Webjet : Code of Conduct

Webjet Limited Code of Conduct

Our values

Respect.

Our people are our greatest asset. They bring passion, commitment, dedication, and pride in what they do. We respect each other, we value collaboration, we are prepared to have robust debate and we have fun in what we do.

Delivering value.

We are focused on delivering high quality products, excellence in customer service, maintaining strong relationships with our supply partners, providing an engaging and supportive work environment for our employees, and delivering value for our shareholders and the broader community.

Integrity.

We are focused on delivering superior outcomes. We always seek to do the right thing and value integrity, accountability and delivering quality in everything we do.

Hunger to win.

As we grow, we remember our humble roots and always strive to retain the spirit that comes with being the challenger brand. We constantly seek to challenge ourselves to find new growth opportunities, innovations and creative ways to deliver value across all aspects of our business. We value curiosity, being brave and having confidence to try new things.

Agility.

Unafraid to disrupt traditional norms, we constantly challenge ourselves to look for new ways to win and deliver value. Our people are agile and nimble and we empower them to effect change.

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1. About our Code of Conduct.

Webjet Limited is committed to operating to the highest standards of ethical behaviour and honesty and with full regard for the safety and wellbeing of our people, customers, the wider community and the environment.

This Code of Conduct (Code) outlines the minimum standards of conduct and behaviour we expect of all our people, including employees, directors, contractors, and everyone working at Webjet or its controlled entities (together Webjet), regardless of your location.

Please familiarise yourself with the requirements of this Code and ensure you understand them fully. You are required to comply with this Code whilst working at Webjet and whenever you are identified as a representative of Webjet (including outside working hours or your workplace).

This Code should be read in conjunction with other Webjet policies and guidelines applicable to you, some of which are referred to in this Code.

Depending on the entity you work for within Webjet, there may also be provisions in your employment or engagement agreement or policies specific to your division, employer entity or geographic region that cover topics similar to those in this Code. Should there be any conflict between the provisions of this Code and those in your employment or engagement agreement or applicable local policies, the latter will prevail.

Any suspected breach of this Code will be treated seriously and investigated. A breach of this Code may result in disciplinary action, including termination of your employment.

This Code may be reviewed and changed from time to time to ensure it is operating effectively. This Code does not form part of any contract of employment or enterprise agreement. The most up-to-date version of this Code can be found on your local intranet and on our investor website at webjetlimited.com.

2. Diversity and inclusion.

Webjet is an equal opportunity employer and welcomes people from a diverse range of backgrounds. We strive to create an inclusive environment that respects and celebrates cultural diversity in our workplace.

Our decisions regarding recruitment, selection for specific roles and career progression are based on personal merit, competency and the candidate's potential to effectively perform the role. We recognise the importance of attracting and retaining talented people with a diverse mix of skills, backgrounds, ethnicity, experience and expertise.

For more information please refer to our Diversity Policy.

3. Our expectations of you.

3.1 Compliancewithlawsandethicalstandards

We strive to conduct ourselves and our business in an ethical manner at all times. Ethical conduct relates to standards of behaviour characterised not only by complying with the law, but also by acting honestly, fairly, with integrity and with respect for others and the communities and environments in which we operate.

As a Webjet team member, you are expected to:

• comply with the letter and spirit of all laws and regulations applicable in Australia and in any jurisdiction in which Webjet carries out operations or activities;
• comply with all policies, procedures and guidelines of Webjet;
• observe the highest standards of honesty, integrity and ethical behaviour;
• conduct our business in accordance with our values; and
• strive to earn and maintain the respect and trust of fellow team members, customers and the wider community.

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3.2 Safety,wellbeing,respectandhumanrights

Safety, health and wellbeing

The safety, health and wellbeing of our people are our highest priority. We will ensure that every effort is made, and every precaution is taken, to ensure that our people are provided with safe, healthy and comfortable working conditions.

Safety is everyone's responsibility at Webjet, and it is your responsibility to:

• take all steps necessary to ensure your own health and safety;
• not do anything that would endanger the safety of any other person;
• immediately report to your manager or HR representative any safety incidents, injuries or hazards identified in or around your working environment; and
• comply with all health and safety policies, procedures and guidelines.

For more information please refer to our Occupational Health and Safety Policy and our Drug and Alcohol Policy.

Respect in the workplace

We are committed to treating everyone with dignity and respect. At Webjet, it is everyone's responsibility to participate in the development, promotion and maintenance of a working environment free from discrimination, bullying and harassment.

Bullying is any repeated unreasonable behaviour directed towards a person or group of people that creates a risk to their mental or physical health and safety. Some examples may include:

• verbal abuse, screaming, insults, swearing at a person or name-calling;
• deliberate exclusion or isolation from workplace activities;
• intimidation and threats;
• assigning meaningless tasks unrelated to a person's job; or
• deliberately withholding information that is vital for effective work performance.

