Privacy Policy COMMITMENT TO YOUR PRIVACY AFGRI Equipment Australia Pty Ltd (‘we’, ‘our’, ’us’) is bound by the National Privacy Principles under the Privacy Act and we are committed to ensuring the privacy of the information our clients and customers provide to us. We understand that your personal information, and how we use it, is very important to you. The following statement reflects our policy in relation to the personal information that we collect. However, if you have any further questions relating to this privacy policy, please contact us. OUR PRIVACY POLICY We will: 1. not collect personal information unless we consider it necessary for us to provide services; 2. not use or disclose personal information about an individual for a purpose other than: o
the purpose for which it was collected;
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a related purpose which the individual would reasonably expect;
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a purpose required or permitted by law; or
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a purpose for which we have obtained the consent of the individual;
3. take all reasonable steps to make sure that the personal information we collect, use or disclose is accurate and up to date; 4. take all reasonable steps to protect and safeguard the personal information we collect; 5. make available our policies on our management of personal information; and 6. provide individuals with access to their personal information that we hold, except where we are required or entitled by law to refuse access. When do we collect personal information? We will only collect personal information if it is necessary for us to do so. Situations in which we may collect personal information include: 1. when taking applications from customers or prospective customers – to determine what kind of goods and services they require, to handle any
inquiries we might receive in relation to our goods and services, to arrange account details; 2. when providing goods and services to customers; 3. when dealing with other parties to a transaction; 4. when required by law; 5. when dealing with certain government agencies; 6. in connection with suppliers – to ensure that they are able to provide the services that we require, and so that we may refer customers to them; and 7. when recruiting staff – in reviewing curriculum vitaes, arranging contact details, conducting interviews. Personal information may include sensitive information (for example, religious beliefs, health status, ethnic origins). Ways in which we collect personal information We collect personal information in person, in writing, by telephone, through our website and through other methods of communication. Most of the personal information that we collect is provided to us by our customers, when they initially apply to obtain goods and services from us, and during the course of us providing goods and services to them. Sometimes we may need to collect personal information from third parties, in the course of assessing whether we wish to supply our goods or services to you, supplying our goods or services to you, or ensuring that information that we have been given is correct. These third parties may include: 1. other parties to a transaction; 2. other parties’ lawyers; 3. your agents and contractors, including your finance broker, lawyer, real estate agent, settlement agent, financial advisor, insurance broker, insurer, banks and other financial providers; 4. credit reference agencies and other information-providing bodies; 5. statutory bodies such as Department of Land Information (Landgate) and the Australian Securities and Investments Commission, and other government agencies and instrumentalities; 6. referees.
In each case, we will treat personal information we collect in accordance with the principles set out above. What do we use personal information for? We use personal information to: assess whether we wish to provide any of our goods and services to you, to provide our goods and services, satisfy regulatory requirements, carry out administrative tasks, recruiting, refer our customers to suppliers, conduct market or customer satisfaction research. Disclosure of personal information to third parties Sometimes, in order to supply you with our services, we may disclose your personal information to third parties. These may include John Deere, Holden, Ford or other manufacturers, repairers, bodies related to us, our bank or other financial providers, our lawyer, agents, contractors, insurers, advisors, your agents, your contractors, organisations with whom we have an alliance or arrangements, and other entities which it is reasonable to expect that information would be provided by in the course of or incidental to the provision of services by us. We will only do so in accordance with our policy. We may also be required to disclose your personal information to some third parties by law. When we collect personal information Usually we will take reasonable steps at or before the time we collect personal information from an individual, to ensure that individual is aware of: 1. who we are and our full contact details; 2. the fact that person is able to gain access to the personal information that we collect; 3. the purposes for which the personal information is collected; 4. the organisations (or types of organisations) we will usually disclose or transfer that personal information to; 5. any law which requires us to collect the personal information; and 6. the main consequences if we do not disclose all (or part) of the personal information. However, there are circumstances where we are not required to do so. Access to your personal information
If you request, then in most circumstances we will make available to you the personal information about you that we have collected. Situations where we might not allow you access to your personal information are described below. Requests for access to your personal information should be made in writing to our privacy officer. We will respond to a request for access to information as a priority and will seek to do so within a maximum of 10 days. We will not charge you for requesting access to your own personal information. When might we refuse access to your personal information? In certain circumstances we may refuse you access to your personal information. The circumstances in which we might do so include: 1. it would have an unreasonable impact on the privacy of others; 2. the information relates to legal proceedings with you; 3. the information would reveal our commercially sensitive decision-making process; 4. providing access to the information would prejudice certain investigations; 5. we are required by law not to disclose the information. What to do if you believe the information we hold about you is inaccurate If you believe that any information that we hold about you is inaccurate or out of date, please contact us and we will review and update the relevant information. Direct marketing In order to provide services to you we may use your personal information in order to update you as to the goods or services being offered by us. If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting our offices. Change in our privacy policy We will review and amend this privacy policy from time to time. If you are dissatisfied with the manner in which we use your personal information We want always to improve our systems and procedures to give you full confidence in our ability to respect and safeguard the privacy of the personal information you provide to us. If we have not fulfilled our commitment to you, please contact us.
