Privacy Policy

Last Reviewed: April 2026

Introduction

Compass Agri Australia Pty Ltd (“Compass Agri”, “we”, “us”, or “our”) is committed to protecting the privacy of personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Privacy Policy outlines how we collect, use, disclose, store and protect personal information in the course of our agricultural investment management and dairy operations.

What Personal Information We Collect

We collect personal information reasonably necessary to conduct our business, including:

Employees and Contractors

• Full name
• Email address
• Phone number
• Date of birth
• Bank account details (for payroll purposes)

Investors and Related Parties

• Full name and contact details
• Investing entity details
• Bank account details (for distributions and transactions)

General Business Contacts

• Names
• Email addresses
• Phone numbers

We do not collect or store sensitive identification information, such as:

• Passport details
• Driver’s license details
• Medicare information

How We Collect Personal Information

We collect personal information through:

• Direct communications (e.g. email, phone correspondence)
• Employment and onboarding processes
• Investor onboarding and administration processes
• Third parties, including our Trustee, Rawlings Bolton

Where reasonable and practicable, we collect personal information directly from the individual.

Why We Collect and Use Personal Information

We collect and use personal information for the following purposes:

• Human resources and employee management
• Payroll processing
• Investor relations and communications
• Financial management and distributions
• Operational and business administration
• Marketing and business development (where appropriate)

We only use personal information for purposes that are reasonably necessary for our business activities or as required by law.

Disclosure of Personal Information

We only disclose personal information where necessary to operate our business, including to:

• Automatica (IT provider) – employee data only
• Rawlings Bolton (Trustee) – investor-related information only
• Bentleys QLD (accountants)

We do not sell or rent personal information to third parties.

Overseas Disclosure

We do not store or disclose personal information overseas. All data is managed within Australia.

Data Security

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification, or disclosure.

These measures include:

• Secure IT systems and infrastructure
• Restricted access to sensitive information
• Engagement of professional IT support providers
• Internal policies and procedures for data handling

Data Retention

We retain personal information only for as long as necessary to:

• Fulfil the purposes outlined in this policy
• Meet legal and regulatory obligations

When no longer required, personal information is securely destroyed or de-identified.

Access and Correction

You may request access to, or correction of, your personal information held by us.

To do so, please contact us using the details below. We will respond within a reasonable timeframe and in accordance with our legal obligations.

Complaints

If you believe we have breached your privacy, you may lodge a complaint with us.

We will:

• Acknowledge your complaint promptly
• Investigate the matter
• Provide a response within a reasonable timeframe

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC).

Contact Us

For any privacy-related enquiries or requests, please contact:

Heidi McKechnie
Compass Agri Australia Pty Ltd
Email: heidi@compassagriaus.au

Updates to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available on our website.