SenSen : Corporate Code of Conduct

	Code of Conduct
	SenSen Networks Limited
	ACN 121 257 412
Name of Policy	Code of Conduct
Policy applies to	All Directors, Employees, Contractors, Consultants and
Interns in all countries
Written Date	November 2021
Approval Date	6 December 2021
Approver	SenSen Board of Directors
Date of Policy Review	January 2024

1. INTRODUCTION

At SenSen Networks Limited (SenSen or the Company) we are world leaders in Sensor AI. We achieve this by solving customer problems that were once considered impossible and thus positively transform people's lives in innovative ways. Our purpose is underpinned by our core Values:

• Integrity - always do the right thing, and bring this value into all customer and employee relationships.
• Ingenuity - solve problems considered impossible by our customers through innovation.
• Excellence - deliver solutions and service that exceed our customer expectations.

This is our Corporate Code of Conduct (Code) and is designed to maintain confidence in the integrity of the Company. The Code sets out certain basic principles that all of us - whether we are directors, employees, contractors, consultants or interns - must follow in all dealings related to the Company. It applies in all countries in which SenSen operates.

SenSen's reputation is an essential element of the Company's success. We must all act in a way that preserves and enhances the Company's reputation. Proper business conduct is in the long-term interests of SenSen because it creates loyalty and trust from employees, customers, shareholders, the communities in which we operate, and other stakeholders.

Each one of us has a responsibility to ensure that SenSen achieves the highest levels of business conduct and we are all accountable for acting in line with the policies and standards outlined in the Code. While it is impossible to discuss every conceivable situation that might arise, SenSen's Board believes that the matters contained in this Code provide examples and a set of principles on which decisions can be based to ensure that our actions are not, and will not be, challenged for being unethical.

2. WE COMPLY WITH THE LAW

Each one of us must comply with the letter and the spirit of all laws and regulations. This includes:

1. Understanding the laws and regulations relevant to your own work; and
2. Complying with those legal requirements.

Some laws affect the business conduct of everyone and include laws prohibiting discrimination and harassment and laws relating to workplace health and safety. Other laws focus primarily on particular roles in the Company such as the environment, trade practices and product liability. It is crucial that each one of us understands the laws that affect both our own role and general business conduct. If you are unclear of the impact that the law may have on your role, you should seek advice from your supervisor, a senior manager or from the Director, Human Resources.

We are each required to comply with the Company's Securities Trading Policy which summarises the law relating to insider trading and sets out our policy on buying and selling SenSen Securities including shares, options, derivatives and any other financial products of SenSen that are able to be traded on a financial market.

3. WE HAVE FAIR DEALINGS WITH STAKEHOLDERS

Each one of us is expected to deal fairly, ethically and lawfully, with all stakeholders including customers, suppliers, competitors and employees in all business dealings on SenSen's behalf. This means striving to deliver superior performance in conducting our duties and not taking unfair advantage of another person in business dealings on the Company's behalf through the abuse of privileged or confidential information or through improper manipulation, concealment or misrepresentation of material facts.

SenSen acknowledges and endorses the expectation that funds of shareholders will be used in a manner that results in the best possible return, consistent with the agreed risk profile which takes into account the appropriate level of risk after balancing returns with risk. In achieving this aim, each one of us is required to undertake our duties with honesty, integrity, care, skill and diligence.

SenSen recognises that transparency in business conduct and open disclosure of the strategies of the Company play a key role in building shareholder value, loyalty and trust. The Company also recognises that in order to grow and achieve success, it must earn the trust of employees, customers, suppliers, communities and shareholders by being open and communicative.

Conflicts of Interest

A conflict of interest involves a conflict between your personal interests (or the interests of another person such as your friend or a relative) and your responsibilities to SenSen. Conflicts of interest may be actual, perceived (involving a perception or appearance to a reasonable observer) or potential (involving the possibility that a conflict could arise in the future).

You should not engage in activities or hold or trade assets that involve, or could appear to involve, a conflict between your personal interests and the interests of the Company. Such circumstances could compromise or appear to compromise your ability to make impartial business decisions.

Each one of us is required to make full and complete disclosure to SenSen of the existence, nature and extent of any actual, perceived or potential conflict of interest that you may have in any manner or capacity whatsoever with your duties or obligations. Declarations must be submitted to your supervisor and to the Director, Human Resources who will both work with you to develop an appropriate plan to avoid or appropriately manage the conflict of interest. If in any doubt about a conflict of interest, the matter should be disclosed to ensure it can be adequately considered.

The Director, Human Resources will maintain a register of conflicts of interest declared by SenSen directors and employees.

You must not undertake any other competing employment, engagement, or work during employment with SenSen without prior written consent. Consent will not be provided where the work may adversely affect SenSen or result in you being in competition with SenSen.

4. WE USE RESOURCES APPROPRIATELY

Confidentiality

Confidentiality is a key characteristic of an efficient and successful business. We are all required to protect proprietary, commercial and other information that is confidential to the Company. These obligations of confidentiality continue after your employment or engagement as a contractor has ceased with the Company. Information that is not generally available concerning the activities, results, strategies or plans of SenSen must be used for authorised purposes only. Confidential information should be handled and communicated with care, and must not be disclosed outside the Company without proper authority. Any contracts that are entered into by SenSen with customers, consultants and contractors should contain appropriate confidentiality clauses that ensure the protection of the Company's confidential information.

