Company Policies &
Terms of Trade

1. Definitions

1.1 “Company” refers to Nova Onda Pty Ltd trading as Avenida Australia, ABN 34 679 468 985, its subsidiaries, successors or assigns.

1.2 “Customer” means any person, firm or company purchasing goods or services from the Company.

1.3 “Goods” means all items supplied by the Company to the Customer, including equipment, machinery and consumables.

1.4 “Services” means any labour, consultancy, procurement, supply or related services provided by the Company to the Customer.

1.5 “Order” means any request or agreement by the Customer to purchase Goods or Services from the Company.

1.6 “Terms” refers to these Terms of Trade, as amended from time to time.

2. General

2.1 These Terms apply to all Goods and Services supplied by the Company to the Customer unless otherwise agreed in writing.

2.2 Any variation to these Terms must be agreed in writing by the Company.

2.3 The Customer acknowledges and accepts these Terms by placing an Order, accepting a quote, making payment or otherwise instructing the Company to proceed.

2.4 The Company reserves the right to refuse service, terminate agreements or suspend supply where reasonably required to protect its business interests.

3. Orders and Quotations

3.1 All quotations provided by the Company are valid for 30 days from the date of issue unless otherwise stated.

3.2 The Company reserves the right to withdraw or amend a quotation before acceptance.

3.3 An Order is not binding until confirmed by the Company in writing.

3.4 The Company may decline, in whole or in part, any Order at its discretion, including where the Customer has outstanding debts or poses a credit risk.

4. Pricing and Payment Terms

4.1 All prices are quoted in Australian Dollars and are exclusive of GST unless otherwise stated.

4.2 The Customer agrees to pay all invoices within 7, 14 or 30 days as stated in the relevant quote, invoice or written agreement, unless otherwise agreed in writing.

4.3 Payment must be made by electronic funds transfer, direct deposit or another method agreed by the Company.

4.4 The Company reserves the right to charge interest at 2% per month, compounded monthly, on overdue invoices.

4.5 If the Customer disputes an invoice, they must notify the Company in writing within 7 days of the invoice date, specifying the reasons for the dispute.

4.6 The Customer is responsible for all bank fees and charges related to payments.

4.7 The Company may recover all collection costs, including legal fees and debt recovery charges, incurred in recovering overdue amounts.

5. Delivery and Risk

5.1 Delivery dates provided by the Company are estimates only and are not binding unless expressly agreed in writing.

5.2 The Company is not liable for delays in delivery caused by external factors beyond its reasonable control.

5.3 Risk in the Goods passes to the Customer upon delivery.

5.4 The Customer must inspect all Goods upon delivery and notify the Company of any discrepancies within 48 hours.

5.5 The Company reserves the right to refuse delivery or suspend further supply if the Customer has outstanding debts.

6. Title and Retention of Ownership

6.1 Title in the Goods remains with the Company until full payment is received.

6.2 Until payment is made, the Customer must store Goods separately and ensure they are clearly identifiable as the Company’s property where practical.

6.3 The Company may enter the Customer’s premises, or any premises where the Goods are located, to recover Goods if payment is not made in accordance with these Terms, subject to applicable law.

6.4 The Customer grants the Company a security interest over all Goods supplied, including a security interest that may be registered under the Personal Property Securities Act 2009 (Cth).

7. Warranties and Liability

7.1 The Company will comply with applicable guarantees, warranties and obligations under Australian Consumer Law where those obligations apply.

7.2 To the extent permitted by law, the Company’s liability is limited to replacing, repairing or refunding the cost of the relevant Goods or Services.

7.3 The Company is not liable for indirect or consequential losses, including loss of profit, business interruption, loss of opportunity or delay-related loss, except to the extent such liability cannot be excluded by law.

7.4 The Customer agrees to indemnify the Company against claims, losses, damages or costs arising from misuse of Goods, incorrect use, unlawful use, site conditions, operational decisions or failure to comply with these Terms.

8. Returns and Cancellations

8.1 Returns are only accepted within 14 days of delivery, subject to prior written approval by the Company.

8.2 Goods must be returned in original condition, with all packaging intact, unless otherwise agreed in writing.

8.3 The Customer is responsible for all return freight costs unless the return is due to a fault of the Company.

8.4 Orders for custom-made, specially procured, project-specific or non-stock Goods cannot be cancelled or returned unless the Company agrees in writing.

