12 April 2021

To our stakeholders:

I am pleased to confirm that Aspen Medical Pty Ltd reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to sharing this information with our stakeholders using our primary channels of communication.

Sincerely yours,
Bruce Armstrong
Chief Executive Officer
Aspen Medical Pty Ltd

At Aspen Medical, we believe passionately that having a Social Purpose ensures that the business can benefit shareholders and the community. We aim to create a better world by the very act of conducting business and to be a positive force in society. Social Purpose is much more than Corporate Social Responsibility in that it is embedded into our operational and strategic decision making.

Our engagement with Aboriginal and Torres Strait Islander peoples cuts across several objectives that are encompassed within our Reconciliation Action Plan, these are:
• pro-active Aboriginal and Torres Strait Islander peoples employment strategies
• ensuring a culturally safe workplace
• annual cultural training
• the Aspen Foundation – the Aspen Foundation focuses on medical, nursing and allied health scholarships for Aboriginal and Torres Strait Islander peoples, as well as supporting organisations working on disease eradication within Aboriginal and Torres Strait Islander peoples’ communities (e.g. Rheumatic Heart Disease, Trachoma and Scabies).

Our commitment to People with Disabilities (PWDs) is such that we aim to provide opportunities within Aspen Medical for employment of People with Disabilities (PWDs) and also ensure they are supported where needed. We also support organisations and programs that develop PWDs’ skills to give them the opportunity to work and live independently.

• We have policies to define our approach to Human Rights in the Our Team. Vulnerable People and Child Protection Policy which is included in any Humanitarian Contract prior to deployment.

• Our Team, Vulnerable People and Child Protection Policy aims to ensure the prevention of exploitation and abuse of vulnerable people. Aspen Medical recognises vulnerable people are at particular risk of being subjected to exploitation and abuse.

• We also have policies to protect our staff such as our Code of Conduct, Respectful Workplace Behaviour, which is included in annual training and a Prevention and Management of Aggression in the provision of Health Services.

• Aspen Medical has been accredited as an Emergency Management Team under the World Health Organisation (WHO) for international Humanitarian work and as such our policies and procedures relating to Human Rights and Labour has been rigorously audited by the WHO prior to accreditation being awarded.

• Aspen Medical is also a certified B Corporation. Certified B Corporations are businesses that meet the highest standards of verified social and environmental performance, public transparency, and legal accountability to balance profit and purpose.

Aspen Medical has completed the development of a Modern Slavery Statement and submitted it to the Australian Government.

Aspen Medical has established policies that demonstrate our commitment to Human Rights:
• Indigenous Engagement and Participation Policy and a Reconciliation Action Plan
• Community Engagement Policy
• Aspen Medical Business Ethics Policy
• Equal Employment Opportunity Policy
.
Aspen Medical has recently implemented its Diversity and Inclusion Strategy 2021 which focuses on:
• Gender Equality
• Social Inclusion
• Aboriginal and Torres Strait Islander People

Aspen Medical has implemented a new Domestic and Family Violence Policy providing a range of support mechanisms for staff affected.

Aspen Medical's Human Rights was audited by the World Health Organisation (WHO) to ensure we met their stringent requirements.

Aspen Medical is preparing for its 3 yearly B Corp certification audit in June which comprises question on "Workers" which includes Human Rights.

In implementing the Modern Slavery Statement Aspen Medical has established a Supplier Code of Conduct with a supporting Questionnaire that is provided to Suppliers

Aspen Medical's Diversity and Inclusion Strategy 2021 includes an action plan with implementation teams covering:
• Engaging male colleagues
• Working with culturally and linguistically diverse (CALD)
• Working with Colleagues with a disability

• Aspen Medical’s business operations are conducted in accordance our with accreditation of the International Standards Organisation (ISO) Quality Management System 9001:2015, Occupational Health and Safety and Management System 45001:2018, and Environmental Management System 14001:2015. These include all the elements of an integrated Management System which is audited by a third part annually.

Aspen Medical's

The Modern Slavery Statement Supplier Code of Conduct Questionnaire is provided to international suppliers with a clause written into the Supply contract

Aspen Medical completes a Workplace Gender Equality Report annually to the Governments Gender Equality Agency signed by the CEO reporting on:
• Gender composition of workforce
• Gender composition of governing bodies
• Equal remuneration between women and men
• Flexible working and support for employees with family and caring responsibilities
• Consultation with employees on issues concerning gender equality in the workplace
• Sex-based harassment and discrimination

• Aspen Medical has a policy that outlines its approach to business integrity in two parts: a Code of Ethics and a Code of Conduct. This policy applies to Aspen Medical and all of its subsidiaries and affiliates. Our Code of Ethics outlines the ethical principles of Aspen Medical and its staff, representing the aspirations of the company at the business level. Our Code of Conduct translates these principles into practical guidance that empowers Aspen Medical, its staff, its business partners and their employees to realise these aspirations. Our Business Ethics Policy – the combination of these two codes – has been developed to reinforce our commitment to honest and truthfulness and for the practical purpose of protecting Aspen Medical, its staff and business partners from acts of corruption, modern slavery (slavery, servitude, forced or compulsory labour, bonded labour) or human trafficking and the potential criminal liabilities.

