Whistleblower Policy

1. Purpose

Officeworks is committed to the highest standards of conduct and ethical behaviour in our business activities and to promoting and supporting a culture of honest and ethical behaviour, corporate compliance and good corporate governance.

Officeworks encourages reporting of suspected unethical, illegal, fraudulent or undesirable conduct involving Officeworks and provides protections and measures so that those persons who make a report may do so confidentially and without fear of intimidation, disadvantage, or reprisal.

This policy can be accessed via the Officeworks website and intranet.

2. Scope

This policy applies to all directors, officers, team members and external whistleblowers, including suppliers / tenderers and their team members and relatives.

3. Related Documents

• Whistleblower Consent Form

4. Policy

4.1. What is reportable conduct?

You may make a report under this policy if you have reasonable grounds to suspect any misconduct or improper state of affairs or circumstances (Reportable Conduct).

For example (and the following is not an exhaustive list), this might include having reasonable grounds to suspect that an Officeworks director, officer, team member, contractor, supplier, tenderer or other person who has business dealings with Officeworks has engaged in conduct which:

• is dishonest, fraudulent or corrupt, including bribery or other activity in breach of the Officeworks Anti-bribery Policy;
• is an illegal activity (such as theft, violence, harassment or intimidation, criminal damage to property or other breaches of law);
• is unethical or in breach of Officeworks' policies (such as dishonestly altering company records or data or adopting questionable accounting practices);
• is potentially damaging to Officeworks, an Officeworks team member or a third party, such as unsafe work practices, environmental damage, health risks or abuse of Officeworks property or resources;
• amounts to an abuse of authority or conflict of interest;
• may cause financial loss to Officeworks or damage its reputation or be otherwise detrimental to Officeworks' interests; or
• involves harassment, discrimination, victimisation or bullying, that is systemic or widespread and is not characterised as personal work-related grievance as defined in the Corporations Act 2001 (Cth) (Corporations Act).

Reportable Conduct generally does not include Personal Work-Related Grievances. These are grievances which relate to your current or former employment or engagement, and which has implications which affect only you. Examples include:

• a conflict between you and another team member;
• a decision relating to a promotion or transfer; or
• a decision relating to the termination of your employment.

Such matters should be raised directly with your People Leader or through your People and Capability Partner.

A personal work-related grievance may however amount to Reportable Conduct under this policy, such as where the grievance is systemic in nature and involves or affects multiple team members or relates to conduct that has been taken against a person because they made a report under this policy.

Officeworks expects that reports made under this policy are made honestly, ethically and on reasonable grounds.

4.2. Who can I make a report to?

If you have reasonable grounds to suspect or become aware of any issue or behaviour which you consider to be Reportable Conduct, Officeworks has several channels for making a report.

To ensure appropriate escalation and timely investigation, we request that reports are made to any of the following Protected Disclosure Officers (PDO's), listed below:

• Chief Financial Officer - Brendan Hargreaves
• Senior Legal Counsel - Michelle Welsh
• Head of People Operations and Advisory - Heidi Dorman

Current team members can access contact details of PDOs in SuccessFactors.

Additionally, a report may be made via the Officeworks Honesty Service, an external hotline and reporting service independently managed by Deloitte.

Honesty reporting options are:

• by phone: Free call 1800 645 127 (24 hours a day / 7 days a week)
• by email: honesty@deloitte.com.au
• web-based access: www.honesty.deloitte.com.au
• by post:

  Honesty at Officeworks
  Reply Paid 12678
  A'Beckett Street
  Melbourne VIC 8006

Deloitte will provide the details of your disclosure to a Protected Disclosure Officer. Reports may be made anonymously but if you provide your contact details to Honesty, those contact details will only be provided to the Protected Disclosure Officer if you consent. For more information, please see the Honesty at Officeworks, Whistleblower Service Information Sheet.

