Safe to speak policy

The Woodbrook Wines Group (the Group) comprises Woodbrook Wines Pty Ltd (WW) and its subsidiary and related entities including A. G. Oatley Wines Pty Ltd (“AGOW”). 

1. Purpose

The Woodbrook Wines Group is committed to the highest standards of conduct and ethical behaviour in all business activities. This Safe to Speak policy refers to raising concerns about potential, suspected or actual misconduct within or against the Group.

2. Applicability

Employees, directors and officers who have reasonable grounds to suspect misconduct must make a report. Former employees, contractors, suppliers, associates and related persons are also encouraged to report concerns. 

3. Misconduct

Misconduct includes dishonest, fraudulent or corrupt conduct, illegal activity, dangers to the public, breaches of Group principles, unsafe work practices, environmental damage, health risks, abuse of Group property, financial loss, reputational damage or other serious misconduct. 

4. Personal work-related grievances

Personal employment grievances are outside the scope of this policy and should be raised with management or Human Resources. 

5. Reporting

Disclosure Officers: 
-    Fiona Dart, Chief Disclosure Officer, fdart@oatleywines.com.au
-    Ed Vinzenz, Disclosure Officer, evinzenz@oatleywines.com.au

Reports may also be made through the Whispli Safe to Speak website.:

https://balmoralaustralia.whispli.com/lp/speakup?locale=en#refresh

6. Anonymity

Reports may be submitted anonymously. Confidentiality protections apply. 

7. Investigation of Misconduct

Reports are assessed fairly, objectively and confidentially. Serious matters may be reported to the Board and investigated as appropriate.

8. Protection of those who speak up

The Group protects the identity of reporters and seeks to prevent detrimental treatment, including dismissal, harassment, discrimination or threats. 

9. Outcome of investigations

Investigation findings may result in disciplinary action or referral to legal authorities. 

10. This Policy and the Law

Additional whistleblower protections are available under Australian law. 

11. Reporting procedures and review

Periodic reporting and policy review will occur.

12. Relationship to other policies

This policy should be read with the Ethical Dealing Principles and Code of Conduct.

Version 1.0 – 16 September 2026