9. Force Majeure

9.1 The Company is not liable for failure or delay in performance due to circumstances beyond its reasonable control, including natural disasters, strikes, government actions, supplier delays, transport delays, shortages, breakdowns, industrial action or other events outside the Company’s control.

10. Default and Termination

10.1 If the Customer fails to pay an invoice by the due date, the Company may suspend or cancel future Orders.

10.2 The Company may terminate any agreement immediately if the Customer becomes insolvent, breaches these Terms or fails to remedy a breach within a reasonable timeframe after notice.

10.3 Termination does not affect the Company’s right to recover outstanding amounts.

10.4 The Company reserves the right to report late payments and defaults to credit reporting agencies where lawful and appropriate.

11. Dispute Resolution

11.1 In the event of a dispute, the parties must first attempt to resolve the matter in good faith.

11.2 If a resolution cannot be reached, the dispute may be referred to mediation before legal proceedings are commenced, unless urgent relief or debt recovery action is required.

11.3 The Customer agrees to indemnify the Company for reasonable legal costs and recovery costs incurred in enforcing these Terms, to the extent permitted by law.

12. Governing Law

12.1 These Terms are governed by the laws of Western Australia.

12.2 The parties submit to the exclusive jurisdiction of the courts of Western Australia.

13. Privacy and Confidentiality

13.1 The Company will handle personal and business information in accordance with its Privacy Policy and applicable privacy laws where relevant.

13.2 Confidential information shared between the Company and the Customer must not be disclosed to third parties without prior written consent, except where required by law.

13.3 The Customer agrees not to use any confidential business, pricing or supply information of the Company for competitive purposes.

14. Variation of Terms

14.1 The Company reserves the right to update or amend these Terms from time to time.

14.2 Any changes may be notified to the Customer by email or published on the Company’s website.

15. Severability

15.1 If any provision of these Terms is found to be invalid or unenforceable, it does not affect the validity of the remaining provisions.

By engaging in business with Avenida Australia, the Customer acknowledges and agrees to abide by these Terms of Trade.

1. Purpose

Avenida Australia is committed to conducting business with integrity, transparency and accountability. This policy outlines our zero-tolerance position on bribery and corruption. It is designed to support compliance with relevant Australian laws, including the Criminal Code Act 1995 (Cth) and applicable ethical standards in our operations.

2. Scope

This policy applies to all employees, directors, officers, contractors, consultants, agents and other parties representing Avenida Australia, collectively referred to as Personnel.

3. Definitions

Bribery means offering, promising, giving, accepting or soliciting an undue advantage of any value, whether financial or non-financial, directly or indirectly, to influence the actions of another person in order to obtain or retain business or a business advantage.

Corruption means abuse of entrusted power for private gain. It may include bribery, embezzlement, fraud, extortion, facilitation payments, conflicts of interest or improper influence.

4. Prohibited Conduct

• Offering or accepting kickbacks, facilitation payments or other improper payments.
• Providing or receiving gifts, hospitality, entertainment or benefits intended to improperly influence a business decision.
• Making political or charitable contributions to gain an improper business advantage.
• Using third parties, consultants, suppliers or agents to do anything Avenida Australia would not lawfully or ethically do itself.
• Concealing, misrepresenting or failing to disclose a conflict of interest that may affect commercial judgement.

5. Compliance with Australian Law

Avenida Australia is committed to complying with applicable anti-bribery and corruption laws. Personnel must not offer, provide, request or accept any payment, benefit or advantage that may breach Australian law or create an improper business influence.

6. Due Diligence

Before engaging with third parties, including agents, contractors, suppliers or joint venture partners, Avenida Australia may conduct appropriate due diligence to assess the risk of bribery, corruption, conflicts of interest, reputational risk, beneficial ownership and compliance with applicable laws.

7. Record Keeping

All financial records and supporting documents must accurately reflect transactions and be maintained in accordance with applicable accounting standards, taxation requirements and company policies. False or misleading entries are strictly prohibited.

8. Training and Communication

Avenida Australia may provide training or guidance to Personnel on anti-bribery, corruption risks, reporting expectations and ethical business conduct. This policy may also be communicated to relevant external parties where appropriate.

9. Reporting and Whistleblower Protection

Personnel are encouraged to report any concerns or suspicions of bribery, corruption, fraud or unethical conduct promptly. Reports may be made confidentially and will be handled with appropriate care. Avenida Australia will not tolerate victimisation or retaliation against any person who raises a concern in good faith.

