Corporate Governance & ESG Policies

The Trustee for Venture Labs Investment Trust
ABN 26 627 872 754
902, Level 9, 530 Little Collins Street, Melbourne 3000, Victoria
Email: admin@cryolux.com.au | finance@cryolux.com.au
Phone: +61 2 8091 2122

1. Human Rights Policy

Cryolux Group is committed to respecting and promoting internationally recognised human rights across our operations, investments, and supply chain. We align with the Universal Declaration of Human Rights (UDHR), UN Guiding Principles on Business and Human Rights, and ILO Core Labour Standards.

Commitments:

• Fair, safe, and healthy working conditions
• Non-discrimination and equal opportunity
• Zero tolerance for forced labour, child labour, and modern slavery
• Respecting freedom of association and collective bargaining
• Protecting privacy and personal information
• Integrating human rights considerations into investment decisions and due diligence

Scope:

Applies to all management, employees, contractors, and suppliers.

2. Modern Slavery Statement

Cryolux Group opposes all forms of modern slavery, forced labour, debt bondage, human trafficking, and child labour.

Our Commitments:

• Conduct human rights and modern slavery risk assessments
• Evaluate suppliers and investments for ethical labour compliance
• Maintain a risk-based due diligence approach
• Require suppliers to uphold this statement and our Supplier Code of Conduct
• Provide channels for reporting suspected modern slavery
• Take corrective actions where risks or violations are identified

This statement is voluntary, reflecting best practice and alignment with the Australian Modern Slavery Act 2018.

3. Code of Conduct

All representatives of Cryolux Group must uphold professionalism, honesty, and ethical behaviour.

Standards of Behaviour:

• Act with integrity and in Cryolux Group’s best interests
• Avoid conflicts of interest and disclose any potential conflicts
• Comply with all applicable laws and regulations
• Treat all individuals with respect and dignity
• Maintain confidentiality and protect sensitive information
• Use Cryolux Group resources responsibly

Breaches may result in disciplinary action.

4. Privacy Policy

Cryolux Group complies with the Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs).

Information Collected:

• Personal identification details
• Contact information
• Financial information relevant to investments or transactions

Use of Information:

• To manage investments and business operations
• To communicate with stakeholders
• To comply with legal and regulatory requirements

Your Rights:

You may request access to or correction of your personal information via admin@cryolux.com.au. We do not sell or misuse personal data.

5. Whistleblower Policy

Cryolux Group supports the reporting of wrongdoing and protects whistleblowers in line with the Corporations Act 2001.

Protected Disclosures:

• Fraud, theft, or corruption
• Breaches of law or regulation
• Modern slavery or human rights violations
• Unsafe or unethical business practices

Protections:

• Confidentiality of identity
• Protection from retaliation
• Fair and transparent investigation

Reports may be made anonymously via admin@cryolux.com.au.

6. Anti-Bribery & Corruption Policy

Cryolux Group maintains a zero-tolerance approach to bribery, corruption, money laundering, and unethical inducements.

Prohibited Conduct:

• Offering or accepting bribes
• Secret commissions or facilitation payments
• Misuse of Cryolux Group funds or assets
• Conflicts of interest not properly declared

We comply with Australian Criminal Code provisions on bribery and corruption.

7. Responsible Investment Policy

Cryolux Group integrates Environmental, Social, and Governance (ESG) considerations into investment analysis, decision-making, and monitoring.

Investment Principles:

• Avoid investments with harmful human rights or ESG impacts
• Assess risks related to environment, labour practices, and governance
• Prefer investments with strong ethical, sustainability, and governance standards
• Monitor investee performance and engage where concerns arise

8. Supplier Code of Conduct

All suppliers must comply with ethical, social, environmental, and governance standards.

Supplier Requirements:

• Prohibit modern slavery, forced labour, child labour
• Provide safe and fair working conditions
• Follow all applicable laws
• Reduce environmental impact
• Maintain transparency in supply chain operations

Non-compliance may result in corrective actions or termination of engagement.

9. ESG / Sustainability Statement

Cryolux Group is committed to long-term sustainability across environmental, social, and governance dimensions.

Environmental:

• Reduce waste, emissions, and resource consumption
• Support sustainable procurement

Social:

• Respect human rights
• Promote diversity and inclusion
• Support fair labour practices

Governance:

• Uphold transparency, accountability, and ethical management
• Maintain strong compliance structures

10. Conflict of Interest Policy

Conflicts of interest must be actively avoided, managed, and disclosed.

Requirements:

• All conflicts must be disclosed to the Board of Management
• Decisions must prioritise Cryolux Group’s best interests
• Individuals must remove themselves from decisions where conflicts exist

11. Data Security Policy

Cryolux Group safeguards information in accordance with the Privacy Act 1988 and industry best practices.

Security Measures:

• Secure storage of digital and physical records
• Access controls based on role and responsibility
• Monitoring and management of cybersecurity risks
• Prompt reporting of data breaches

All employees and partners must follow secure data-handling procedures.

End of Policy Suite

These policies are approved by the Board of Management and updated periodically to reflect legislative and industry changes.