Supplier Code of Conduct

1. Purpose and Application

1.1. Purpose
National Storage Group is committed to and strives to act honestly and with integrity in all its dealings.
This Supplier Code of Conduct (Code) sets out the minimum environmental, social and governance standards of conduct that National Storage Group expects of its Suppliers, considering National Storage Group’s legal and other obligations to its stakeholders.

1.2. Application
This Code applies to all Suppliers of National Storage Group whether directly or indirectly engaged by National Storage Group, including without limitation any representatives or agents appointed to act on behalf of National Storage Group. Suppliers should refer to the Code when considering supplying to National Storage.
The provisions of this Code shall survive the term of any applicable contractual agreement made between the relevant Supplier and any National Storage Group entity.

2. Statement of Compliance

2.1. With Laws and this Code
National Storage Group expects its Suppliers to comply with:
(a) the relevant legislation, regulations, and standards of the countries in which they operate which relate to their organisation; and
(b) this Code,

and to apply an equivalent expectation to their own operations and supply chains.

Where local legislation, regulations, or standards differ from this Code, Suppliers must apply the higher standard of behaviour.

In entering an agreement with any National Storage Group entity, a Supplier is:
(a) acknowledging the obligations and expectations under this Code; and
(b) warranting that, to the best of its knowledge, it has met its obligations and expected standards set out in this Code.
Where a Supplier becomes aware of a breach of this Code, they must notify National Storage Group immediately and take the necessary steps to rectify the breach.

3. Ethical Expectations

3.1. Corporate Governance, Anti-Bribery and Anti-Corruption
National Storage Group believes that strong corporate governance is essential to the conduct of sustainable, equitable and reputable business operations.
National Storage Group does not tolerate bribery or corruption in any form.

Suppliers are expected to:
(a) comply with all applicable laws and regulations relating to bribery, corruption, anti-money laundering, counter terrorism, and related conduct, in all jurisdictions where it operates; and
(b) never directly or indirectly give, offer, or accept any money or opportunity or other benefit which could be interpreted as an inducement, secret commission, or bribe.

3.2. Data Privacy and Information Security
National Storage Group’s Privacy Policy outlines its privacy commitment and explains how it collects, holds, uses, discloses, and protects personal information.

Suppliers are expected to:
(a) respect and safeguard the privacy of personal information held by National Storage Group regarding its clients, customers, suppliers, employees, and others; and
(b) collect, keep, disclose, handle, and use information in a manner that complies with the Privacy Act 1988 (Cth), any other privacy and data protection laws that may apply, and National Storage Group’s Privacy Policy.

3.3. Conflict of interest
National Storage Group is committed to ensuring that all conflicts of interest, whether actual, reasonably perceived, or that could arise in future, are avoided where possible and reported and managed where it is not possible to avoid them.

Suppliers are expected to:
(a) avoid all conflicts of interest when doing business with any National Storage Group entity;
(b) report as soon as possible to National Storage Group any instances involving conflicts of interest between the Supplier’s interest and those of National Storage Group; and
(c) comply with National Storage Group’s directions on managing any reported conflicts of interest.

3.4. Modern Slavery
National Storage Group respects and upholds the human rights of workers in its operations and supply chains, including by ensuring compliance with the requirements of the Modern Slavery Act 2018 (Cth) (the Act). National Storage Group adopts the definition of ‘modern slavery’ set out under the Act. National Storage Group’s Modern Slavery Statement is published on its investor website.

Suppliers are expected to:
(a) comply with the Act (to the extent applicable to the Supplier) and any other relevant modern slavery laws and regulations;
(b) identify, assess, mitigate, and where required by legislation, report on the risks of modern slavery in their operations and supply chains;
(c) make all reasonable efforts to ensure that businesses within their operations and supply chains are not engaged in, or complicit with, human rights abuses, including modern slavery; and
(d) immediately inform National Storage Group if they become aware of instances or allegations or actual or potential risks of slavery or human rights abuses in their operations and supply chains and work to provide remediation.

3.5. Health and Safety
Health, safety, and wellbeing is of paramount importance to National Storage Group. National Storage Group is committed to providing and maintaining a safe working environment to safeguard the health and safety of all Suppliers and visitors to its sites and workplaces.

Suppliers are expected to:
(a) comply with all relevant local and national laws and regulations regarding work or occupational health and safety and the provision of healthrelated benefits to employees;
(b) provide a safe and healthy workplace for all workers;
(c) take reasonable steps to identify, manage, and review potential health and safety hazards to prevent employee exposure;
(d) implement written policies and standards regarding health and safety; and
(e) implement safe systems of work and provide appropriate training for employees and visitors.

3.6. Environmental and Human Sustainability
National Storage Group prefers to work with Suppliers who share its commitment to sustainability across the environmental, social and governance landscape in which it operates, demonstrated by (where applicable):
(a) compliance with all required environmental permits and registrations;
(b) a commitment to continuous improvement of environmental performance and resource management;
(c) promotion of an inclusive workplace where employee differences are valued and respected;
(d) endeavouring to provide a workplace that is free of discrimination, harassment, and bullying.

4. Breach of this Code
The highest standards of corporate conduct are critical to National Storage Group’s success and image. The values and policies in this Code are not exhaustive. This Code is designed to focus the Supplier on values and compliance standards identified by National Storage Group as central to its integrity.

If a breach is found to have occurred, the Supplier may face remediation action including but not limited to the termination of supply contract arrangements.

5. Verification
National Storage Group is committed, where possible, to working with its Suppliers to meet the expectations outlined in this Code.

From time to time, National Storage Group will request its key suppliers to confirm alignment against this Code. This may include, without limitation, self-assessment by Suppliers, or a request for additional information if appropriate based on identified risks. Suppliers are expected to respond in full and be transparent and forthcoming in response to any request for information.

6. Administration

6.1. Where can I obtain further information?
National Storage Group has a dedicated person responsible for the administration of this Code. At the date of adoption of this Code, these are the Company Secretary and the Chief Counsel.
If you require further information or assistance or are uncertain about the application of this Code, please contact [email protected].

6.2. Contact
National Storage Group encourages Suppliers and their employees to immediately report any concerns regarding ethics or compliance issues related to National Storage Group’s Legal and Governance Department. Such reports can be made as follows:
(a) by contacting the Supplier’s primary National Storage Group contact;
(b) via e-mail to [email protected]; or
(c) anonymously via our Whistleblower service.

6.3. Review and publication of this Code
National Storage Group will review this Code from time to time.
A copy of this Code is available on the National Storage website.

7. Definitions
Corporations Act means the Corporations Act 2001 (Cth).

National Storage Group means that stapled group comprising:
(a) National Storage Holdings Limited ACN 166 572 845 and its Subsidiaries;
(b) National Storage Financial Services Limited ACN 600 787 246 AFSL 475 228 as responsible entity of the National Storage Property Trust (the Trust); and
(c) the Trust and the entities which the Trust controls.

Subsidiaries has the meaning given in the Corporations Act.

Supplier means any third party which provides any goods, services, or works to, or for the benefit of, National Storage Group.