10. Consequences of Non-Compliance

Engaging in bribery, corruption or unethical conduct may result in disciplinary action, termination of employment or engagement, contract termination and where applicable, referral to regulatory or law enforcement authorities.

11. Monitoring and Review

Avenida Australia will monitor compliance with this policy and review its effectiveness as required. Improvements may be implemented where necessary.

12. Approval and Acknowledgement

This policy has been approved by Avenida Australia’s management. Personnel may be required to acknowledge their understanding of and commitment to this policy.

Policy Owner: John Veiga, Managing Director

Review Date: June 2026

1. Policy Statement

Avenida Australia is committed to maintaining high standards of professional integrity, ethical behaviour and responsible business conduct. This Code of Conduct and Ethics Policy sets out the principles that guide how employees, contractors, suppliers and stakeholders are expected to act in business dealings and workplace interactions.

This policy supports responsible conduct under relevant Australian laws, including the Fair Work Act 2009 (Cth), Work Health and Safety Act 2020 (WA), Privacy Act 1988 (Cth), Competition and Consumer Act 2010 (Cth) and Corporations Act 2001 (Cth), where applicable.

This policy applies to all employees, contractors, suppliers and representatives of Avenida Australia.

2. Objectives

• Encourage compliance with Australian laws and ethical business practices.
• Promote integrity, professionalism and accountability in all operations.
• Prevent discrimination, harassment, fraud, bribery, corruption and conflicts of interest.
• Support a respectful, inclusive and fair workplace culture.
• Promote transparency in decision-making, financial transactions and corporate governance.
• Establish clear guidelines for reporting unethical behaviour and misconduct.

3. Legal and Regulatory Considerations

• Fair Work Act 2009 (Cth), covering workplace rights, workplace fairness and employment conditions.
• Work Health and Safety Act 2020 (WA), covering duties for health and safety in Western Australian workplaces.
• Competition and Consumer Act 2010 (Cth), covering fair trading, anti-competitive conduct and consumer protection.
• Corporations Act 2001 (Cth), covering corporate responsibilities, financial transparency and directors’ duties.
• Privacy Act 1988 (Cth), covering personal information handling where applicable.
• Australian Human Rights Commission Act 1986 (Cth), supporting equal opportunity and anti-discrimination principles.

4. Core Ethical Principles

4.1 Integrity and Honesty

• All employees and representatives must act with honesty, transparency and fairness in business dealings.
• Misrepresentation, fraud, bribery and corruption are strictly prohibited.
• Employees must disclose conflicts of interest that may influence their decisions.

4.2 Respect and Inclusion

• Avenida Australia values diversity, fairness and equal opportunity.
• Workplace discrimination, harassment, bullying and victimisation will not be tolerated.
• All Personnel must foster a culture of respect, inclusion and collaboration.

4.3 Compliance with Laws and Policies

• Employees, contractors and suppliers must comply with applicable Australian laws, regulations and internal policies.
• Unethical or unlawful activities must be reported promptly to management.

4.4 Confidentiality and Data Protection

• Company, client and supplier information must be protected.
• Personal and commercial information must only be used for authorised business purposes.
• Unauthorised disclosure of confidential or sensitive information is prohibited.

4.5 Fair Competition and Anti-Corruption

• Avenida Australia is committed to fair and ethical competition.
• Employees and representatives must not engage in price-fixing, bid-rigging or anti-competitive conduct.
• Bribery, gifts or improper benefits from suppliers, customers or competitors are prohibited.

4.6 Workplace Health and Safety

• All employees and contractors must follow Avenida Australia’s Health and Safety Policy.
• Unsafe conditions must be reported promptly.
• Drugs, alcohol and other substances that impair workplace safety are strictly prohibited in work activities.

4.7 Environmental Responsibility

• Employees and contractors must support responsible environmental practices.
• Avenida Australia promotes waste reduction, resource efficiency and responsible procurement.

5. Responsibilities

5.1 Management Responsibilities

• Lead by example and promote ethical behaviour.
• Provide employees with guidance and training on ethical standards.
• Address and investigate reports of misconduct.
• Support compliance with workplace laws, safety obligations and business policies.

