Gifts & Hospitality Policy

Purpose

Wellbeing Places Equip Limited ("WBP Equip") is committed to conducting its business with integrity and independence.

This Gifts & Hospitality Policy sets out the Company's approach to the offering, giving, or receiving of gifts, hospitality, or other benefits, to ensure that business decisions are made objectively and free from improper influence.

Guiding Principles

WBP Equip applies the following principles in relation to gifts and hospitality:

• business decisions must be taken in the best interests of the Company;
• gifts or hospitality must never influence, or appear to influence, judgement;
• transparency and proportionality are essential; and
• compliance with applicable laws and ethical standards is expected at all times.

Scope

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

• directors and officers;
• employees and contractors;
• advisers and consultants; and
• others representing the Company in business dealings.

Acceptable Conduct

Reasonable and proportionate gifts or hospitality may be offered or accepted where they:

• are modest, infrequent, and appropriate to the business context;
• are not linked to any business decision or advantage;
• comply with applicable laws and local customs; and
• would not cause reputational concern if disclosed.

Unacceptable Conduct

Gifts or hospitality must not be offered or accepted where they:

• could reasonably be perceived as a bribe or inducement;
• create a conflict of interest or obligation;
• involve cash or cash equivalents; or
• are offered during sensitive decision-making processes.

Transparency and Disclosure

WBP Equip expects transparency in relation to gifts and hospitality.

Where there is uncertainty about the appropriateness of a gift or hospitality, individuals are expected to seek guidance or disclose the matter through appropriate governance channels.

Relationship with Other Policies

This Policy should be read alongside:

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

Together, these documents support ethical conduct and financial integrity.

Consequences of Non-Compliance

Failure to comply with this Policy may result in appropriate action in line with the Company's governance arrangements.

Transparency and Limitations

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

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

Review

This Gifts & Hospitality 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.