Privacy

SenSen will only collect personal information from you ethically, lawfully and in a way that is not unreasonably intrusive. The person whose information is collected will be informed of the purpose for which the information is being collected and will be made aware that, subject to some limitations, directors and employees will be able to gain access to the information collected on request. Steps will be taken to ensure that data is appropriately accurate and current and that data is stored no longer than necessary.

If you have access to personal information as part of your role then you must ensure that its confidentiality is strictly maintained. Personal information relating to individuals must not be provided to other employees unless it is required to perform their jobs. Information relating to employment records, salaries, addresses etc. cannot be released to external organisations unless required by law.

Environment and Social Responsibility

We aim to be a responsible business that meets the highest standards of ethics and professionalism. SenSen's social responsibility falls under two categories: compliance and proactiveness. Compliance refers to SenSen's commitment to legality and willingness to observe community values. Proactiveness is every initiative to promote human rights, help communities and protect our natural environment.

Our purpose is built around positively transforming people's lives. SenSen is committed to preventing slavery and human trafficking in our operation and supply chain and will ensure that contracts with suppliers require them to act in accordance with all applicable laws.

We also recognise the need to protect the natural environment. Keeping our environment clean and unpolluted is a benefit to all. We'll always follow best practices when disposing garbage and using chemical substances.

Gifts

We must not make unauthorised gains or payments. This means that as a general rule, the Company's directors and employees should not accept or offer to give gifts, services, discounts, gratuities or other gains from (or to) people who conduct business with the Company. Small gifts or invitations to local social or sporting functions may be acceptable with the approval of the SenSen Executive Team.

Nobody within SenSen is permitted to make unauthorised political donations on behalf of the Company.

5. WE LOOK AFTER EACHOTHER

Working collaboratively is fundamental to SenSen demonstrating its values of Ingenuity and Excellence.

Workplace Health & Safety

SenSen is committed to the health and safety of all of our people. The Company recognises it holds a primary duty of care to ensure that, as far as reasonably practicable, SenSen employees, contractors, consultants and visitors are not exposed to health and safety risks arising from their work or at their workplace. Each one of us has a duty to take reasonable care of our own health and safety and to ensure we do not adversely affect the health and safety of other persons at the workplace.

SenSen will work to eliminate hazardous practices and behaviour, which could cause accidents, injuries or illness to employees, contractors, visitors and the general public. The Company strives to have injury free workplaces. To support each one of us is required to:

1. Comply with SenSen's Workplace Health & Safety Policy and all other health and safety policies, procedures, directions and statutory obligations;
2. Undertake health and safety training as directed by SenSen;
3. Proactively identify safety hazards to their supervisor; and
4. Report any safety incident and/or injury to your supervisor and to the Director, Human Resources.

Supervisors have additional responsibilities under SenSen's Workplace Health & Safety Policy.

Respect and Inclusion in the Workplace

SenSen seeks to provide a work environment in which everyone is treated fairly and with respect. We are all required to refrain from acting in a way that, harasses (including sexually harasses), unlawfully discriminates, bullies, vilifies, victimises, demeans or is violent towards another person.

Each one of us is expected to play our part in creating a respectful workplace culture that is free of harassment, intimidation, bias and unlawful discrimination. The Company is committed to ensuring that employment related decisions are based solely on individual merit and qualifications directly related to professional competence. All employees and applicants for employment should be treated respectfully and evaluated according to their job-related skills, qualifications, abilities, aptitudes and attitude only. Any discrimination, including decisions or adverse conduct towards another person, based on characteristics such as gender, age, race, religion, disability, marital status, sexual preference, carer or parental status, or political belief is not accepted by the Company and is generally unlawful in the countries in which SenSen operates.

6. COMPLIANCE

Breaches of the Code and Reporting Instances of Non-Compliance

Each one of us is responsible for ensuring our individual compliance with the Code.

Breaches of the Code of Conduct are considered misconduct or potentially serious misconduct and will be subject to management and/or disciplinary actions. In serious cases, or repeat cases, this may include termination of employment or engagement with SenSen. Particularly serious non-complianceof the Code includes, but is not limited to, any conduct or event involving impropriety which:

1. Constitutes fraud;
2. May have a serious business impact on the Company; or
3. May seriously compromise the reputation of the Company.

SenSen recognises that a key test of the Company's corporate governance is whether there are both formal and informal structures in place to enable good news and bad news to travel rapidly to the appropriate destination. All instances of non-compliance with the Code are to be reported to the Director, Human Resources or an Executive Team member. Where appropriate, the Executive Team member or Director, Human Resources will refer serious non-compliance to the Board's Audit and Risk Management Committee. Individuals making reports of non-compliance with the Code in good faith will be protected from any reprisal or retaliatory action by the Company ensuring that disciplinary action is taken against anyone engaging in such victimising behaviour.

Monitoring Compliance and Review

The Executive Director and Chief Operating Officer and the Director, Human Resources will conduct an annual review of the Code to ensure that it continues to reflect the letter and spirit of all applicable laws and regulations and the Company's commitment to its staff and the community.

Directors and employees of the Company are encouraged to report any difficulties or challenges encountered by them in complying with the Code (including any inconsistencies between the Code and the business initiatives of the Company) to the Director, Human Resources. This will assist in the evaluation of the effectiveness of the Code and will highlight any areas of the Code that may require amendment or additional guidance.

The Executive Director and Chief Operating Officer shall also establish written policies and procedures designed to ensure compliance with the ASX Listing Rule disclosure requirements and to ensure accountability at a senior management level for that compliance.