5.2 Employee Responsibilities

• Follow company policies, procedures, laws and ethical guidelines.
• Report unethical behaviour, fraud, discrimination, harassment or unsafe conduct.
• Maintain professionalism and integrity in all business dealings.
• Use company resources responsibly and ethically.

5.3 Supplier and Contractor Responsibilities

• Conduct business with integrity and comply with applicable Australian laws.
• Avoid conflicts of interest and maintain transparent business practices.
• Respect workplace health and safety requirements.

6. Conflicts of Interest

• Disclose relationships, financial interests or outside employment that may create a conflict.
• Avoid situations where personal gain could influence company decisions.
• Seek management approval before engaging in activities that could create a conflict of interest.

7. Anti-Bribery and Corruption

• Not offer, accept or solicit gifts, payments or favours that could influence business decisions.
• Refuse any request for illegal or unethical payments.
• Report any suspected bribery or corruption to management.

8. Reporting Misconduct and Whistleblower Protection

• Employees are encouraged to report breaches of this policy.
• Reports may be made to a manager or internal compliance officer.
• Reports will be handled confidentially where practical.
• Avenida Australia will not tolerate retaliation against a person who reports a concern in good faith.

9. Disciplinary Action

• Formal warnings, training or performance management.
• Suspension or termination of employment or engagement for serious breaches.
• Legal action where unethical conduct violates Australian law.

10. Continuous Improvement and Policy Review

• Conduct periodic reviews of this policy.
• Provide regular guidance or training on ethics, compliance and workplace conduct.
• Update the policy in response to legislative changes, operational needs and feedback.

Policy Owner: John Veiga, Managing Director

Review Date: June 2026

1. Policy Statement

Avenida Australia is committed to delivering professional, responsive and reliable customer service. This Customer Service and Satisfaction Policy sets out the standards for how we engage with clients, resolve issues and continuously improve our service offering.

This policy supports responsible customer engagement under relevant Australian consumer protection, fair trading, privacy and electronic communications requirements where applicable.

2. Objectives

• Ensure customer interactions are professional, courteous and solution-focused.
• Provide clear, accurate and practical information to customers.
• Respond to enquiries, feedback and complaints within a reasonable timeframe.
• Maintain transparency in pricing, service delivery and contract terms.
• Improve service quality through customer feedback and operational review.
• Build long-term customer relationships based on trust, reliability and value.

3. Legal and Regulatory Considerations

• Competition and Consumer Act 2010 (Cth), including the Australian Consumer Law.
• Privacy Act 1988 (Cth), where personal information handling obligations apply.
• Spam Act 2003 (Cth), covering commercial electronic messages and unsubscribe requirements.
• Do Not Call Register Act 2006 (Cth), where telemarketing rules apply.

4. Customer Service Principles

4.1 Professionalism and Courtesy

• Employees and representatives must communicate respectfully and professionally with customers.
• Information provided to customers should be clear, accurate and not misleading.
• Customers should be treated fairly and with practical consideration.

4.2 Responsiveness and Timeliness

• Customer enquiries should be acknowledged within a reasonable timeframe.
• Requests and concerns should be handled efficiently where practical.
• Unresolved issues should be followed up and escalated where required.

4.3 Transparency and Accuracy

• Pricing, scope, availability, delivery, hire terms and service details should be communicated clearly.
• Claims about goods, services, equipment, warranties or availability must not be false or misleading.
• Where an issue arises, customers should be informed honestly and provided with practical options where available.

4.4 Customer Rights and Consumer Protection

• Goods and services must be supplied in line with applicable consumer law obligations where those obligations apply.
• Customer requests about refunds, repairs, replacements, cancellations or service issues should be assessed fairly and in context.
• Customers should be informed of relevant rights, responsibilities, warranties and service guarantees where applicable.

4.5 Complaints and Feedback

• Customer feedback should be recorded where appropriate and used to improve service delivery.
• Complaints should be acknowledged, reviewed and responded to within a reasonable timeframe.
• Where a complaint relates to a supplier, subcontractor or third-party service provider, Avenida Australia may coordinate a response while considering relevant supplier terms or transaction documents.

5. Responsibilities

• Management must promote a professional, ethical and customer-focused service culture.
• Employees and contractors must engage with customers respectfully, accurately and professionally.
• Suppliers and service providers must supply goods and services in accordance with agreed scope, standards and timeframes.

6. Service Review and Improvement

Avenida Australia may review customer feedback, enquiry records, complaints, supplier performance and project outcomes to identify service improvements.