Under the Corporations Act and the Taxation Administration Act, reports can also be made to Officeworks external auditors and actuaries as set out in Annexures A and B.

While it is Officeworks'preference that you make a report to a Protected Disclosure Officer or through the Honesty Service, it is important to note that under the Corporations Act, you may also raise the matter with an “officer” or “senior manager” of the company. These are defined in the Corporations Act as a director, or a senior manager in the company who makes, or participates in making, decisions that affect the whole, or a substantial part, of the business of the company, or who has the capacity to affect significantly the company's financial standing.

Where a report has been made in person directly to the relevant Protected Disclosure Officer, or “officer” or “senior manager”, they may provide you with a Whistleblower Consent Form (Annexure C) for completion. This allows you to record who you made your report to and to give express consent as to which personnel in the company may be informed of your report to facilitate an investigation.

4.3. Investigating a whistleblower report

Each disclosure will be assessed to determine if it qualifies for protection under this Policy and/or any relevant whistleblower laws and, if so, the nature of investigation required.

Officeworks will assess each disclosure and, where appropriate, investigate all matters reported under this policy as soon as practicable after the matter has been reported.

A Protected Disclosure Officer may, with your consent, appoint a person to assist in the investigation of a report. Where appropriate, Officeworks will provide feedback to you regarding progress of the investigation and/or outcome, subject to considerations of the privacy of those against whom allegations are made, issues of business sensitivity and other broader legal issues.

Any investigation will be conducted in an objective and fair manner, and otherwise as is reasonable and appropriate, having regard to the nature of the alleged Reportable Conduct and the circumstances and in a manner that protects the whistleblower from identification, intimidation, disadvantage or reprisal, or threats of such conduct.

While the particular investigation process and enquiries adopted will be determined by the nature and substance of the report, in general, as soon as practicable upon receipt of the report, if the report is not anonymous, a Protected Disclosure Officer or investigator will contact you to discuss the investigation process including who may be contacted and other matters relevant to the investigation.

Where a report is submitted anonymously, Officeworks will conduct the investigation based on the information provided to it. It will therefore assist the investigation if the whistleblower retains contact with Officeworks by opening a two-way anonymous post box through the Honesty Service.

4.4. Protection of and support for whistleblowers

Officeworks is committed to maintaining confidentiality in respect of matters raised under this policy, and to providing support to those who make a report, so they are treated fairly, and do not suffer detriment.

1. Protection against detrimental conduct

   Detrimental treatment includes dismissal, demotion, harassment, discrimination, disciplinary action, bias, threats or other unfavourable treatment connected with making a report.

   If you are subjected to, or threatened with, detrimental treatment in connection with making a report under this policy you should:

   • inform a Protected Disclosure Officer, officer or senior manager immediately under this whistleblower policy; or
   • raise it in accordance with the other reporting mechanisms detailed in this policy.

2. Protection of your identity and confidentiality

   Where required, Officeworks may take such steps as are reasonably necessary to protect a whistleblower against detriment. For example, as regards a team member this may include, adapting their work or role, changing the work location or granting the employee leave pending completion or resolution of an investigation.

   Subject to compliance with legal requirements, upon receiving a report under this policy, Officeworks will take reasonable steps to keep your identity confidential and mitigate the risk of disclosure in the course of an investigation. We will only share your identity as a whistleblower or information likely to reveal your identity if:

   • you consent;
   • the concern is reported to the Australian Securities and Investments Commission (ASIC), the Australian Prudential Regulation Authority (APRA) , the Tax Commissioner, the Australian Federal Police (AFP) or state / territory police as required; or
   • the concern is raised with a lawyer for the purpose of obtaining legal advice or representation.

   Any disclosures of your identity or information likely to reveal your identity will be made on a strictly confidential basis.

3. Protection of files and records

   All files and records created during an investigation will be retained securely.

