Wrays Code of Conduct

Code of Conduct

wrays.com.au

Wrays Through the Years

1920

Our story began in 1920 when Patent Attorney Peter Bonnerup founded P.M. Bonnerup & Co. in Perth.

In 1921, our first international client, James Frederick Smith of Birmingham, patented an improved motor horn bulb design with a centred neck hole for better durability, efficiency, and quicker action. 1921

In the Beginning

Our First International Client

The firm is renamed R.C. Wray after Reg Wray, the newly appointed Chairman. We then become... 1974: RC Wray & Associates 1985: Wray & Associates 1950

1994

We formally add IP Litigation to our portfolio. Since then, we've played a key role in defending some of Australia's most significant intellectual property cases.

Evolving Firm Identity

Litigation Joins Portfolio

Our name was formally changed to Wrays, reflecting the modern, forward-looking firm we are today. In the same year, we expanded our national presence with the opening of our Adelaide office. 2009

2011

Our Sydney office opens, strengthening our presence on the east coast. Now our second-largest hub, it supports some of the region’s leading clients and organisations across diverse innovation sectors.

Wrays Moves Forward

Sydney

2015

Our Melbourne office opens, expanding our national footprint and connecting us with Victoria’s vibrant innovation ecosystem. As a key hub, it supports clients across technology, research, healthcare and advanced manufacturing sectors.

Today we are a firm of more than 80 people around the country working with the best and brightest minds in medical research, engineering and technology to protect their ideas. 2025

Melbourne

Protecting Brilliant Ideas

Code of Conduct

Wrays’ Code of Conduct defines the principles and ethical standards that guide our behaviour and decision making. It serves as a framework to promote professionalism, safeguard Wrays’ reputation, and uphold its values in all interactions. Wrays aims to foster a culture of integrity, accountability, and respect while ensuring compliance with applicable laws, regulations, and organisational policies.

Throughout this document, "Wrays" means Wrays Pty Ltd and includes Wrays Lawyers Pty Ltd, Wrays Solutions Pty Ltd and all current and future subsidiaries or related entities of Wrays Pty Ltd.

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Our Values

At Wrays, our values are the cornerstone of our culture.

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These values are not just words, but are the guiding principles that shape our actions, decisions and interactions with one another, and our relationships with clients, stakeholders and the community. Our Code of Conduct is a practical extension of our values. It provides guidance on the expected behaviours and decision-making in alignment with these principles. By embracing our values and upholding the Code of Conduct, every employee contributes to a workplace that is ethical, inclusive and committed to excellence. Together, we create an environment where we can achieve our shared goals while supporting one another’s growth and success.

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Code of Conduct: Everyone’s Responsibility

All employees have a shared responsibility to uphold our values and adhere to the Code of Conduct. This includes:

Understanding and Complying Familiarising yourself with the Code of Conduct and Wrays’ values. Employees are expected to always act in a manner consistent with both.

Modelling the Values Demonstrating collaboration, client focus, inclusion, respect and integrity in daily interactions and decision-making.

Speaking Up Reporting any concerns or breaches of the Code of Conduct in good faith. Employees play a crucial role in maintaining a positive and ethical workplace culture.

Seeking Guidance If unsure about a situation or decision, you should seek clarification from your Group Head or a member of the Human Resources team.

Individual Responsibilities

Everyone at Wrays is responsible for behaving in a manner that is consistent with the Code of Conduct and for ensuring our values are being met.

You are expected to:

Read, understand, and comply with all Wrays policies, procedures and contracts

Perform duties in a responsible and professional manner, with due regard for company policies, professional industry standards and other legal requirements and obligations

Use company resources wisely and responsibly

Promote and protect Wrays’ reputation in the wider community Act appropriately when a conflict arises between self-interest and duty to the company Comply with prevailing community standards of equity, justice, fairness, and compassion in dealing with others within and beyond the company

Personal Conduct As part of our commitment to ethical behaviour, all employees and stakeholders covered by this Code of Conduct must demonstrate conduct that aligns with our values.

You are expected to:

Treat everyone with courtesy, respect, kindness and fairness Avoid all forms of discrimination and harassment, as well as any language or behaviour that is abusive, offensive, or unwelcome (also refer to our Workplace Behaviour policy) Respect the privacy of colleagues and maintain confidentiality of personal and company information Consider the impact of decisions and actions on the well being of others Act with integrity and fairness, avoiding actions that could unfairly harm the reputation or career prospects of others Keep personal relations from influencing professional responsibilities Report any suspected breach of the Code of Conduct or any unethical, criminal, corrupt or illegal conduct to your Group Head/Manager, Human Resources or the CEO