7. Policy Review

This policy will be reviewed periodically to ensure it remains practical, relevant and aligned with Avenida Australia’s operating needs.

Policy Owner: John Veiga, Managing Director

Review Date: June 2026

1. Policy Statement

Avenida Australia is committed to conducting business in an environmentally responsible and sustainable manner. We recognise the importance of reducing environmental impact, supporting responsible procurement and promoting practical sustainability measures across our operations.

This policy is designed to support responsible conduct under relevant environmental laws and expectations where applicable, including the Environment Protection and Biodiversity Conservation Act 1999 (Cth), Western Australian environmental legislation and recognised environmental management principles.

2. Objectives

• Support compliance with applicable environmental laws and regulations.
• Reduce waste, pollution and unnecessary resource consumption.
• Integrate sustainability principles into procurement and supplier selection where practical.
• Encourage responsible waste management, recycling and reuse initiatives.
• Promote energy efficiency and responsible use of equipment, transport and materials.
• Engage suppliers and contractors on responsible environmental practices.

3. Legal and Regulatory Considerations

• Environment Protection and Biodiversity Conservation Act 1999 (Cth).
• Environmental Protection Act 1986 (WA).
• Waste Avoidance and Resource Recovery Act 2007 (WA).
• Relevant site, client and supplier environmental requirements.
• Recognised environmental management principles such as ISO 14001, where appropriate.

4. Responsibilities

• Management must implement and maintain this policy.
• Employees must follow Avenida Australia’s environmental policies and procedures.
• Suppliers and contractors must comply with applicable environmental laws and industry best practice.

5. Sustainable Procurement and Supply Chain Practices

• Considering recycled, low-carbon or sustainably certified products where appropriate.
• Encouraging suppliers to reduce unnecessary packaging waste.
• Supporting local procurement where practical to reduce transport impact and strengthen local capability.
• Avoiding suppliers associated with unlawful, unethical or environmentally harmful practices.
• Encouraging use of durable, reusable and repairable goods where suitable.

6. Energy and Resource Efficiency

• Reducing unnecessary energy use in offices, work areas and operations.
• Encouraging efficient lighting, equipment and machinery choices where practical.
• Reducing unnecessary water and material consumption.
• Using efficient transport and delivery planning where possible.

7. Waste Management and Pollution Control

• Reducing construction, industrial and packaging waste where practical.
• Encouraging recycling of paper, plastics, metals and electronic waste.
• Ensuring hazardous waste is handled and disposed of responsibly by competent parties.
• Reducing single-use items where practical.

8. Carbon Footprint and Climate Considerations

• Monitoring and reducing unnecessary energy consumption.
• Encouraging efficient transport and delivery coordination.
• Supporting suppliers that adopt practical lower-emission operations.
• Considering environmental initiatives where commercially and operationally reasonable.

9. Environmental Awareness and Training

Avenida Australia may provide environmental awareness information, training or guidance to employees and contractors where appropriate.

10. Continuous Improvement and Policy Review

Avenida Australia is committed to ongoing environmental improvement through periodic review, incident learning, supplier feedback and operational improvement.

Policy Owner: John Veiga, Managing Director

Review Date: June 2026

1. Policy Statement

Avenida Australia is committed to supporting a safe and healthy work environment for employees, contractors, suppliers, clients and visitors affected by our work activities. Our approach to workplace health and safety aligns with the Work Health and Safety Act 2020 (WA), Work Health and Safety (General) Regulations 2022 (WA) and applicable codes of practice where relevant.

We recognise that safety is a shared responsibility and that practical risk management is essential to preventing workplace injuries, illness and incidents.

2. Objectives

• Comply with relevant WHS laws, regulations, codes of practice and Australian Standards where applicable.
• Identify, assess and control health and safety risks associated with our operations.
• Provide appropriate WHS training and guidance to employees and contractors.
• Ensure employees, contractors and suppliers follow site safety requirements where applicable.
• Encourage prompt reporting of hazards, incidents and near misses.
• Provide or require suitable personal protective equipment where required.

3. Legislative and Regulatory Considerations

• Work Health and Safety Act 2020 (WA).
• Work Health and Safety (General) Regulations 2022 (WA).
• Relevant approved codes of practice.
• Relevant Australian Standards and site-specific safety requirements.