AFGRI Supplier Code of Conduct 1. General Responsibilities: The purpose of this policy is to establish the responsibilities of AFGRI and its suppliers. AFGRI suppliers must comply with the legislation, rules, regulations and AFGRI Policies within Australia. All suppliers are expected to be familiar with the business practices of their suppliers and subcontractors, and ensure they operate according to this code of conduct. AFGRI may terminate its relationship with suppliers who fail to comply to this code of conduct or to any regulator or statutory requirements. 2. Key Expectations: Human Rights and Labour CHILD LABOUR In the absence of legislative and regulatory requirements, suppliers may not employ workers under the age of 14. Workers under the age of 18 may only do so inline with the Australian national employment standards. FORCED LABOUR Suppliers must not facilitate or participate in human trafficking; use forced, involuntary, or slave labour; or purchase materials or services from companies using forced, involuntary, or slave labour. They must be able to certify that materials included in their products comply with the slavery and human trafficking laws of the Australia or countries in which they do business. HIRING AND EMPLOYMENT PRACTICES
Suppliers’ hiring practices must include verification of workers’ legal right to work in Australia and ensure that all mandatory documents, such as work visa’s, are available. AFGRI suppliers are expected to support diversity and equal opportunity in their workplaces. Suppliers must also prohibit discrimination based on race, color, gender, nationality, age, disability, union membership, maternity, sexual orientation, marital status, gender identity or expression. HARASSMENT AFGRI suppliers must treat all workers with respect and dignity. They may not subject workers to corporal punishment, physical, sexual, psychological, or verbal harassment or abuse.
In addition, suppliers must provide an environment that allows employees to raise concerns without fear of retaliation. Where it is allowed by law, suppliers should have a system that allows employees to anonymously report their concerns. COMPENSATION AND WORKING HOURS Suppliers must comply with applicable wage and hour labour laws and regulations governing employee compensation and working hours. Suppliers should conduct operations in ways that limit overtime to a level that ensures a humane and productive work environment. HEALTH AND SAFETY Suppliers must provide workers with a safe and healthy work environment. They should take proactive measures that support accident prevention and minimize health risk exposure. They must ensure their operations comply with all legislative and regulatory requirement related to health and occupational safety in both Western Australia and Australia. ENVIRONMENT Suppliers are expected to conduct their operations in a way that minimizes the impact on natural resources and protects the environment, customers, and employees. They must ensure their operations comply with all applicable legislation related to air emissions, water discharges, toxic substances, and hazardous waste disposal. Ethics GIFTS AND GRATUITIES Suppliers must not offer gifts directly to AFGRI employees. This includes gifts of nominal value. AFGRI requests that suppliers report all gives to branch and group management of AFGRI before providing any gifts. Although giving gifts is acceptable in some cultures, AFGRI requests that suppliers respect its policy of gifts. IMPROPER PAYMENTS Bribes, kickbacks, and similar payments are strictly prohibited. This ban applies even when local legislation may permit such activity. Employees, suppliers, and agents acting on behalf of AFGRI are strictly prohibited from accepting or giving such considerations under any circumstances. CONFIDENTIAL INFORMATION Proper management of confidential information is critical to the success of both AFGRI and suppliers. Suppliers must protect all AFGRI information, electronic data, and intellectual property or AFGRI technologies with appropriate safeguards. Any transfer of confidential information must be executed in a way that secures and
protects the intellectual property rights of AFGRI and its suppliers. Suppliers may receive our confidential information only as authorized by AFGRI management, under either non disclosure agreement or by expressed permission of the AFGRI Board, and suppliers must comply with their obligations to not disclose the confidential information, to not use the information except as permitted by the agreement, and to protect the information from misuse or unauthorized disclosure. Our suppliers can expect AFGRI to similarly safeguard their confidential information when authorization is provided to AFGRI. Suppliers may not use the AFGRI trademark, images, or other materials to which AFGRI owns the copyright, unless explicitly authorized. SUPPLIER MANAGEMENT SYSTEM Suppliers are expected to have a management system that ensures they comply with applicable legislation, regulations, and AFGRI policies; conform to this Supplier Code of Conduct; and identify and reduce operational risks related to this code. The system should also promote continuous improvement and compliance with changing laws and regulations. SUPPLY CHAIN TRANSPARENCY Supply chain transparency is required to confirm compliance to this code of conduct. To monitor this, AFGRI will request documentation, conduct onsite audits, review and approve corrective action plans, and verify implementation of corrective action. 3. Non Compliance Reporting: Violations of the AFGRI Supplier code of conduct can be reported confidentially any of the following ways: Telephone: 0862742400 Email: info@afgri.com.au Mail: 80 Great Eastern Highway, South Guildford, WA 6055 4. Contact & Communication: Suppliers are expected to assist AFGRI in enforcing this Supplier Code of Conduct by communicating its principles to their supervisors, employees, and suppliers.
