Code of Business Conduct & Ethics

Purpose

Wellbeing Places Equip Limited ("WBP Equip") is committed to conducting its business with integrity, professionalism, and respect for the law.

This Code of Business Conduct & Ethics ("the Code") sets out the standards of behaviour expected of those acting on behalf of the Company and reflects the values that guide decision-making, relationships, and risk awareness.

Our Ethical Standards

WBP Equip expects all those associated with the Company to act:

• honestly and in good faith;
• with professionalism and care;
• in a manner that protects the Company's reputation; and
• in accordance with applicable laws, regulations, and ethical norms.

Ethical conduct is viewed as a core business requirement, not an optional standard.

Compliance with Law and Regulation

The Company expects compliance with all applicable legal and regulatory obligations relevant to its activities, including those relating to:

• corporate governance and company law;
• data protection and information security;
• anti-bribery, fraud, and financial crime awareness; and
• fair dealing and competition.

No individual is expected or permitted to breach the law to achieve business objectives.

Conflicts of Interest

Those acting for or on behalf of WBP Equip should avoid situations where personal interests could conflict, or appear to conflict, with the interests of the Company.

Any actual or potential conflict of interest should be disclosed appropriately so that it can be considered and managed transparently.

Gifts, Hospitality, and Inducements

WBP Equip seeks to conduct its business free from improper influence.

Gifts, hospitality, or other benefits should never be offered or accepted where they could reasonably be perceived to influence business judgement or decision-making.

Use of Company Assets and Information

Company assets, including information, technology, and intellectual property, must be used responsibly and for legitimate business purposes.

Confidential information must be protected, and improper use or disclosure is not acceptable.

Fair Dealing and Professional Behaviour

WBP Equip seeks to deal fairly with investors, partners, suppliers, advisers, and other stakeholders.

The Company does not tolerate dishonest, misleading, or unethical behaviour in its business dealings.

Speaking Up and Ethical Concerns

WBP Equip encourages individuals to raise concerns about unethical behaviour, misconduct, or breaches of this Code.

Concerns raised in good faith are taken seriously and handled in accordance with the Company's whistleblowing and governance arrangements.

Accountability

Responsibility for ethical conduct rests with everyone acting on behalf of WBP Equip.

Senior leadership is expected to lead by example and to promote a culture in which ethical behaviour and accountability are embedded.

Transparency and Limitations

This Code provides a high-level statement of ethical expectations.

Detailed internal procedures, controls, and disciplinary processes are maintained separately and are not disclosed publicly.

Review

This Code of Business Conduct & Ethics is reviewed periodically to ensure it remains appropriate to the Company's activities and governance framework.

All revisions must be approved by the Board and recorded in the Policy Register.