   Unauthorised release of information (other than senior managers or directors who need to know to take appropriate action, or for corporate governance purposes) without your consent as a whistleblower may be considered a breach of this policy.

   Whistleblowers are assured that an unauthorised release of information in breach of this policy will be regarded as a serious matter and will be dealt with under Officeworks' disciplinary procedures.

4. Support services

   If appropriate a whistleblower who is an employee can access the Employee Assistance Programme for further support.

4.5. Fair treatment for employee respondents

Any team member who is mentioned in a disclosure that qualifies for protection under this policy and / or any relevant whistleblower laws, or to whom such a disclosure relates, (a respondent) will be treated fairly throughout the investigation process which includes, where appropriate, provided with sufficient details of the allegations to provide a response if required including being given a reasonable opportunity to provide their version of events and / or to submit relevant evidence.

If appropriate a respondent may access the Employee Assistance Programme for further support.

4.6. Duties of team members in relation to reportable conduct

Officeworks team members who are aware of Reportable Conduct, or suspect, on reasonable grounds potential cases of Reportable Conduct, are expected to make a report under this policy or other applicable policies.

4.6. Reporting Procedures

Officeworks will report to the Officeworks Divisional Risk Committee (DRC) and Board on the number and type of whistleblower incident reports annually, to enable Officeworks to address any issues and trends.

These reports will be made on a 'no names' basis, and any information reported will be de-identified, maintaining the confidentiality of matters raised under this policy.

Serious or material Reportable Conduct will be considered by Protected Disclosure Officers for immediate referral to the Chairman of the Officeworks DRC Committee.

5. Roles and Responsibilities

6. Definitions

Please refer to the Corporation Act 2001 (Cth) and Taxation Administration Act 1953 (Cth) for the definitions of key terms. Definitions below have been extracted from the Corporations Act 2001 (Cth):

7. Awareness

This policy is published on Officeworks intranet, supplier portal and external website. It is also posted on noticeboards at Officeworks sites.

All team members are required to complete online Whistleblower training on an annual basis.

“Senior Managers” are required to complete Seminar Training on a biennial basis.

Protected Disclosure Officers and those who investigate Whistleblower reports are also provided with role specific information/awareness/training on a biennial basis.

8. Consequences of non-compliance

In the event any allegations of non-compliance with this Policy is substantiated, a broad range of appropriate and proportionate outcomes may result. This could include, but not limited to:

• Educational training or coaching;
• Formal disciplinary action up to and including termination of employment; and
• As a result could also include reduced or loss of any short term or long term incentive program eligibility, including team member bonus.

Team members and managers should escalate any concerns, both actual or suspected breaches, of this policy. If in doubt, contact the relevant People Leader or People & Capability Partner in the first instance, or alternately email RiskandCompliance@officeworks.com.au.

9. Document Information

Annexure A - Special protections under the Corporations Act¹

The Corporations Act gives special protection to disclosures about any misconduct or improper state of affairs relating to Officeworks, its officers or team members if the following conditions are satisfied:

1. the whistleblower is or has been:
   1. an officer or team member of Officeworks;
   2. an individual who supplies goods or services to Officeworks or a team member of a person who supplies goods or services to Officeworks;
   3. an individual who is an associate of Officeworks; or
   4. a relative, dependent or dependent of the spouse of any individual referred to at (a) to (c) above.

2. the report is made to:

   1. a Protected Disclosure Officer;
   2. an officer or senior manager of Officeworks;
   3. Officeworks' external auditor (or a member of that audit team)²;
   4. an actuary of Officeworks ³;
   5. ASIC;
   6. APRA; or
   7. a legal practitioner for the purpose of obtaining legal advice or legal representation in relation to the operation of the whistleblower provisions in the Corporations Act even if the advice is to the effect that the disclosure does not relate to a disclosable matter;

3. the whistleblower has reasonable grounds to suspect that the information being disclosed concerns misconduct, or an improper state of affairs or circumstances in relation to Officeworks. This may include a breach of legislation including the Corporations Act, an offence against the Commonwealth punishable by imprisonment for 12 months or more, or conduct that represents a danger to the public or financial system.

