WHISTLEBLOWER POLICY

Applies from: 1 November 2021

1. Purpose
The purpose of this policy is to outline Lion’s process for receiving, handling and investigating
whistleblower disclosures, and to ensure individuals who disclose wrongdoing can do so safely,
securely and with confidence that they will be supported by Lion and protected by law.

2. What is this policy about and what does it cover?
Lion is committed to creating a transparent workplace where our people feel empowered to raise
legitimate issues or concerns regarding misconduct. The whistleblower program is an alternate
avenue to raise concerns about our organisation and people independent from the traditional linesof management. Lion will ensure that such whistleblowers are afforded protection from subsequent
detriment.

3. Scope
This Policy applies to all employees of all Lion Business Units, regardless of gender identity,
gender expression, sexual orientation, intersex status, relationship status, ethnicity, cultural
background, age or ability.
As laws, regulations and practices can vary between geographic locations, the policy has been setout as follows:••Global Policy – this sets out the elements of the policy that applies to everyone irrespectiveof your location
Regional specific annexure – this sets out specific requirements relevant to your location(Australia, New Zealand, US or UK)

You must comply with the global policy and relevant regional specific annexure.
This policy may be updated over time. You are required to re-familiarise yourself with this policy
regularly to ensure you remain compliant.

4. Who Do I Contact if I Have Questions on This Policy
Please contact the Group Risk & Audit Director (currently Kenneth Yeo Kenneth.Yeo@lionco.com).

5. Global Policy (to be read in conjunction with the regional
specific annexures below)
The Global Policy applies to all Lion Group team members irrespective of their geographic locationand is set out on the following pages.

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6. Who is an Eligible Whistleblower?
In order to qualify for whistleblower protections, you must be a current or former:•officer or employee of the Lion Group;•contractor, or an employee of a contractor, who has supplied goods or services to the LionGroup (whether paid or unpaid);•

associate of Lion (a person with whom Lion works with to achieve a common goal); or•

the spouse, relative or dependent of one of the people referred to above.

While you must fit into one of these categories, you may choose to remain anonymous.

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7. What is Reportable Conduct?
In order to qualify for whistleblower protections, you must have reasonable grounds to suspect thatthe information you are disclosing relating to Lion concerns:•misconduct; or•an improper state of affairs or circumstances.

'Reasonable grounds' means that a reasonable person in your position would also suspect theinformation indicates misconduct or an improper state of affairs or circumstances.
This may include conduct that:•is dishonest, negligent, fraudulent, corrupt, criminal, anti-competitive or a conflict of interest;•breaches laws or regulations;•is unsafe;•

is damaging to the environment;•

is an abuse of position or authority; or•

relates to modern slavery or issues of ethical sourcing.

Please note that disclosures relating to personal work-related grievances will not attract thelegislative whistleblower protections. However, as a matter of policy at Lion, we will apply the same
protocols as defined in Section 11.
Generally, a personal work-related grievance will include:•

an interpersonal conflict with another employee;•a decision about your employment, transfer, or promotion;•a decision about the terms and conditions of your employment; or•a decision to suspend or terminate your employment or otherwise discipline you.

8. How to Make A Disclosure
Lion has established a number of confidential channels (known as “Eligible Recipients”) throughwhich you can make whistleblower disclosures. In all scenarios, you may choose to remain
anonymous.
Disclosures should contain as much detail as possible to assist with any required investigation andin reaching an appropriate outcome. While not required, providing contact details (which can beanonymous, such as email addresses which do not disclose your identity) is beneficial so that you
may be contacted.

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ChannelDetails

Enter the below website and click “log an incident/suspicion”.
Web

www.drawtheline.deloitte.com
Call one of the dedicated toll-free phone numbers, which operate 24/7.

PhoneEmail•

Australia: 1800 842 070•

New Zealand: 0800 684 788•

United States: 1-888-465-3913•United Kingdom: 0808 101 0519

Send an email to drawtheline@deloitte.com
Send a letter addressed to:
drawtheline

Post

Reply Paid 12628 A'Beckett Street
Victoria 8006, Australia

https://ml.helpline.jp/kirin-hotline/
Kirin

User ID: kirinhd
Password: compliance

Lion Representatives
If you wish to make a disclosure, but do not wish to use the above channels, the following Lion
representatives are able to take your disclosure.
•Members of the Group Leadership Team (GLT)•Group Risk & Audit Director (Kenneth Yeo, +61 2 9230 1532, Kenneth.Yeo@lionco.com)•

Audit, Finance & Risk Committee Chair (Paula Dwyer, Paula.Dwyer@lionco.com)

Whilst preferable for such disclosures to be made internally, you may also make your disclosure toan auditor of Lion, ASIC, or your lawyer and still qualify for the whistleblower protections.

9. Legal Protections for Whistleblowers
The following protections are available to whistleblowers who meet the criteria in sections 6, 7 & 8.
1. Identity Protection (Confidentiality)
The identity of a whistleblower, or information that is likely to lead to the identification of thewhistleblower, will be protected unless their consent is provided.
2. Protection from Detrimental Acts or Omissions

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Whistleblowers are legally protected from conduct that causes detriment, including threats that are
express or implied, conditional or unconditional. Examples of detrimental actions include:•

dismissal of an employee;•alteration of an employee’s position or duties to his or her disadvantage;•

discrimination between an employee and other employees of the same employer;•

harassment or intimidation of a person;•

harm or injury to a person, including psychological harm;•

damage to a person’s property;•

damage to a person’s reputation;•

damage to a person’s business or financial position; or•any other damage to a person.

