Conflicts of Interest Policy

Purpose

Wellbeing Places Equip Limited ("WBP Equip") is committed to conducting its business in a manner that is fair, transparent, and free from improper influence.

This Conflicts of Interest Policy sets out the Company's approach to identifying, disclosing, and managing actual or potential conflicts of interest to protect the integrity of decision-making and maintain stakeholder confidence.

What Is a Conflict of Interest

A conflict of interest may arise where an individual's personal, professional, or financial interests could:

• influence, or appear to influence, their judgement or actions on behalf of the Company; or
• conflict with the interests of WBP Equip.

Conflicts may be actual, potential, or perceived, and all three are taken seriously.

Who This Policy Applies To

This Policy applies to individuals acting on behalf of WBP Equip, including:

• directors and officers;
• employees and contractors;
• advisers and consultants; and
• others engaged in decision-making or representation of the Company.

Examples of Conflicts

Conflicts of interest may include (by way of example):

• personal or financial interests in a supplier, partner, or competitor;
• outside roles or engagements that overlap with Company interests;
• relationships that could affect objectivity or independence;
• receipt of benefits or inducements that could influence judgement; or
• involvement in decisions where an individual has a competing interest.

This list is illustrative and not exhaustive.

Disclosure and Management

WBP Equip expects individuals to:

• disclose any actual or potential conflict of interest promptly; and
• cooperate with reasonable steps to manage or mitigate the conflict.

The Company may take proportionate steps to address conflicts, which may include:

• recording disclosures;
• restricting involvement in certain decisions; or
• applying other safeguards appropriate to the circumstances.

Governance and Oversight

Oversight of conflicts of interest forms part of the Company's wider governance and compliance framework.

Senior leadership is responsible for ensuring that conflicts are handled transparently and in a manner consistent with ethical and legal expectations.

Relationship with Other Policies

This Policy should be read alongside:

• the Code of Business Conduct & Ethics;
• the Whistleblowing & Speaking Up Policy; and
• the Anti-Money Laundering & Financial Crime Awareness Statement.

Together, these documents support ethical conduct and responsible governance.

Raising Concerns

If an individual is uncertain whether a situation constitutes a conflict of interest, they are encouraged to raise the matter through appropriate governance or reporting channels.

Concerns raised in good faith will be treated seriously and without retaliation.

Transparency and Limitations

This Policy provides a high-level overview of the Company's approach to conflicts of interest.

Detailed internal procedures and registers are maintained separately and are not disclosed publicly for confidentiality and governance reasons.

Review

This Conflicts of Interest Policy 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.