Professional Conduct All employees and stakeholders covered by this Code of Conduct are responsible for upholding the highest standards of professionalism and integrity. This includes: Treat everyone with courtesy, respect, kindness and fairness Adhering to all lawful and reasonable directions from Wrays’ leadership and following internal policies and procedures Taking responsibility for workplace safety and complying with health and safety regulations Dressing professionally and maintaining appropriate work attire at all times Staying informed about industry developments and striving for continuous improvement Providing high quality service and maintaining professional excellence in all interactions Avoiding the misuse of official or confidential information and not exploiting information for personal gain Ensuring personal beliefs, political views or affiliations do not interfere with professional duties

Wrays respects employee’s privacy and their right to engage in lawful activities outside of work. Employees should be aware that certain out of-hours conduct may be subject to investigation and potential disciplinary action where it raises legitimate concerns. Out of Hours Conduct

It includes conduct that:

Is likely to cause serious damage to the relationship between Wrays and the employee

Damages Wrays’ interests or reputation

Is incompatible with the employees duty as a Wrays employee

Use of Company Resources

All employees are expected to use company resources responsibly and in accordance with Wrays’ values and legal obligations.

Employees must ensure that Wrays’ property is protected from theft or fraud, and the integrity and security of company information, intellectual property and commercial data is maintained

Key expectations include:

Using Wrays’ technical and physical resources properly and responsibly and for legitimate work-related purposes, while minimising waste and extravagance Seeking approval for personal use of company property and safeguarding company assets Using resources in a manner that causes no harm to the community or the environment Ensuring the security and confidentiality of intellectual property and all company information

Protection and Promotion of Wrays’ Reputation

All employees are expected to:

Promote Wrays wherever possible in professional dealings with others

Refrain from representing themselves as spokespersons, or acting for or on behalf of Wrays, unless authorised to do so *

Refrain from engaging in any activity that may compromise Wrays’ integrity and reputation

When in doubt seek advice from your Group Head or a member of the Human Resources team

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By working together to act with integrity, we maintain the trust of our colleagues, clients, and community.

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Dealing with Conflicts of Interest

At Wrays, we are committed to the highest standards of ethical conduct. As part of this commitment, all employees are expected to uphold our values by actively identifying and managing any potential conflicts of interest. This means:

Prioritising Company Interests Always act in the best interests of the company, avoiding any actions or decisions that could be influenced by personal gain or conflicting loyalties.

Maintaining Objectivity

Recognising Relationship Boundaries Be aware of how relationships, both inside and outside the company, might be perceived. Take proactive steps to address or avoid situations that could appear biased or compromised.

Steer clear of any financial or personal interests that might directly or indirectly interfere with your ability to carry out your responsibilities fairly and effectively.

Being Transparent If you become aware of a real or potential conflict of interest, promptly inform your Group Head, or a member of the Human Reesources team.

Disclosing Personal Relationships

When involved in decisions that could affect someone with whom you have a personal relationship, always disclose that connection to ensure transparency and fairness.

By working together to act with integrity, we maintain the trust of our colleagues, clients, and community.

Compliance and Breaches

All employees must comply with this Code of Conduct and report any breaches to their Group Head or a member of the Human Resources team. Wrays will investigate all reported instances of questionable or unethical behaviour. Where improper behaviour is found to have occurred, Wrays will take appropriate disciplinary action, up to and including termination of employment, and may refer the matter to relevant authorities where criminal conduct is suspected. We will not tolerate any retaliation against employees who, in good faith, raise genuine concerns.

Confidentiality

If you become aware of a real or potential conflict of interest, promptly inform your Group Head, Manager, or a member of the HR team. In instances where potentially unlawful behaviour may have occurred, Wrays has a responsibility to report the matter to the appropriate authorities. Together, we uphold the integrity of our workplace by treating these matters with the seriousness and professionalism they deserve. When involved in decisions that could affect someone with whom you have a personal relationship, always disclose that connection to ensure transparency and fairness. At Wrays, we are committed to handling all concerns and investigations with care, respect, and discretion. While every effort will be made to preserve the confidentiality of individuals involved in an alleged breach of the Code of Conduct, it may be necessary to speak with relevant parties to ensure a fair and thorough investigation. Everyone involved in an investigation – whether as a complainant, witness, or otherwise – has a responsibility to maintain confidentiality and support the integrity of the investigation process. Respecting the process and avoiding gossip or spreading rumours, whether directly or indirectly related to the investigation, is essential. Any breach of confidentiality, including inappropriate discussion about the matter, may result in further disciplinary action.

Additional Resources

Available on the Intranet

Workplace Behaviour Policy

Wrays Values

Wrays respectfully acknowledges the Traditional Owners and Custodians of Country throughout Australia, on the land on which we gather, work, and live. We recognise their continuing connection to land, waters, and culture, and pay our respects to their Elders past and present. We acknowledge the enduring wisdom, resilience, and richness of Indigenous cultures.

wrays.com.au