Whistleblower Policy

At  Mount Burgess Mining NL and its subsidiary companies, we value integrity, transparency, and accountability in all aspects of our operations. This policy outlines our commitment to providing a safe and confidential mechanism for employees, contractors, suppliers, and other stakeholders to report concerns about unethical, illegal, or improper conduct within the organization.

This Policy is designed to comply with the whistleblower protection provisions under Part 9.4AAA of the Corporations Act 2001 (Cth), including the rights and obligations of eligible whistleblowers.

Scope

This policy applies to all employees, contractors, suppliers, and individuals associated with Mount Burgess Mining NL and its subsidiary companies, including board members and volunteers. It encompasses any concerns related to fraud, corruption, misconduct, violations of laws or regulations, or any other unethical or improper behaviour within the organization.

Responsibilities

Management:

Management is responsible for fostering a culture of openness and accountability within the organization and ensuring that all reports of misconduct are taken seriously and investigated promptly.
They must designate a whistleblower protection officer or team responsible for receiving and handling whistleblower reports in accordance with this policy and relevant laws and regulations.
Management should provide training and resources to employees and other stakeholders to raise awareness of the whistleblower policy and encourage the reporting of concerns.
Whistleblower Protection Officer/Team:

The whistleblower protection officer or team is responsible for receiving and processing whistleblower reports in a confidential and impartial manner.
They must ensure that whistleblowers are protected from retaliation or victimisation for making a report in good faith and that appropriate measures are taken to safeguard their confidentiality and anonymity, if requested.
The whistleblower protection officer or team should conduct thorough and impartial investigations into reported concerns and take appropriate action to address any wrongdoing identified.
Employees and Stakeholders:

All employees and stakeholders are encouraged to report concerns about unethical, illegal, or improper conduct within the organization without fear of reprisal or retaliation.
They may make a report through designated channels, such as the whistleblower hotline, email, or in person to the whistleblower protection officer or team. As of 10 September 2025 the Protection Officer is Mrs Jan Forrester – email mtb@mountburgess.com.
Employees and stakeholders should provide as much detail as possible when making a report, including specific incidents, individuals involved, and any supporting evidence or documentation.

Policy Guidelines

Disclosable Matters: A disclosable matter is information that an eligible whistleblower has reasonable grounds to suspect concerns misconduct or an improper state of affairs or circumstances in relation to:

Mount Burgess Mining NL or a related body corporate, or
the tax affairs of Mount Burgess Mining NL or an associate.
Disclosable matters include, but are not limited to:

breaches of corporate, financial or tax laws,
dishonest, fraudulent, or corrupt conduct,
bribery or misuse of company funds,
illegal conduct (e.g. theft, violence, harassment, criminal damage),
conduct that represents a danger to the public or financial system,
conduct likely to cause financial or reputational harm to the company,
systemic issues with company practices or internal controls.
Disclosable matters do not include personal work-related grievances, unless they have broader implications or are linked to victimisation of a whistleblower. Personal grievances (e.g. interpersonal conflicts, dissatisfaction with pay or performance outcomes) should be handled under the company’s grievance procedures.

Eligible Whistleblower: For the purposes of this Policy and in accordance with the Corporations Act 2001 (Cth), an eligible whistleblower is any individual who is, or has been, any of the following in relation to Mount Burgess Mining NL or its related entities:

an officer (including directors and company secretaries),
an employee (current or former),
a contractor or supplier (including their employees),
an associate of the company,
a relative, dependent, or spouse of any of the above individuals.
Confidentiality: Whistleblower reports will be treated with the utmost confidentiality, and the identity of the whistleblower will be protected to the fullest extent possible, consistent with the need to conduct a thorough investigation.

Non-Retaliation: Mount Burgess Mining including its subsidiaries prohibits retaliation or victimisation against whistleblowers for making a report in good faith. Any form of retaliation against a whistleblower will be treated as a serious violation of company policy and may result in disciplinary action, up to and including termination of employment.

Fair Treatment: Whistleblowers will be treated fairly and impartially throughout the investigation process, and their concerns will be addressed promptly and appropriately.

Investigation: All whistleblower reports will be investigated promptly, thoroughly, and impartially by the whistleblower protection officer or team. Investigations will be conducted in accordance with established procedures and principles of natural justice.

Follow-Up: Whistleblowers will be kept informed of the progress and outcome of the investigation to the extent possible, while still maintaining confidentiality and protecting the rights of all parties involved.

Reporting Process

Internal Reporting: Whistleblowers may make a report internally through designated channels, such as the whistleblower hotline, email, or in person to the whistleblower protection officer or team.

External Reporting: Whistleblowers who believe that their concerns have not been adequately addressed internally or who wish to report anonymously may make a report to external authorities, such as regulatory agencies or law enforcement, in accordance with applicable laws and regulations.

Protection of Identity: Whistleblowers who wish to remain anonymous may do so, and their identity will be protected to the fullest extent possible under the law. However, anonymous reports may limit the ability to conduct a thorough investigation.

Review and Updates

This policy will be reviewed periodically to ensure its effectiveness and compliance with Australian legislative requirements and best practices in whistleblower protection. Updates may be made as necessary to reflect changes in laws, regulations, or organizational procedures.

Authorised by

Jan Forrester

Company Secretary

MOUNT BURGESS MINING NL

12 September 2025