Gifts & Hospitality Policy

Purpose

WBP Equip is committed to conducting its business with integrity and independence. This policy sets out our approach to the offering and acceptance of gifts, hospitality, and other benefits, to ensure that business decisions are made on merit and free from improper influence.

Guiding Principles

All individuals associated with WBP Equip are expected to:

• act in the best interests of the Company at all times;
• not allow gifts or hospitality to influence — or appear to influence — business judgement;
• maintain transparency in all dealings; and
• comply with applicable laws, including anti-bribery and corruption legislation.

Scope

This policy applies to all directors, employees, contractors, advisers, and consultants acting on behalf of, or in connection with, the business of WBP Equip.

Acceptable Conduct

Gifts and hospitality may be acceptable where they are:

• modest, reasonable, and proportionate;
• infrequent and not part of a pattern;
• offered or received in the normal course of business; and
• not linked — or perceived to be linked — to any business decision or outcome.

Unacceptable Conduct

The following are not acceptable:

• any gift, payment, or benefit intended as a bribe or inducement;
• gifts or hospitality that create — or may appear to create — a conflict of interest;
• cash or cash-equivalent gifts; and
• gifts or hospitality offered during or in connection with sensitive business decisions (such as procurement or investment discussions).

Transparency and Disclosure

Where individuals are uncertain whether a gift, invitation, or benefit is appropriate, they should seek guidance before accepting or offering it.

Related Policies

This policy should be read alongside the Code of Business Conduct and Ethics, Conflicts of Interest Policy, and Anti-Money Laundering and Financial Crime Awareness Statement.

Consequences

Breaches of this policy may result in appropriate action being taken in accordance with the Company's governance arrangements.