   Examples of conduct which may amount to a breach of the Corporations Act include: insider trading, insolvent trading, breach of the continuous disclosure rules, failure to keep accurate financial records, falsification of accounts, failure of a director or other officer to act with the care and diligence that a reasonable person would exercise, or to act in good faith in the best interests of the corporation or failure of a director to give notice of any material personal interest in a matter relating to the affairs of the company.

   The protections given by the Corporations Act when these conditions are met are:

   1. the whistleblower is immune from any civil, criminal or administrative legal action (including disciplinary action) for making the disclosure;
   2. no contractual or other remedies may be enforced, and no contractual or other right may be exercised, against the whistleblower for making the report;
   3. in some circumstances, the reported information is not admissible against the whistleblower in criminal proceedings or in proceedings for the imposition of a penalty ⁴;
   4. anyone who causes or threatens to cause detriment to a whistleblower or another person in the belief or suspicion that a report has been made, or may have been made, proposes to or could be made, may be guilty of an offence and may be liable for damages;
   5. a whistleblower's identity cannot be disclosed to a Court or tribunal, except where considered necessary; and
   6. the person receiving the report commits an offence if they disclose the substance of the report or the whistleblower's identity, without the whistleblower's consent, to anyone except ASIC, APRA, the AFP or a lawyer for the purpose of obtaining legal advice or representation in relation to the report.

Confidentiality

If a report is made, the identity of the discloser must be kept confidential unless one of the following exceptions applies:

1. the discloser consents to the disclosure of their identity;
2. disclosure of details that might reveal the discloser's identity is reasonably necessary for the effective investigation of the matter;
3. the concern is reported to ASIC, APRA, or the AFP; or
4. the concern is raised with a lawyer for the purpose of obtaining legal advice or representation.

Disclosures may be made anonymously and the discloser may choose to remain anonymous and remain protected under the Corporations Act.

A “public interest disclosure” or an “emergency disclosure” may be made to a journalist or a parliamentarian under certain circumstances and qualify for protection. The discloser should seek independent legal advice before making such a disclosure.

Annexure B - Special Protections under the Taxation Administration Act

The Taxation Administration Act gives special protection to disclosures about a breach of any Australian tax law by Officeworks or misconduct in relation to Officeworks' tax affairs if the following conditions are satisfied:

1. the whistleblower is or has been:
   1. an officer or team member of Officeworks;
   2. an individual who supplies goods or services to Officeworks or a team member of a person who supplies goods or services to Officeworks;
   3. an individual who is an associate of Officeworks; and /or
   4. a spouse, child, dependent or dependent of the spouse of any individual referred to at (i) to (iii) above;
2. the report is made to:
   1. a Protected Disclosure Officer;
   2. a director, secretary or senior manager of Officeworks;
   3. Officeworks' external auditor (or a member of that audit team);⁵
   4. a registered tax agent or BAS agent who provides tax or BAS services to Officeworks;⁶
   5. any other team member, or officer of Officeworks who has functions or duties relating to tax affairs of the company (e.g. an internal accountant); (Officeworks recipients)
   6. the Commissioner of Taxation; or
   7. a legal practitioner for the purpose of obtaining legal advice or representation in relation to the operation of the whistleblower provisions in the Taxation Administration Act; and
3. if the report is made to an Officeworks recipient, the whistleblower:
   1. has reasonable grounds to suspect that the information indicates misconduct, or an improper state of affairs or circumstances, in relation to the tax affairs of Officeworks or an associate of Officeworks; and
   2. considers that the information may assist the Officeworks recipient to perform functions or duties in relation to the tax affairs of Officeworks or an associate of the company; and
4. if the report is made to the Commissioner of Taxation, the whistleblower considers that the information may assist the Commissioner of Taxation, to perform functions or duties in relation to the tax affairs of Officeworks or an associate of Officeworks.

