTH & SAFETY POLICY
The Company maintains a comprehensive health and safety policy that is regularly updated to reflect changes in regulations, industry standards, and operational requirements. All employees are required to adhere to health and safety procedures and report any workplace hazards or incidents to management immediately.
 
5) ENVIRONMENTAL POLICY
The Company maintains an environmental policy that is designed to ensure compliance with applicable environmental laws and regulations. The policy covers environmental protection, sustainable practices, and responsible management of resources.
 
6) CERTIFICATIONS & COMPLIANCE POLICY
The Company endeavors to align its compliance policies with those of the customer to whom we are contracted to provide services. This ensures consistency in standards and facilitates seamless integration with our customers’ governance frameworks.

6.1 Technology and Systems
The Company deploys the GoMotion platform for beneficiaries’ records management. The platform is able to integrate with most ERP systems, enabling efficient data management and streamlined operational processes across multiple systems.
 
7) INCLUSION, DIVERSITY & EQUITY POLICY
This policy establishes the Company’s commitment to fostering an inclusive workplace that values diversity and promotes equity for all employees and stakeholders.

7.1 Diversity and Inclusion Commitment
The Company is committed to creating and maintaining an inclusive workplace culture that welcomes and values individuals from diverse backgrounds, experiences, and perspectives. We recognise that diversity strengthens our organisation and enhances our ability to serve our stakeholders effectively.

7.2 Supplier Diversity Program
The Company has established a supplier diversity program that actively seeks partnerships with diverse suppliers. We encourage and support the development of business relationships with suppliers from underrepresented groups.

7.3 B-BBEE Contributor Status
The Company is proudly a Level 1 B-BBEE contributor. This rating is valid until October 2026 and has been issued by EMPOWERDEX, demonstrating our commitment to advancing inclusion, diversity, and economic empowerment within our organisation and supply chain.

7.4 Policies and Efforts
The Company implements the following policies and efforts in respect to Inclusion, Diversity, and Equity:
• Inclusive recruitment and hiring practices
• Equal opportunity for advancement and professional development
• Regular diversity and inclusion training for all employees
• Employee resource groups and mentoring programs
• Pay equity assessments and adjustments
• Supplier diversity initiatives

7.5 Accountability and Measurement
The Company regularly measures and reports on diversity metrics to assess progress toward inclusion and equity goals. Senior leadership is held accountable for advancing these objectives.
 
GENERAL POLICY PROVISIONS

Training and Awareness
The Company provides regular training and awareness programs on all policies to ensure all personnel understand their responsibilities and obligations. Training is mandatory and documented.

Reporting and Investigation
The Company encourages personnel to report any suspected violations through appropriate channels. All reports are investigated promptly, and confidentiality is maintained to the extent possible. Retaliation against good faith reporters is strictly prohibited.

Consequences of Violation
Violations of these policies may result in disciplinary action, up to and including termination of employment or engagement. Additionally, violations may result in civil or criminal liability and referral to relevant authorities.

Policy Review and Updates
These policies will be reviewed periodically and updated as necessary to reflect changes in law, regulations, or the Company’s business practices. Personnel will be notified of any material changes to these policies.