Aspen Medical has completed the development of a Modern Slavery Statement and submitted it to the Australian Government. It has been assessed as meeting all the requirements of the Australia Modern Slavery Act 2018.(Commonwealth).comprising :
• Our approach and progress
• Our governance
• Risk Management and mitigation
• Due diligence and supply chain assurance
• Stakeholder engagement
• Training and capacity building
• Measuring effectiveness
• Looking ahead

• Our Team, Vulnerable People and Child Protection Policy aims to ensure the prevention of exploitation and abuse of vulnerable people. Aspen Medical recognises vulnerable people are at particular risk of being subjected to exploitation and abuse.

• Aspen Medical is also a certified B Corporation. Certified B Corporations are businesses that meet the highest standards of verified social and environmental performance, public transparency, and legal accountability to balance profit and purpose which is audited by a third party to ensure compliance

Aspen Medical is committed to membership of the UN Global Compact and its principles

Aspen Medical has recently implemented its Diversity and Inclusion Strategy 2021

Through our B Corp membership Aspen Medical has implemented the following polices in support of our Social Purpose:
• Volunteering Policy
• Workplace Giving and Matching Guidelines

Reports on our actions to implement the ten principles of the UN Global Compact to Aspen Medical periodically

A Modern Slavery Awareness online training course has been provided for all staff and is included in our induction training package.

Aspen Medical completes a Workplace Gender Equality Report annually to the Governments Gender Equality Agency signed by the CEO reporting on:
• Gender composition of workforce
• Gender composition of governing bodies
• Equal remuneration between women and men
• Flexible working and support for employees with family and caring responsibilities
• Consultation with employees on issues concerning gender equality in the workplace
• Sex-based harassment and discrimination

• Aspen Medical has an accredited Environmental Management System (EMS) to ISO 14001: 2015 and has held this for several years.
• Aspen Medical demonstrates its commitment to Health, Safety and Environmental Sustainability (HSES) in our HSES Policy Statement
• We publish our environmental commitment and performance annually in our EMHSEPL03 Environmental Sustainability Development Plan 2019 – 20
• Our Risk Management Processes include Environmental Risks as part of our 10 areas of risk
• Our EMS undergoes monthly Site Hazard inspections and six-monthly audits as part of our accreditation.
• Environmental hazards and incidents are required to be reported and investigated as per our AMHSE01 HSE Incident Reporting and Investigation SOP. Tracking is conducted in our RiskMan Incident Reporting system.
• Aspen Medical does not emit any pollutants from our work processes other than procuring utility supply, use of vehicles and third-party commercial aircraft.
• Aspen Medical has Emergency Management Policy (AMHSEP10) to prevent and address incidents affecting the environment and human health impacts
• We strive to minimize the use and safe handling and storage of chemical and other dangerous substances as per our procedures AMHSE13 Hazardous Substances SOP and AMHSE12 Dangerous Goods SOP

Aspen Medical provides an Environmental Sustainability Development Plan annually.

Our Head Office has completed an audit by the utility provider and have had our lights bulbs changed to more energy efficient LEDs

• Environmental Key Performance Indicators (KPIs) are reported annually in our EMHSEPL03 Environmental Sustainability Development Plan and reported to the Senior Management Team, the Corporate HSE Committee and the Board comprising:
• Water
• Paper
• Electricity
• Fuel
• Vehicles
• Domestic and International Air Travel

• Aspen Medical has a policy that outlines its approach to business integrity in two parts: a Code of Ethics and a Code of Conduct. This policy applies to Aspen Medical and all of its subsidiaries and affiliates. Our Code of Ethics outlines the ethical principles of Aspen Medical and its staff, representing the aspirations of the company at the business level. Our Code of Conduct translates these principles into practical guidance that empowers Aspen Medical, its staff, its business partners and their employees to realise these aspirations.

Our Business Ethics Policy – the combination of these two codes – has been developed to reinforce our commitment to honest and truthfulness and for the practical purpose of protecting Aspen Medical, its staff and business partners from acts of corruption, modern slavery (slavery, servitude, forced or compulsory labour, bonded labour) or human trafficking and the potential criminal liabilities.

• Australia is a signatory to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions Countries (the Convention). In accordance with our Anti-Bribery Policy, despite the availability of a facilitation payment defence in Australia, it is the policy of Aspen Medical that facilitation payments will not be made to Foreign Public Officials. Aspen Medical states further, that Aspen Medical will not pay bribes in any circumstances.

• Aspen’s Risk Management Policy is aligned and is conducted in conformance with the ISO 31000: 2009 methodology. Accordingly, Aspen’s Risk Management Plans cover ten areas of business risks which includes Financial Risk that incorporates anti-bribery and corruption

• Aspen Medical has implemented a Fraud Control Plan

All Financial staff are trained in Aspen Medical's Fraud Control Plan

The Finance Team undergo third party auditing annually

The results of Financial Audits demonstrate our successful implementation of the Fraud Control Plan. The results are presented to the Board