You are encouraged to report your concerns openly (i.e. by identifying yourself) but, if preferred, you may do so anonymously.

In choosing to identify yourself, you may provide Flow Power Group with greater ability to follow up on your report, seek any additional information or clarification required and, ultimately, to close the report out with you.   Please note, however, that in closing out a report with you, we are likely to be very limited in what we can disclose.

If you have disclosed, or agreed to disclose, your identity to a Responsible Manager, your identity will not be shared with any other person or body without your express permission (except as provided for in clause 8 of this Policy).

If you prefer to remain anonymous, you may send your report to a Flow Power Group Responsible Manager by post.   Alternatively, you may wish to contact our Whistleblower Service. The Whistleblower Service can accept reports over the phone, via email, post or fax, or via a confidential portal.  If you choose to send your report by email, we recommend not using your work email address for this purpose.

In the event you choose anonymity, we ask you to be cognisant of the fact that investigations can sometimes be hampered or stalled by a lack of information or detail.

Where possible, and particularly if you have chosen to remain anonymous, you should include the following information:

• Description of the suspected or alleged incident or alleged breach (‘alleged breach’)
• Date (at least approximately) and time (if possible) of the alleged breach
• Name(s) of individual or individuals committing the alleged breach
• Any action you may have taken to address the alleged breach
• Name(s) of any internal and external parties impacted, or potentially impacted by the alleged breach
• Name(s) of any individuals you believe may have witnessed or otherwise been party to the alleged breach
• Any evidence you may have, e.g. emails, documentation, photos, etc.

Those able to receive reports under this policy are called Responsible Managers.   The Responsible Managers are listed below:

Matthew van der Linden

Director

matthew@flowpower.com.au

D:  + 61 3 9069 8898

Lachlan Jacobson

Chief Financial Officer

lachlan.jacobson@flowpower.com.au

D:  + 61 3 9069 1245

David O’Connor

General Manager, Human Resources

david.oconnor@flowpower.com.au

D:  + 61 3 9069 1221

6.2.1 Stopline – Independent Whistleblower Service
In addition to the above, Flow Power Group has engaged the services of Stopline, an independent Whistleblower reporting service.

The Whistleblower Service reporting options include:

Phone: 1300 30 45 50 (in Australia)

Fax:     Flow Power, C/- Stopline + 61 3 9882 4480

Email:   flowpower@stopline.com.au

On-line: https://flowpower.stoplinereport.com

Mail:     Flow Power, C/- Stopline

PO Box 403

Diamond Creek   Vic   3089

App:     Smart phone app – ‘Stopline365’ (free download from Apple iTunes and Google Play)

You can learn more about this service in clause 6.3 below.

6.2.2 Certain matters can be reported to our auditors
In the event the matter relates to Flow Power Group finances or tax, you may choose to make your report to a Responsible Manager, the Whistleblower Service or, alternatively, you can choose to contact Flow Power Group’s auditors instead.   The contact details for our auditors are below:

Brock Mackenzie

Partner

Grant Thornton

brock.mackenzie@au.gt.com

D +61 3 8663 6273

M +61 407 439 677

If you feel uncomfortable or unable to report concerns internally, you can make a report via our external and independent whistleblowing service provider, Stopline (“Whistleblower Service”). The Whistleblower Service acts as an intermediary, giving Whistleblowers the ability to remain anonymous, whilst giving Flow Power Group the means to obtain further information if required. Responsible Managers will be informed of reports received by the Whistleblower Service.

Whilst we would prefer that you disclose your identity in order to facilitate any investigation, you are not required to identify yourself to either Stopline or to the Flow Power Group.  In the event you choose to remain anonymous to Flow Power Group, you will not be named in any report to Flow Power Group unless you have expressly consented to your identity being disclosed. The important thing to remember is that you are in control.  That is, your choice will be respected.

In most instances, it will be the responsibility of a Responsible Manager to undertake any required investigation.  However, there may be circumstances where the Whistleblower Service is engaged to conduct the investigation.   Regardless of how the investigation is conducted, you will be able to receive updates through the Whistleblower Service, however there will be limitations on what can be disclosed to you.

In the event your report relates to a Responsible Manager, the Whistleblower Service will exclude that Responsible Manager from all communications when reporting the matter to Flow Power Group.  All Responsible Managers have a strict duty of confidentiality.

If your report relates to all Responsible Managers, the Whistleblower Service will refer the report directly to Flow Power Group’s General Counsel, Jonathan Mitchell, who will act as the alternative Responsible Manager in that instance.  The Whistleblower Service remains the independent intermediary at all times and will only communicate with our General Counsel as necessary.

Once a report has been received, a determination will be made as to whether there is sufficient information or grounds to undertake an investigation.  Where it is determined that an investigation can or should be undertaken, the investigation will be conducted as soon as practicable and will be carried out confidentially, sensitively and thoroughly.

To help the investigation, you may be asked for further information or for clarification on your report.  Other individuals may also need to be spoken to, however, your identity will not be disclosed to them or to anyone else unless you specifically provide consent for us to do so.

In order to preserve confidentiality for all parties, it is also imperative that you, as Whistleblower, maintain confidentiality.

The nature of the investigation is likely to vary depending on the nature of the concern raised but will generally involve:

• Interviewing you (where you have disclosed your identity)
• Interviewing the person or persons who are alleged to have committed the act(s)
• Interviewing any witnesses named by you, or the person or persons alleged to have committed the act(s)
• A review of any evidence or documentation provided by you, any named witnesses or the person(s) alleged to have committed the act(s)

Once all information has been received and properly considered:

• A determination will be made; and
• You will be advised that the investigation has been concluded.

If appropriate, and subject to any applicable confidentiality, privacy or legal constraints, you may be notified of the action taken.  The information provided to you will likely to be limited to a high level outcome, examples of which are below:

• The report was substantiated and appropriate action has been taken
• The report was not substantiated and no further action will be taken unless further evidence comes to light
• It wasn’t possible to make a determination and no action will be taken unless further evidence comes to light

If, after 60 days, you reasonably believe that no action has been taken on your report, we encourage you to contact the Responsible Manager, or independent third party, that you initially reported the matter to.   If you feel uncomfortable doing so or don’t feel satisfied with their response, you may wish to contact an alternative Responsible Manager, the Whistleblower Service or, in the case of financial or tax matters, Flow Power Group’s auditors.

Even though a Whistleblower may be implicated in the Reportable Conduct, that person must not be subjected to any actual or threatened detrimental action taken in reprisal for reporting that Reportable Conduct. However, reporting Reportable Conduct will not necessarily shield the Whistleblower from the consequences flowing from involvement in the Reportable Conduct itself. A person’s liability for their own conduct is not affected by their disclosure of that conduct under this Policy (though in some circumstances, an admission of complicity in the Reportable Conduct may be a mitigating factor when considering disciplinary or other action).

Flow Power Group takes its obligations to all parties seriously and will apply principles of procedural fairness and natural justice to the conduct of any investigation and findings arising under this Policy.

The possible outcomes are varied depending on the nature of the report and the resultant findings.   However, possible outcomes could include, but not necessarily be limited to:

• Change to, or tightening of, a process, technology access or security
• Where a breach of this Policy is determined to have occurred, disciplinary action (up to and including termination of employment)
• Where illegal activity has occurred, reporting the offending individual(s) to the relevant authorities (where civil or criminal remedies may apply). The individual may also be subject to disciplinary action (up to and including termination of employment)
• A determination that no further action is required.