Examples of actions that are not detrimental conduct include:•administrative action that is reasonable for the purpose of protecting a whistleblower fromdetriment (such as moving a whistleblower who has made a disclosure about their
immediate work area to another office to prevent them from detriment); and•managing a whistleblower’s unsatisfactory work performance, if the action is in line with
Lion’s performance management framework.

3. Compensation and Other Remedies
A whistleblower may seek compensation and other remedies if:•they suffer loss, damage or injury because of their disclosure; and•the company failed to take reasonable precautions and exercise due diligence to prevent
detrimental conduct being taken against them.

4. Civil, Criminal and Administrative Liability Protection
A whistleblower is protected from the following in respect of their eligible disclosure:•civil liability (legal action against the whistleblower for breach of an employment contract,
duty of confidentiality or another contractual obligation);•criminal liability (attempted prosecution of the whistleblower for unlawfully releasing
information, or other use of the disclosure against the whistleblower in a prosecution (otherthan for making a false disclosure)); and•administrative liability (disciplinary action for making the disclosure).

The legislative protections do not grant immunity for any misconduct a whistleblower has engaged
in that is revealed in their disclosure.

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10. Support and Practical Protection for Whistleblowers
Examples of practical mechanisms that Lion will apply to protect the confidentiality of awhistleblower and to protect them from detriment include:•

access to all information relating to a disclosure will be limited to those directly involved inmanaging and investigating the disclosure (such as the Whistleblower Committee);•disclosures will be handled and investigated by qualified staff (this may be an independent
external party, if appropriate);•

reporting of whistleblower disclosures (such as to Lion’s AF&RC) will be redacted andanonymised;•

application of Lion’s performance management framework and Achievement@Work; and•availability of support services such as the Personal Support Program (PSP).

Please be aware that individuals may be able to identify the whistleblower’s identity if:•

the whistleblower has previously mentioned to other people that they are considering
making a disclosure;•the whistleblower is one of a very small number of people with access to the information; or•the disclosure relates to information that a whistleblower has previously been told privatelyand in confidence.

11. Handling and Investigating a Disclosure
Receipt
Eligible recipients (refer to paragraphs 10 & 11 above) will accept disclosures. Details of thedisclosure will be captured, along with the preferences of the whistleblower regarding
confidentiality and anonymity.

Consideration by Lion Whistleblower Committee
The Whistleblower Committee will consider whether the disclosure is an eligible disclosure and thenext steps. The Whistleblower Committee will take reasonable steps to ensure that the identity of
the whistleblower (or information enabling their identification) is not disclosed without consent, andwill ensure that any further disclosure of details regarding the substance of the complaint arestrictly limited and only shared on a “need to know” basis for the purpose of the proper
investigation and resolution of the disclosure.

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Investigation
Depending on the nature of the disclosure, detail provided and available evidence, an investigation
plan may be developed. Such investigation will determine whether there is enough evidence tosubstantiate or refute the matters reported. It will be conducted by appropriate individuals, typicallywithin LRA, P&C, Legal or by an independent external party, if necessary.
Note that in certain circumstances an investigation will not be possible, for example if there isinsufficient detail and the whistleblower has not provided contact details for further information.

Communication
Whistleblowers will be provided with regular updates, if they can be contacted. Typically, there will
be at least three key points of communication:•

when the disclosure has been considered and an investigation process has begun or otheraction taken;•

while any investigation is in progress; and•after any investigation has been finalised.

In certain circumstances the level of detail that can be shared may be limited (for example, thenature and extent of disciplinary action), but transparency will be provided to the extent possible

Anonymised Reporting
Once the disclosure has been considered, and in the absence of a conflict of interest, relevant
members of the GLT and the AF&RC chair will be notified – such reporting of whistleblower
disclosures will be anonymised, and limited detail will be shared.
Confidential and anonymised summaries of all whistleblower disclosures are reported to theAF&RC on a quarterly basis.

12. Ensuring Fair Treatment of Individuals Mentioned
Employees mentioned in a disclosure and subject to any investigation will be treated fairly. Any
investigation will seek to determine whether there is sufficient evidence to substantiate or refute thematters reported. Employees who are the subject of a disclosure will be provided the opportunity torespond to the facts and findings derived from the investigation. Where applicable, theconfidentiality/anonymity of the whistleblower will be preserved throughout this process.

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13. Ensuring the Policy is Easily Accessible
The policy is made available externally via Lion's website.
There is an ongoing program of communication including emails from the CEO, posters at keysites and desktop wallpapers to ensure information about whistleblowing is widely disseminated ona regular basis.

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Annexure A – Australia Specific Requirements
There are no specific geographical requirements for this policy in Australia.

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Annexure B – New Zealand Specific Requirements
There are no specific geographical requirements for this policy in New Zealand.

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Annexure C – US Specific Requirements
There are no specific geographical requirements for this policy in the US.

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