Modern Slavery Statement Financial Year 2025 THE AFGRI COMMITMENT The Modern Slavery Statement by AFGRI Australia Pty Ltd (ABN 14 103 619 067) and its controlled entities, including AFGRI Equipment Australia Pty Ltd (ABN 52 008 686 002), hereby referred to as (AFGRI Group) is prepared as required by the Modern Slavery Act 2018 (Cth) for the financial year ended 31 March 2023. This statement is submitted within the temporary extension of reporting deadlines under the Act. AFGRI Group has a zero-tolerance approach to modern slavery and is committed to addressing any modern slavery risks in its operations and supply chains. We have undertaken an initial risk assessment of modern slavery in AFGRI operations and supply chains. This statement outlines AFGRI’s progress to date and the current and future commitments.
THE AFGRI STRUCTURE, OPERATIONS AND SUPPLY CHAINS AFGRI Group is a privately owned company which acquired its Western Australian operations in 2004 and has operated under the AFGRI name since 2013. AFGRI Group has been the reliable source of premium new and used equipment, including the supply of spare parts and servicing. AFGRI Group start with only three regional dealerships based in the Mid-West of Western Australia and has seen significant growth over the last several years where AFGRI now supports 19-branch locations covering Western Australia. AFGRI Group is the leading John Deere franchise holder in Western Australia, selling and supporting John Deere products. Close to 80% of the AFGRI Group machinery sales are a John Deere product and it therefore represents a substantial part of the business. There are also various other franchises that we trade to ensure we continue to meet the farming needs of our customers. Such other franchises include Kuhn, Manitou, Bourgault, Equalizer, Horsch, Croplands, Grainking, MacDon, Midwest, Fieldquip and Agrowplow. Our main form of revenue is through the sale of machinery (both new and used) which accounted for 76% of total revenue in the 2025 Financial year. The remaining 24% of our revenue is aftermarket revenue in the form of sales of parts and services provided to our agricultural and construction customers. All revenue is earned and carried out in Western Australia with a very small percentage of machinery sales being sold to other states in Australia. During the reporting period we undertook many significant transactions with some of Australia’s leading and predominant Agricultural operations, as well as leading government and private civil construction and forestry operations, employing more than 500 employees. All staff are based in Western Australia with 480 full time staff and the rest being part time. AFGRI group is led by its Chief Executive Officer (CEO) who is responsible for its operations. The CEO is supported by 6 General Managers who together form the
executive team of the AFGRI group in Australia. The CEO is also a director of the company. Predominantly, AFGRI Group contracts and partners with leading global entities and where possible supporting leading local and regional Australian-domiciled companies, that provide specialised services in the following areas: Agricultural Machinery and Spare Parts, o
Heavy Construction and Forestry Equipment parts and repair services
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Precision Agricultural products and solutions. From those suppliers we buy:
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Complete Machinery
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Agricultural machinery parts, accessories, and consumables.
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heavy machinery parts, accessories, and consumables.
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plant and equipment hire services; and
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various servicing and support services.
In 2024, we had approximately 1980 active vendors and suppliers and spent in excess of $490M with direct suppliers. Since its establishment, AFGRI’s core values have been the foundation of the business and how formed the basis of how AFGRI engages its relations with Customers, Suppliers, and the broader community. RISKS OF MODERN SLAVERY PRACTICES Utilising AFGRI Group’s Risk Management Program, which is a structured and proactive program to facilitate the early identification of hazards, assessment of risk and implementation of control measures to enable a safe working environment for all AFGRI employees and contractors, we undertook an initial risk assessment of modern slavery in our operations and supply chains. We will continue to monitor the effectiveness of actions being taken to assess and address modern slavery risks. Potential areas identified by us where there may be some risk for modern slavery are: o
Overseas manufacturing of machinery parts and PPE, particularly where sourcing occurs from Asia or other low-cost regions.
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Logistics and transportation, especially through third-party providers.
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Cleaning and maintenance services, which can involve vulnerable labor populations
While our direct operations are considered low risk due to strict HR practices and Australian employment laws, we acknowledge that modern slavery risks increase
deeper in the supply chain. Nevertheless, AFGRI Group is committed to assessing and addressing the risks of modern slavery and will look to implement processes and systems to address and remedy any actual risks that may arise. ACTIONS TAKEN TO ASSESS AND ADDRESS RISKS To be able to assess the risk of modern slavery in the AFGRI business we rely on our policies, processes and procedures. The following polices and procedure are in place to assist AFGRI Group to assess and address any modern slavery risks accordingly:
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XD11 Supplier Code of Conduct.
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XLH8 Code of Ethics and Conduct.
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XLH19 Health Safety Environment (HSE) Policy
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XK5 Risk Management Program
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XJ12 Tender Policy
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XF18 Supplier Incentive Policy; and
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XC10 Procurement and Payment.
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XLH52 Whistleblower Policy
AFGRI Group and its board is committed to continued improvement in governance and management to address the risks of modern slavery in AFGRI’s operations and supply chains. During the reporting period, a supply chain risk assessment was conducted focusing on tier 1 and tier 2 suppliers. A review of supplier contracts was performed to ensure that modern slavery controls were present in contracts conducted with AFGRI Group. AFGRI Group has developed a Modern Slavery Policy, the objective of which is to assist management to identify, report and implement appropriate controls to ensure that modern slavery is not taking place within AFGRI’s operations and supply chains. A whistleblower mechanism is available for employees to report suspected unethical conduct, including forced labour. AFGRI Group has also included provisions within its template supply agreements (for goods and services) addressing modern slavery. AFGRI Group continues to monitor and update other agreements to include similar provisions to ensure that we meet our obligations under the Act. ASSESSING THE EFFECTIVENESS OF OUR ACTIONS
AFGRI Group undertakes due diligence when considering new suppliers and contractors, which includes but is not limited to a process addressing, among other things, our obligations under the Act, which in turn assists us to identify, investigate and remedy any potential modern slavery issues that may be present. During the period we continued to track supplier agreements with our major suppliers, monitored grievance mechanisms for any reported incidents (none received this period) and established KPI’s for the next reporting period. The KPI’s include extending modern slavery training to our next level of management, the continued review of our Tier 1 and Tier 2 customers which contribute to over 95% of our trading for the AFGRI Group. We are also currently updating our induction and onboarding training materials to include the potential modern slavery risks identified within AFGRI’s operations and supply chains and educating incoming employees by providing examples of such circumstances to enable them to better identify modern slavery practices. CONSULTATION WITH OWNED OR CONTROLLED ENTITIES AFGRI Group Management team (Chief Executive Officer, General Managers and Branch Managers) oversee the operations, risk and management of the AFGRI business and meet regularly to collaborate and discuss the practices of the business and how these can be improved. This statement was prepared with the engagement and input of those specialists within AFGRI’s business. AFGRI Australia Pty Ltd does not own or control other entities within Australia. However, we continue to engage with our parent company and other subsidiaries of AFGRI Group Holdings to ensure alignment on modern slavery risk management and reporting.
FUTURE COMMITMENTS In the next period, we intend to: o
Expand our supplier due diligence to include more second-tier suppliers.
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Introduce a central risk register for supply chain monitoring.
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Enhance employee awareness through ongoing modern slavery training and awareness.
APPROVAL This statement was approved by the AFGRI Group Board of Directors on 28/07/2025 and is available on our website.
1 AFGRI Group comprising AFGRI Australia Pty Ltd (ABN 14 103 619 067), AFGRI Equipment Australia Pty Ltd (ABN 52 008 686 002)