The protections given by the Taxation Administration Act when these conditions are met are:

1. the whistleblower is immune from any civil, criminal or administrative legal action (including disciplinary action) for making the disclosure;
2. no contractual or other remedies may be enforced, and no contractual or other right may be exercised, against the whistleblower for making the report;
3. where the disclosure was made to the Commissioner of Taxation, the reported information is not admissible against the whistleblower in criminal proceedings or in proceedings for the imposition of a penalty, except where the proceedings are concerned with whether the information is false;
4. unless the whistleblower has acted unreasonably, a whistleblower cannot be ordered to pay costs in any legal proceedings in relation to a report;
5. anyone who causes or threatens to cause detriment to a whistleblower or another person in the belief or suspicion that a report has been made, or may have been made, proposes to or could be made, may be guilty of an offence and liable to pay damages;
6. a whistleblower's identity cannot be disclosed to a Court or tribunal, except where considered necessary; and
7. the person receiving the report commits an offence if they disclose the substance of the report or the whistleblower's identity, without the whistleblower's consent, to anyone except the Commissioner of Taxation, the AFP or a lawyer for the purpose of obtaining legal advice or representation in relation to the report.

Confidentiality

If a report is made, the identity of the discloser will be kept confidential unless one of the following exceptions applies:

1. the discloser consents to the disclosure of their identity;
2. disclosure of details that might reveal their identity is reasonably necessary for the effective investigation of the allegations;
3. the concern is reported to the Commissioner of Taxation or the AFP; or
4. the concern is raised with a lawyer for the purpose obtaining legal advice or representation.

Annexure C - Officeworks Whistleblower Consent Form

Acknowledgement and Consent to Disclosure for Investigation and Reporting Purposes

1. I have made a disclosure of information to: _____________________________ ^*
2. I have reasonable grounds to believe the information I have disclosed is true.
3. I have received a copy of the Officeworks Whistleblower Policy. I understand that information about my complaint that is unlikely to reveal my identity can be disclosed to any other Officeworks team member or consultant without my consent.
4. I understand that if my complaint is captured under whistleblower protections set out in whistleblower laws, my identity and information that is likely to reveal my identity cannot be disclosed to any other Officeworks team member or consultant (except for legal advisers) without my consent, unless the disclosure:
   1. is made to a legal practitioner for the purpose of obtaining advice or representation in relation to whistleblower laws; or
   2. is reasonably necessary for the purposes of investigating the matter and reasonable steps are taken to reduce the risk that I will be identified.
5. I give my consent to the disclosure of my identity, under conditions of confidentiality and for the purpose of investigation and reporting, to the following people (strike out any that you do not approve to):
   • An Officeworks Director
   • Officeworks Managing Director
   • Officeworks Chief People Officer
   • Officeworks Chief Financial Officer
   • Officeworks Senior Legal Counsel/s
   • Any partner or team member of an external law firm appointed by any of the above
   • Wesfarmers' Chief Human Resources Officer
   • Wesfarmers' Managing Director
   • Wesfarmers' Chief Financial Officer
   • Wesfarmers' Group General Counsel
   • Wesfarmers' Company Secretary

Name of reporting person [print]

Signature of reporting person

Date

¹See Part 9.4AAA of the Corporations Act 2001 (Cth).

²Officeworks' external auditor as at July 2025 was Ernst & Young, Pierre Dryer Lead Partner.

³Officeworks' does not currently have an actuary.

⁴Such as where the disclosure has been made to ASIC or APRA, or where the disclosure qualifies as a public interest or emergency disclosure.

⁵Officeworks' external auditor as at July 2025 was Ernst & Young, Pierre Dryer Lead Partner.

⁶Officeworks does not currently have a tax agent.

^*Insert name of person receiving report