-
PURPOSE
Northern Star Resources Limited (Northern Star or the Company) and the Board of Directors are committed to treating Employees with fairness and respect. Our objective is to maintain a psychologically healthy and safe work environment free from bullying, harassment, discrimination, victimisation and retaliation. We recruit, develop and promote personnel on the basis of merit, and provide a structured format to respond to any employment or personnel related issue. Equal Employment Opportunity (EEO) is an integral part of Northern Star's overall management philosophy and is underpinned by our Code of Conduct and STARR Core Values.
Northern Star prohibits unlawful discrimination, workplace bullying and harassment including sexual harassment, and any occurrence will be dealt with in accordance with this Policy. Northern Star also has a positive duty in Australia to prevent, and is committed to identifying, responding and preventing discrimination and harassment, including sexual discrimination and sexual harassment, at work. Northern Star encourages employees to come forward with complaints of bullying, harassment, discrimination, victimization and retaliation they experience or observe.
-
EQUAL EMPLOYMENT OPPORTUNITY
The Company takes its obligations seriously with respect to EEO and providing a psychologically and physically health and safe work environment, free from discrimination and harassment. This Policy and its associated procedures set out the Company's commitment to fair employment practices in relation to all decisions affecting employment and career development, including, but not limited to recruiting, promoting, assigning work, training, upgrading, developing and retaining employees and future employees. All discipline and qualification standards will be based on the principle of merit.
-
SCOPE
This Policy applies to all persons performing work for Northern Star including, employees, Directors, contractors, apprentices, trainees, graduates, students gaining work experience, volunteers and visitors working for, or visiting Northern Star and its related bodies corporate at any of the Company's business locations. The Policy is subject to change from time to time at the Company's discretion and in accordance with applicable Federal, State, Commonwealth, or local laws. This Policy is authorised by the Board of Directors of the Company and cannot be amended without the prior approval of the Board of Directors.
-
OBJECTIVE
To ensure the Company meets its legal obligation by providing a workplace free from unlawful discrimination, victimisation, harassment and retaliation, and offers employees a fair, impartial and prompt resolution process in dealing with grievances.
-
DEFINITIONS AND ACRONYMS
Northern Star or the Company
Northern Star Resources Limited and its subsidiaries.
Equal Employment Opportunity (EEO)
Freedom from discrimination on the basis of any other class or category protected by this policy or protected by applicable laws in the countries we are operating in.
EEO rights are guaranteed by U.S. federal and U.S. state fair employment laws and are enforced, in the U.S., by the Equal Employment Opportunity
Commission and equivalent state agencies.
In Australia, EEO rights are protected under Federal and State legislation, and are enforced by bodies such as the Fair Work Commission, the Australian Human Rights Commission or the Western Australian Equal Opportunity Commission.
Australian based employees may seek relief at various courts or commissions of competent jurisdiction, or they may also seek assistance from the Fair Work Ombudsman or WorkSafe WA.
Grievance or Complaint
A real or perceived cause for complaint, especially relating to unfair treatment.
Prepared by:
Manager Culture & Capability
Document Status:
Controlled
Review Date:
01/07/2026
Approved by:
Board of Directors
Approver's Signature:
Hilary Macdonald
Document No:
NSR-HR-005-POL
Revision No:
7.1
Issue Date:
11/07/2025
Page No:
1 of 16
Contact Officer
An employee who has volunteered and is trained to support other employees, who feel that they are, or may be,experiencing bullying, harassment or discrimination in the workplace.
-
EQUAL OPPORTUNITY FOR ALL GENDERS IN THE WORKPLACE
The Company is committed to maintaining the requirements of the Workplace Gender Equality Act 2012 (Cth), the Fair Work Act 2009 (Cth), Title VII of the Civil Rights Act of 1964 (U.S.), and Equal Pay Act of 1963 (U.S.) to promote gender equality in the workplace so that equal access to opportunities and outcomes for both men and women is achieved. Northern Star aims to achieve this by:
promoting merit in employment;
recognising that employees have the right to share (or not share) information about their pay or employment terms and conditions that would be needed to work out their pay, such as their hours of work, with others;
promoting equal employment opportunity and eliminating discrimination including in relation to remuneration; and
encouraging consultation between managers and employees on these issues.
In accordance with the Workplace Gender Equality Act 2012 (Cth), the Company will report to the Workplace Gender Equality Agency on an annual basis, detailing the measures taken and future initiatives to promote equal employment opportunities for women within the Northern Star Group.
-
UNACCEPTABLE BEHAVIOUR
Types of unacceptable behaviour may be (but are not limited to):
intended or unintended;
physical, verbal, written or indirect, in any form of media;
disallowing access to training and special assignments; and
behaviour that a reasonable person, having regard to all circumstances, would feel personally threatened, intimidated, offended, uneasy, embarrassed or humiliated by and/or that affects the terms and conditions of an individual's employment.
