Ethics and transparency While CSL’s Values serve as its directional compass, CSL’s Code of Responsible Business Practice (the Code) is a principle-based guide for CSL employees. CSL’s Code continues to foster a culture that supports and encourages high ethical standards, personal and corporate integrity and respect for others. All employees must undertake training on the Code every two years, which is available in 15 languages to cater for CSL’s global workforce. CSL expects its employees and third party partners to comply with the applicable local laws and regulations of the countries in which they operate, and to observe all of the requirements set out in the Code and in CSL’s Third Party Code of Conduct respectively. The Company has internal control systems to enable financial statements comply with the applicable local laws of the countries in which it operates and to prevent fraud and other improper conduct. CSL has an Anti-Fraud Policy which applies a ‘zero tolerance’ approach to acts of fraud such as deliberate deception or dishonesty to obtain an unfair, unauthorised or illegal advantage, whether financial or otherwise instances of fraud. CSL’s Code as well as Third Party Code of Conduct can be found on CSL.com. + READ MORE AT CSL.COM/WE-ARE-CSL/ CORPORATE-GOVERNANCE/CODE-OF- RESPONSIBLE-BUSINESS-PRACTICE Anti-bribery and anti-corruption CSL has an Anti‑Bribery and Anti‑Corruption Policy that prohibits CSL businesses and employees from directly or indirectly offering, paying, soliciting or accepting bribes or giving or receiving personal favours, financial or other rewards or inducements in exchange for making business decisions. This prohibition applies regardless of the value of the reward or inducement. CSL policy also prohibits facilitation payments. The Board, via the ARMC, periodically receives information if there are any material breaches of the Anti‑Bribery and Anti‑Corruption Policy as a way of maintaining oversight. CSL operates in a diverse and complex marketplace and has a number of commercial arrangements with governments and related agencies across various geographies. Bribery and corruption are risks that could expose the organisation and employees to possible prosecution, fines and imprisonment. Market practices are governed by company‑specific policies and procedures. Internal compliance mechanisms and control systems are directly supported by CSL’s Global Ethics and Compliance team and subject to additional oversight by CSL’s Business Units Compliance Committees, regional and local committees, and CSL’s Audit and Risk Management Committee of the Board. Based on these controls, CSL considers its overall risk relating to corruption to be low, and is committed to complying with laws and regulations in the regions in which CSL operates and those that CSL seeks to enter. CSL also has a Group Speak Up Policy to encourage anyone to raise concerns about potential misconduct, including in relation to bribery or corruption. CSL staff may raise any concerns internally. Additionally, anyone can make anonymous reports to the Speak Up Hotline, an independent and confidential reporting line available globally. In addition, over the reporting period, an annual assessment of bribery and corruption risk was conducted by the Ethics & Compliance teams with the business. The assessment included asking a cross‑section of employees in CSL’s commercial and manufacturing operations to complete a standardised questionnaire. The questionnaire is designed to assist with identifying practices or behaviours that could be in breach of CSL’s Anti‑Bribery and Anti‑Corruption Policy. Results are provided to the Business Units’ Compliance Committees and regional/local compliance committees for review, and the committees may ask for actions to be taken which could include revising regional or local policies or procedures, delivering further training, conducting ongoing monitoring or for a more detailed assessment of the local commercial operation, including any third parties acting on behalf of CSL. The implementation of the committees’ review and actions are supported by the local, regional and global Ethics and Compliance teams. Fair competition In FY2025, there were no findings against CSL relating to a breach of any fair trading or competition laws. In May 2025, the UK’s Competition and Markets Authority accepted CSL Vifor’s proposed commitments and concluded its investigation into alleged anti-competitive conduct of Vifor Pharma. CSL Vifor had offered the commitments without any admission of liability or any engagement in unlawful conduct contrary to UK competition law. CSL Vifor agreed to make a voluntary (ex-gratia) payment of £23 million to the National Health Service (NHS). This payment is not a penalty or fine and was offered without any admission of liability. Political contributions Over the reporting period, CSL contributed a total of: • US$2,500 in non-cash corporate political contributions in the US; • AU$19,100 to political organisations in Australia; and • EUR$7,735 to political organisations in Germany, solely for attendance at events including policy briefings, lunches, boardroom lunches and dinners. In all other regions, CSL made no political contributions. More at CSL.com. + READ MORE AT CSL.COM/WE-ARE-CSL/ SUSTAINABILITY/GOVERNANCE Disclosure As a publicly listed company on the Australian Securities Exchange (ASX), CSL has obligations under Australian law and the ASX Listing Rules. Subject to limited exceptions, CSL must continuously disclose to the ASX information about CSL that a reasonable person would expect to have a material effect on the price or value of CSL securities. CSL has a policy that sets clear guidelines and describes the actions that the directors and all employees should take when they become aware of information that may require disclosure. CSL’s Continuous Disclosure Policy can be found on CSL.com. + READ MORE AT CSL.COM/WE-ARE-CSL/ CORPORATE-GOVERNANCE/CORE- POLICIES 49 CSL Limited Annual Report 2024/25
RkJQdWJsaXNoZXIy MjE2NDg3