1. Your rights in relation to privacy

UHY Sothertons understands the importance of protecting the privacy of an individual’s personal information. This policy sets out how UHY Sothertons aims to protect the privacy of your personal information, your rights in relation to your personal information managed by UHY Sothertons and the way UHY Sothertons collects, holds, uses and discloses your personal information.

UHY Sothertons is a member of UHY Haines Norton, an association of independent accounting and consulting firms with offices around Australia and New Zealand. In this policy, UHY Sothertons includes each UHY Haines Norton entity and associated entity and each Australian UHY Haines Norton office.

In handling your personal information, UHY Sothertons will comply with the Privacy Act 1988 (Cth) (Privacy Act) and with the 13 Australian Privacy Principles in the Privacy Act. This policy may be updated from time to time.

2. What kinds of personal information does UHY Sothertons collect?

Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of its services, UHY Sothertons may collect your personal information.

Generally, the kinds of personal information UHY Sothertons collects are:

• contact and identification information such as your name, address, telephone number, email address and date of birth;

• financial information about your assets, occupation and income, investments, account balances, account activities, and payment history;

• details of superannuation and insurance arrangements;

• educational qualifications, employment history and salary;

• information contained in CVs or employment applications in relation to potential roles with UHY Sothertons;

• sensitive information (e.g. information about your health, medical history or specific condition, criminal record, professional memberships etc), which will only be collected with your consent, and if the information is reasonably necessary for UHY Sothertons to provide its services to you; and

• other information relevant in the circumstances.

3. How does UHY Sothertons collect personal information?

Generally, UHY Sothertons collects your personal information directly from you, through the completion of online forms, or exchange in person or by way of telephone, facsimile, email, post or through the use of the UHY Sothertons website.

There may be occasions when UHY Sothertons collects your personal information from other sources such as:

• from your employer or former employer, where necessary for UHY Sothertons to provide its services to you;

• from a bank, fund manager, insurance provider, or superannuation or other product issuer;

• from government or regulatory bodies;

• from an information services provider;

• from a publicly maintained record or other publicly available sources of information including social media and similar websites; and

• if for recruitment purposes, an external recruitment or background screening services provider.

Generally, UHY Sothertons will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you or if you consent or it is otherwise required by law.

4. Why does UHY Sothertons need your personal information?

UHY Sothertons collects, holds, uses and discloses your personal information for a number of purposes including, but not limited to, the following:

• to provide professional services, including services in audit and assurance, accounting and taxation, business improvement, migrant advice, business valuations, corporate advisory, due diligence, litigation support, superannuation, estate and succession planning, and specialist tax consulting;

• accounting, billing and other internal administrative purposes;

• to respond to requests or queries;

• to maintain contact with clients;

• to notify clients of seminars and other events and to seek feedback;

• identifying and informing you of services that may be of interest to you;

• assessing your application for employment with UHY Sothertons or otherwise for the purpose of engaging you as a contractor or consultant;

• to manage any conflict of interest or independence issues;

• to conduct surveys;

• to meet any regulatory obligations;

• as part of a corporate transaction; and/or

• for any other business related purposes.

UHY Sothertons may also use your personal information for purposes related to the above purposes and for which you would reasonably expect UHY Sothertons to do so in the circumstances, or where you have consented or the use is otherwise in accordance with law.

Where personal information is used or disclosed, UHY Sothertons takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to UHY Sothertons. However, without certain information from you, UHY Sothertons may not be able to provide its services to you.

5. To whom does UHY Sothertons disclose your personal information?

UHY Sothertons discloses your personal information for the purpose for which UHY Sothertons collects it. That is, generally, UHY Sothertons will only disclose your personal information for a purpose set out at paragraph 4. This may include disclosing your personal information to:

• third parties engaged to perform administrative or other business management functions;

• business partners and associates;

• people or entities considering acquiring an interest in UHY Sothertons enterprise or assets;

• UHY Sothertons professional advisors, contractors, consultants and related bodies corporate;

• banks, fund managers, insurance providers, and superannuation and other product providers;

• other parties in the context of a corporation transaction;

• government or regulatory bodies; and

• any other entity, with your consent, or to whom disclosure is required or authorised by law.

UHY Sothertons disclosures of your personal information to third parties are on a confidential basis or otherwise in accordance with law. UHY Sothertons may also disclose your personal information with your consent or if disclosure is required or authorised by law.

6. Overseas disclosure

Where it is necessary to make any overseas disclosures, UHY Sothertons will take steps reasonable in the circumstances to ensure the overseas recipient complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme unless you consent to the overseas disclosure or it is otherwise required or permitted by law.

7. Direct marketing

UHY Sothertons may use and disclose your personal information in order to inform you of products and services that may be of interest to you. In the event you do not wish to receive such communications, you can opt-out by contacting UHY Sothertons via the contact details set out in paragraph 10 or through any opt-out mechanism contained in a marketing communication to you.

8. Security of your personal information

UHY Sothertons takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. UHY Sothertons holds personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff.

UHY Sothertons will destroy or de-identify personal information in circumstances where it is no longer required, unless UHY Sothertons is otherwise required or authorised by law to retain the information.

9. Can you access and correct the personal information that UHY Sothertons holds about you?

UHY Sothertons takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and seek correction of your personal information that is collected and held by UHY Sothertons. If at any time you would like to access or correct the personal information that UHY Sothertons holds about you, or you would like more information on UHY Sothertons approach to privacy, please contact one of UHY Sothertons Privacy Compliance Officers on the details set out in paragraph 10 below. UHY Sothertons will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.

To obtain access to your personal information:

• you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;

• UHY Sothertons requests that you be reasonably specific about the information you require; and

• UHY Sothertons may charge you a reasonable administration fee, which reflects the cost to UHY Sothertons, for providing access in accordance with your request.

• If UHY Sothertons refuses your request to access or correct your personal information, UHY Sothertons will provide you with written reasons for the refusal and details of complaint mechanisms. UHY Sothertons will also take steps reasonable in the circumstance to provide you with access in a manner that meets your needs and the needs of UHY Sothertons.

UHY Sothertons will endeavour to respond to your request to access or correct your personal information within 30 days from your request.

10. How to contact us

For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications, please contact UHY Sothertons Privacy Compliance Officer as follows:

Mr T Finos, 08 8223 7311, tfinos@uhysothadl.com.au

11. Privacy complaints

Please direct all privacy complaints to UHY Sothertons Privacy Compliance Officer.

At all times, privacy complaints:

• will be treated seriously;

• will be dealt with promptly;

• will be dealt with in a confidential manner; and

• will not affect your existing obligations or affect the commercial arrangements between you and UHY Sothertons.

The UHY Sothertons Privacy Compliance Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner.