To our stakeholders,

I am pleased to confirm that Flinders Port Holdings Pty Ltd (FPH) 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, our first 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

Stewart Lammin

Flinders Port Holdings (FPH) operates only in Australia and in full compliance of Australia’s regulations relating to labour and human rights. Our approach to human rights is documented in FPH Modern Slavery Statement, covering FY2022.

FPH has developed a Sustainability Plan that incorporates our actions in relation to modern slavery. Our Sustainability Plan underpins our Sustainability Policy and includes embedding ethical sourcing principles into procurement processes. FPH aims to foster an organisational culture committed to corporate social responsibility, including the recognition of human rights. In the reporting period, FPH finalised its Ethical Sourcing Policy, supported by our Supplier Code of Conduct.

FPH Ethical Sourcing Policy and FPH Supplier Code of Conduct prohibits our suppliers from engaging in any form of child or forced labour. As stated in our Ethical Sourcing Policy, ‘FPH is committed to high standards of ethical conduct and strives to uphold human rights, fair working conditions and to engage in sustainable business practices. In accordance with the expectations of our stakeholders, the community and requirements of regulatory authorities, we strive to always operate responsibly and we expect the same from our suppliers’.

To assist us to identify and address any risks of modern slavery in our operations, we have properly embedded grievance reporting mechanisms. Our Whistleblower Policy includes instructions to enable internal and external parties to raise concerns and this is publicly available on our website.

Behaviour of FPH Board of Directors, executive, senior leaders and employees is guided by FPH Values and FPH Code of Conduct. As stated in our Code of Conduct, FPH ‘commits to the highest standard of ethical and behavioural standards in all of our internal and external activities and relationships’.

All our new supplier agreements contain specific modern slavery compliance clauses which have been drafted in consideration of our obligations under Australian anti-slavery legislation, including the Modern Slavery Act. Existing agreements (entered into prior to the template modern slavery compliance clauses being included) are updated, with these modern slavery clauses, as they are renewed.

Our vendor approach electronic procurement systems include modern slavery compliance questions in relation to the supplier’s policies, procedures or monitoring systems to address the risk of modern slavery practices. Since April 2020, we have provided a mandatory modern slavery supplier questionnaire (Supplier Questionnaire) to our new suppliers in our Vendor Application Pack. There is now a trigger in our procurement systems that if a supplier has not been engaged within 24 months they are ‘reactivated’ and will be sent the Supplier Questionnaire.

To date, our Supplier Questionnaire is targeted to Tier 1 suppliers. The responses are assessed by our Procurement Team who are responsible for identifying potential ‘red flags’ in a vendor’s responses. In this reporting period, the Group finalised its Supplier Modern Slavery Risk Management Framework to assist us in using the Supplier Questionnaire responses in our risk assessment and risk controls in a systemised manner. In particular, responses to our Supplier Questionnaire have been integrated into our RFX process as part of the implementation of the Supplier Modern Slavery Risk Management Framework.

As per our Whistleblower Policy, internal and external parties are instructed to raise concerns that may relate to our operational risk via an independent reporting platform, operating 24 hours per day. This Policy was revised and communicated to staff during FY2022.

Our Company Secretary and Legal Counsel monitors communications from internal and external parties, that can include grievances and reports relating to integrity and human rights violations. FPH procedures require that grievances be tracked by the Group Legal Manager, incorporated into the regular evaluation of FPH's enterprise risks, and communicated to the Board Audit and Risk Committee. Any human rights reports are to be addressed by the Modern Slavery Working Group. However, no such communications were received during FY2022.

Flinders Port Holdings (FPH) employs most of its workforce directly and had a total of 715 employees at the end of FY2022. Our staff are engaged on full-time, part-time and casual contracts which are either compliant with the Australian regulations or Enterprise Agreements approved by the independent Fair Work Commission.

FPH published a Diversity and Inclusion Policy in 2021 and subsequently formed it’s first Diversity and Inclusion Committee, which oversees implementation of various initiatives. The policy states ‘We expect everyone to demonstrate the appropriate workplace behaviours and look to ensure the safety and wellbeing of all. We do not tolerate unlawful discrimination, bullying, harassment (including sexual harassment), vilification or victimisation’.

Health, safety and wellbeing of our employees, contractors, suppliers and port users is paramount. Our approach to worker health, safety and wellbeing is documented in the FPH Health, Safety & Environment Policy and FPH Safety Strategy.

Behaviour of FPH Board of Directors, executive, senior leaders and employees is guided by FPH Values and FPH Code of Conduct. As stated in our Code of Conduct, FPH ‘commits to the highest standard of ethical and behavioural standards in all of our internal and external activities and relationships’.

In FY2022, FPH engaged in regulated and consultative processes with staff and union representatives to successfully negotiate revised Enterprise Agreements that were scheduled for renewal.

FPH developed and launched a revised Safety Strategy, involving staff consultation across the Group.

Our Company Secretary and Legal Counsel monitors communications from internal and external parties, that can include grievances relating to integrity and labour violations. FPH procedures require that grievances be tracked by the Group Legal Manager, incorporated into the regular evaluation of FPH's enterprise risks, and communicated to the Board Audit and Risk Committee. However, no such communications were received during FY2022.