Bullying is always unacceptable and may be against the law.

Harassment occurs when someone engages in unwelcome behaviour in relation to a particular attribute that results in a person feeling offended, humiliated or intimidated, and under the circumstances, it would be reasonable for them to feel this way. Some examples may include telling insulting jokes about a person's sexual orientation or racial group and making derogatory comments or taunts about someone's religion.

Even if there is no intention to offend or humiliate, seemingly harmless acts such as gossip, jokes, teasing or the use of inappropriate nicknames, could all possibly constitute harassment.

Discrimination is treating or proposing to treat someone unfavourably because of a personal characteristic protected by the law. These are referred to as 'protected attributes' and may include but are not limited to:

• gender, marital status, pregnancy, breastfeeding or parental or carer status;
• sexual orientation, gender identity or intersex status;
• race, colour, descent, nationality or ethnic background;
• religious belief, political opinion or industrial activity;
• disability, disease or injury; and
• age.

Unlawful discrimination, bullying and harassment are not tolerated at Webjet and may constitute serious misconduct and result in disciplinary action.

For more information please refer to our Equal Employment Opportunity, Bullying and Harassment Policy.

Human rights and modern slavery

Wherever we operate, we respect the human rights of our people, our customers and those of our suppliers and business partners. We reject all forms of modern slavery, including slavery, servitude, forced labour and human trafficking. We are committed to identifying and mitigating modern slavery and human rights risks across our own business and through our supply chain relationships.

Our latest Modern Slavery Statement, along with previously published statements, are available on our investor website at webjetlimited.com.

3.3 Conflictsofinterest

You are expected to act in the best interests of Webjet. You should avoid any situation which involves, or may involve, an actual or perceived conflict between your personal interests, commercial activities or affiliations outside of Webjet (including any duties you owe to third parties) and the interests of Webjet.

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Any actual, potential or perceived conflicts of interest must be disclosed to the appropriate people (including your manager and HR leader) or, if you are a member of the Board, in accordance with our Board Charter.

If you have an actual or perceived conflict of interest, you should not participate in any decision-making process relevant to the conflicted matter or be present during any discussions relating to the conflicted matter.

3.4 TradinginWebjetsecurities

You should never deal (or procure another person to deal) in the shares or other securities of Webjet or another company if you have unpublished price sensitive information which could materially affect the price or value of those shares or securities. There are blackout periods during which you are not permitted to trade in Webjet securities, and additional restrictions apply to directors and senior managers.

For more information please refer to our Share Trading & Conflicts Policy.

3.5 Anti-bribery,fraudandcorruption

You must comply with all applicable anti-bribery and corruption laws, regardless of your location or position. Failing to comply with anti-bribery and corruption laws is a criminal offence and can result in significant penalties, including imprisonment, large fines and reputational damage.

You must never offer or accept any bribe, kickback, secret commission or other payment or benefit of a similar nature, including any irregular payment to influence or achieve a particular business outcome for Webjet.

All suspected fraudulent or corrupt conduct at Webjet will be thoroughly investigated. Appropriate disciplinary action will be taken against anyone who is found guilty of bribery, fraud or corruption, including referral to appropriate law enforcement or regulatory bodies for independent investigation.

For more information please refer to our Anti-Fraudand Corruption Policy.

3.6 Gifts,entertainmentandhospitality

As a Webjet team member, you are expected to maintain honest, unbiased and ethical relationships with all our business partners.

Subject to the below guidelines, you are prohibited from receiving gifts, entertainment, meals, travel or any other good or service of value from existing or potential business partners, where such receipt might directly or indirectly influence, or be perceived to influence, your business judgement or decision-making.

While gifts should generally be declined, you may accept a gift if the following guidelines are followed:

• If accepted, the cumulative value of gifts received from a business partner should not exceed $300 in any 12- month period.
• Gifts that do not meet the above criteria may be accepted only if the gift will be used as a shared item (such as food baskets) or as a charity or raffle prize at a Webjet company-wide or departmental function.
• The gift is not made during a period in which bids are being sought to award a new contract or renegotiate an existing contract with a business partner.
• Gifts won as part of a contest or give-away, where other individuals have an equal chance of winning, are excluded from the above requirements.
• Notwithstanding the above, gifts of cash or other negotiable instruments, including loans, are always prohibited regardless of their value.
• You must advise your manager as soon as you receive any gift, including meals and entertainment.

3.7 Competitionandconsumerlaw

At Webjet, our goal is to promote business success through the pursuit of fair competition within the regulatory requirements. Competition and consumer laws exist to promote and maintain fair and open competition and protect consumers. You must comply with all competition and consumer laws that apply in the countries in which we operate, including the Australian Consumer Law. Depending on your role and location, you may also be required to complete mandatory competition and consumer law training.

If you are unsure about a competition or consumer law matter, you should speak with your manager or a member of our legal team.

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