Examples of some, but not all, unacceptable behaviour, is in Appendix I
-
DISCRIMINATION
Discrimination, in direct and indirect forms, means treating an individual or group with an identified attribute or category, less favourably than others at any point in the employment cycle.
Discrimination against the protected categories in section 8.1, at any point in the employment cycle, is prohibited by this policy. This includes, but is not limited to, categories protected under anti-discrimination law or human rights legislation.
Further guidance and examples of discrimination and relevant legislation is captured in Appendix I
-
Protected Categories
Discrimination on any of the following bases is strictly prohibited under this policy (whether or not such categories are protected by applicable law):
race
colour
national or ethnic origin
sex
gender identity
intersex status
sexual orientation
pregnancy or parenthood
breastfeeding
marital or relationship status
Prepared by:
Manager Culture & Capability
Document Status:
Controlled
Review Date:
01/07/2026
Approved by:
Board of Directors
Approver's Signature:
Hilary Macdonald
Document No:
NSR-HR-005-POL
Revision No:
7.1
Issue Date:
11/07/2025
Page No:
2 of 16
age
family or care giver's responsibilities
political opinion
social origin
subjection to family and domestic violence
religious beliefs
physical or mental disability or impairment or medical condition (including HIV)
medical record
personal association with a person with a protected attribute
freedom of association
military service or veteran or discharge status
bankruptcy or bad debts
genetic information
citizenship or residency status
victimisation
whistleblower status
criminal record
or any other characteristic specified under anti-discrimination or human rights legislation.
-
Direct Discrimination
Direct discrimination occurs when an individual is treated less favourably than others. For example, two individuals apply for a promotion - one is male and one is female. The male candidate succeeds on the basis that it is perceived that he will better fit the image of the employer.
-
Indirect Discrimination
Indirect Discrimination is more subtle. It is where there is an apparent neutral employment requirement, applied to everyone, but which results in an unfair disadvantage to some individuals or groups. For example, unnecessary height requirements may have a disparate impact on women.
-
Protected Categories
-
HARASSMENT
The Company will not tolerate verbal or physical conduct by an employee which harasses, disrupts or interferes with another's work performance and/or creates an intimidating, offensive or hostile environment.
Under Commonwealth and U.S. laws, it is not the harasser's intent that is significant, it is whether someone's words or actions are viewed as being unwelcoming, offensive, intimidating or humiliating. The severity of the harassment lies in the impact on the individual.
-
Sexual Harassment
Sexual harassment means any verbal, written or physical act, remark or conduct of a sexual nature that is unwelcome and uninvited, resulting in an individual being offended, humiliated or intimidated, that affects the terms and conditions of the individual's employment, and/or that is sufficiently severe or pervasive so as to create a hostile work environment. People who are harassed may experience feelings of personal threat, annoyance, intimidation, humiliation, distress or discomfort.
The Company must take reasonable and proportionate measures to eliminate, as far as possible, sexual harassment and conduct resulting in the workplace environment being offensive, intimidating or humiliating to a person of any sex. The conduct does not necessarily have to be directed towards a particular person, but results in a generally hostile work environment.
A single act may be sufficient. The intention of the harasser is not relevant.
It is not sexual harassment to develop friendships with other workers. Sexual harassment is not behaviour which is based on mutual attraction, friendship and respect. If the interaction is consensual, welcomed and acceptable to both parties, then it is not sexual harassment.
Prepared by:
Manager Culture & Capability
Document Status:
Controlled
Review Date:
01/07/2026
Approved by:
Board of Directors
Approver's Signature:
Hilary Macdonald
Document No:
NSR-HR-005-POL
Revision No:
7.1
Issue Date:
11/07/2025
Page No:
3 of 16
-
Racial Harassment
Harassment means any verbal, written or physical conduct of a racial nature that is unwelcome and uninvited resulting in an individual being offended, humiliated or intimidated, that affects the terms and conditions of the individual's employment, and/or that is sufficiently severe or pervasive so as to create a hostile work environment. A single act may be sufficient, depending on the severity.
Racial harassment may include, but is not limited to, telling a joke about a particular race, and using derogatory slang names.
-
Sexual Harassment
-
WORKPLACE BULLYING
Workplace bullying is repeated occurrences of verbal, physical, social or psychological abuse by another person or group of people in the workplace, which create a risk to health and safety. Bullying in the workplace is harmful, can impact on the health and wellbeing of the victims of bullying, and is detrimental to the workplace culture.
Reasonable management action that is done in accordance with the Company's relevant policy is not bullying. A Supervisor/Manager can make decisions about an employee's poor performance or conduct, take disciplinary action and direct and control the way work is carried out.
-
COMPLAINT / GRIEVANCE PROCEDURE ("FAIR TREATMENT PROCEDURE")
Northern Star, and in particular the Board of Directors and the Chief Executive Officer, encourages and promotes through it's Code of Conduct and this EEO Policy, fairness and transparency in all our dealings and interactions.
The Company has a legal responsibility to prevent unlawful discrimination, victimisation/retaliation, and harassment in the workplace.
The Company is required to ensure that the Fair Treatment Procedure is followed in relation to all informal or formal complaints of discrimination, harassment and or retaliation.
The Fair Treatment Procedure is to provide a structured process to assist an employee raise any employment complaint, grievance or other matters which may arise from time to time, by providing a fair, impartial and prompt resolution process for the complainant and the respondent and having regard to their respective safety and wellbeing.
While this policy provides a prescriptive process, the Company will, wherever possible, support the complainant's choice and control over the process. If the complainant would like to explore other resolution options or alterations to the prescriptive model below, the Company will genuinely consider whether it can accommodate the same, in the interests of fairness to all parties.
The complainant can, at any time, stop or withdraw from the process. Having said that, the Company may have an independent obligation to continue investigating a complaint even if the complainant ceases to be involved.
The Company will consider, in conjunction with the complainant, whether immediate and interim adjustments need to be made to the working arrangements of the parties to the complaint process.
No steps will be taken in relation to adjusting the complainant's working arrangements without first consulting with the complainant.
Any person experiencing what they consider may be unlawful discrimination or harassment in the workplace is encouraged, in the first instance, to make it clear to the person concerned that the behaviour is unwelcome, provided that he or she feel comfortable to do this. If however, the employee does not succeed in satisfactorily having the issue resolved, the employee should then direct the complaint to their immediate Supervisor/Manager.
The Company recognises that this is not always appropriate or easy for the individual, and this step is not compulsory. In the event the Supervisor/Manager is the respondent, the complaint should be addressed to the respondent's Supervisor or Manager.
The following methods of resolving grievances are recommended.
Prepared by:
Manager Culture & Capability
Document Status:
Controlled
Review Date:
01/07/2026
Approved by:
Board of Directors
Approver's Signature:
Hilary Macdonald
Document No:
NSR-HR-005-POL
Revision No:
7.1
Issue Date:
11/07/2025
Page No:
4 of 16
-
Informal Complaint
The informal procedure emphasises resolution rather than factual proof or substantiation of a complaint. Informal action is usually appropriate where:
the allegations may not amount to unlawful harassment, but the individual subjected to the behaviour wants it to cease
it is not sufficiently serious to warrant suspension, termination or otherwise pose as an ongoing risk to health and safety
the individual subjected to the behaviour wishes to pursue an informal resolution; and
the parties are likely to have ongoing contact with one another and the individual subjected to the behaviour wishes to pursue an informal resolution so that the working relationship can be sustained.
Informal ways of dealing with complaints of discrimination and/or harassment can include the following:
resolving the situation yourself. This may be after seeking advice from the HR Department, a Contact Officer or your direct Supervisor; or
requesting your Supervisor speak to the respondent on your behalf. The Supervisor will privately convey your concerns and reiterate the Company's commitment to EEO to the respondent without assessing the merits of the case; or
a complaint is made, the respondent admits to the behaviour, and an investigation is not required if the complaint can be resolved; or
a Supervisor or Manager observes unacceptable conduct occurring and takes independent action even when no complaint has been made.
An employee is not required to exhaust informal attempts at resolution before making a formal complaint.
The most senior People & Culture support onsite must be informed by the relevant Supervisor or Manager or HR Advisers of any informal complaint.
-
Formal Complaint
The formal procedure focuses on investigating whether a complaint can be substantiated, or at least whether the parties can try and reach a satisfactory outcome. The relevant Human Resources Manager (HR Manager) must be informed by the relevant Supervisor or Manager or HR Advisers of any formal complaint. Formal procedures are usually appropriate where:
informal attempts at resolution have failed
the person alleging discrimination or harassment has been victimised or retaliated against
the complaint involves serious allegations of misconduct and informal resolution could compromise the rights of the parties
the complaint is against a more senior employee. Formal procedures may help to ensure that the aggrieved person is not victimised, retaliated against, or disadvantaged
the allegations are denied and the aggrieved person wishes to proceed and investigation is required to substantiate the complaint; or
the aggrieved person wishes to make a formal complaint from the outset. Formal procedures should involve:
-
Informal Complaint
investigations of the allegations
application of the principles of natural justice
making a finding as to whether the discrimination or harassment occurred, or whether it is likely it occurred or determining legitimacy of the grievance
submitting a report with a recommended course of action to the appropriate decision maker (Senior Management, being the Executive Manager People & Culture, the General Manager and the Chief Legal Officer & Company Secretary, as appropriate to the circumstances); and
implementation of an appropriate outcome.
Prepared by: | Manager Culture & Capability | Document Status: | Controlled |
Review Date: | 01/07/2026 | ||
Approved by: | Board of Directors | Approver's Signature: | Hilary Macdonald |
Document No: | NSR-HR-005-POL |
Revision No: | 7.1 |
Issue Date: | 11/07/2025 |
Page No: | 5 of 16 |
Attachments
- Original document
- Permalink
Disclaimer
Northern Star Resources Ltd. published this content on July 17, 2025, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on July 17, 2025 at 23:45 UTC.