To minimize risks to our marine and terrestrial environment, and fulfil commitments within the Sustainability Policy and underlying Environment Policy, Flinders Port Holdings (FPH) sets and regularly reviews environmental objectives and targets across six program areas: land and water, emissions reduction, resource efficiency, ecosystems, waste management and climate resilience.

Responding to climate change is now an essential part of doing business. Through the FPH Climate Statement we are committed to adapting to the changing climate and to decarbonising our operations to net zero by no later than 2050. In doing so we align with the Paris Agreement and support the Australian government’s carbon targets and interim International Maritime Organisation’s (IMO) maritime sector target of 50% reduction of total annual carbon emissions by 2050.

In regards to pollution control and monitoring the following initiatives were completed:
- A major hardstand and stormwater upgrade at Port Pirie Berths 7 and 8, directed rainfall to a neighbouring stormwater detention and treatment system
- A maintenance dredging campaign within Port Adelaide’s Inner Harbour was successfully completed in compliance with South Australia's Environment Protection Authority requirements and the National Australian Dredging Guidelines. Sediment and ecology were comprehensively assessed and monitored throughout the dredging campaign, with sediment directed a nearby pond for settlement and dewatering
- FPH completed the final stage of a Voluntary Site Contamination Assessment Proposal; a detailed PFAS monitoring campaign and risk assessment relating to legacy fire-fighting foam pollution of Inner Harbour M Berth. Further monitoring is being scoped in consultation with the Environment Protection Authority and in alignment with FPH’s Contaminated Site Management Strategy.
- Flinders Ports Maritime Environment Guide was released in 2021 to give shipping agents, vessel masters and other port users a common set of guidance relating to maritime pollution mitigation actions, this can be found on our website.
In regards to Biodiversity the following initiatives were completed:
- In 2021, FPH commenced a partnership with the South Australian government to habitat management, restoration and monitoring of Bird Island – a small yet critical nesting site for the migratory and endangered Fairy Tern. Each summer, adults migrate from Siberia to mate and raise their chicks. With our financial support, specialist ecologists and ornithologists are working hard to protect these birds during their annual visit to our shores and reduce the threat from predation and habitat deterioration.
- The seagrass study relating to the 2019 Outer Harbor Channel Widening project was completed finding no impact.

In regards to noise reduction the following initiative was undertaken:
- Straddle carriers at the Flinders Adelaide Container Terminal (FACT) emit a short alarm when they start up. This essential safety feature is in place to reduce the risk of collisions with nearby vehicles and pedestrians. In 2021, the entire fleet of straddle carriers were retrofitted, replacing high-pitched tonal alarms with a new broadband type that reduces the noise footprint of our operations.

Through our Sustainability Plan, were able to complete the following initiatives in relation to carbon reduction activities:
- Virtual Generation Agreement (VGA) – increasing the proportion of renewable energy we purchase from the grid. FPH increased consumption of Greenpower – sourced from solar and wind generation – from 59.6% in FY21 to 64.3% in FY2022.
- Conversion of all lighting within the FWD warehouse from halogen/metal halide to LED, which was partially funded through a South Australian government grant, has reduced electricity consumption and associated carbon emissions by 50%.
- Conversion of external flood lighting from halogen/metal halide to LED at several berths, including Port Pirie Berths 7 and 8, has not only reduced electricity consumption and carbon emissions but improved safety and security outcomes through improved lighting levels.
- Trial of an electric light vehicle at FACT, to inform the transition to a fully electrified fleet.

FPH's environmental management system (EMS) was recertified to the ISO 14001:2015 standard.

FPH's Group Environment Manager monitors environmental performance and compliance and submits reports to the relevant overseeing body (ie.Environment Committee, Sustainability Steering Committee and executive management group).

The environmental monitoring program encompasses:
- air quality
- biodiversity (specifically seagrass communities potentially impacted by capital dredging projects, and bird populations)
- water quality (relating to dredging projects)
- soil and groundwater
- noise
- electricity and fuel consumption
- carbon inventory
- transition and physical risk assessment relating to climate change

Flinders Port Holdings (FPH) has embedded anti-bribery and corruption controls throughout our governance framework an actions, including with the FPH Code of Conduct, which states ‘Trust and honesty are very important to the Group [FPH]. These values are integral to the way in which we do business with clients and the way in which we behave with employees. Employees must not engage in any unethical or improper payment practices either to obtain business or for personal gain.’

Our Whistleblower Policy includes instructions to enable internal and external parties to raise concerns that may relate to our operational risk via an independent reporting platform, operating 24 hours per day.

Behaviour of FPH Board of Directors, executive, senior leaders and employees is guided by FPH Values and FPH Code of Conduct. As stated in our Code of Conduct, FPH ‘commits to the highest standard of ethical and behavioural standards in all of our internal and external activities and relationships’.

As per our Whistleblower Policy, internal and external parties are instructed to raise concerns that may relate to our operational risk via an independent reporting platform, operating 24 hours per day. This Policy was revised and communicated to staff during FY2022.

Our Company Secretary and Legal Counsel monitors communications from internal and external parties, that can include grievances and reports relating to integrity violations. FPH procedures require that grievances be tracked by the Group Legal Manager, incorporated into the regular evaluation of FPH's enterprise risks, and communicated to the Board Audit and Risk Committee. However, no such communications were received during FY2022.