4. Responsibilities

• Management must implement and maintain WHS policies, procedures and controls.
• Employees must follow WHS policies, procedures and instructions.
• Contractors and visitors must comply with applicable safety laws, procedures and site instructions.

5. Risk Management and Hazard Control

• Identify hazards through workplace inspections, consultation and reporting.
• Assess risks based on likelihood and consequence.
• Apply control measures using the hierarchy of controls where practical.
• Monitor and review control measures for effectiveness.

6. Emergency Preparedness and Incident Reporting

• Emergency response planning for fire, medical events and hazardous material spills.
• First aid and medical treatment arrangements suitable for the workplace or site.
• Incident reporting and investigation procedures.
• Return to work support for injured workers where applicable.

7. WHS Training and Communication

• Induction training where required for employees and contractors.
• WHS awareness information on relevant workplace risks.
• Toolbox talks or safety meetings where appropriate.
• Access to WHS documentation, policies and procedures where relevant.

8. Continuous Improvement and Policy Review

This policy will be reviewed periodically to ensure it remains effective, practical and aligned with applicable WHS obligations and business operations.

Policy Owner: John Veiga, Managing Director

Review Date: June 2026

1. Policy Statement

Avenida Australia is committed to maintaining a fair, respectful and productive workplace where employees are valued, treated lawfully and supported to perform their roles. This policy outlines standards and expectations for employee conduct, workplace relations, employment conditions and compliance with relevant workplace laws.

2. Objectives

• Support fair and lawful employment practices.
• Promote equal employment opportunity and prevent workplace discrimination.
• Provide a safe, healthy and respectful work environment.
• Set clear expectations for employee conduct and performance.
• Support professional development and employee wellbeing.
• Maintain transparent grievance and dispute resolution procedures.

3. Legal and Regulatory Considerations

• Fair Work Act 2009 (Cth), covering workplace rights and employment conditions.
• National Employment Standards, covering minimum employment entitlements.
• Work Health and Safety Act 2020 (WA), covering duties for workplace safety.
• Privacy Act 1988 (Cth), covering employee personal information where applicable.
• Relevant anti-discrimination laws.

4. Recruitment and Employment Conditions

• Avenida Australia is committed to fair and merit-based recruitment.
• Hiring decisions should be based on skills, experience, qualifications and role requirements.
• Discrimination based on a protected attribute is prohibited.
• Employment terms must comply with applicable workplace laws, awards or agreements.

5. Workplace Conduct and Behaviour Expectations

• Employees must conduct themselves with integrity, respect and professionalism.
• Unlawful harassment, bullying, discrimination and victimisation are prohibited.
• Employees must disclose personal or financial interests that may affect their duties.

6. Work Health and Safety

• Workplace hazards must be reported promptly to management.
• Employees must comply with safety procedures, including PPE requirements where applicable.
• Workplace incidents must be reported and investigated in accordance with WHS requirements.

7. Employee Performance and Development

• Employees may receive regular performance feedback.
• Training may be provided to enhance skills, safety and career growth.
• Mandatory compliance training should be completed where required.

8. Leave Entitlements

Avenida Australia provides leave entitlements in accordance with applicable employment laws, the National Employment Standards, awards, agreements and individual employment contracts where relevant.

9. Grievance and Dispute Resolution

• Employees may raise concerns with their direct manager or nominated contact.
• Concerns should be reviewed fairly and impartially.
• Corrective actions may be implemented where required.
• Unresolved matters may be escalated to an appropriate external body where applicable.

10. Termination and Redundancy

Avenida Australia follows fair and lawful termination procedures in line with applicable workplace laws, employment contracts and business requirements.

11. Continuous Improvement and Policy Review

Avenida Australia will review this policy periodically to reflect legal changes, operational needs and industry best practice.

Policy Owner: John Veiga, Managing Director

Review Date: June 2026

1. Policy Statement

Avenida Australia is committed to maintaining a strong, ethical and professional brand presence in the Australian market. This policy establishes guidelines to ensure marketing activities align with company values, industry best practice and relevant Australian consumer, advertising, privacy and electronic communications laws where applicable.

2. Objectives

• Ensure marketing and branding reflect Avenida Australia’s values, professionalism and industry expertise.
• Support compliance with consumer protection, advertising, privacy and electronic marketing requirements where applicable.
• Maintain consistency in brand messaging, logos and visual identity.
• Promote ethical and responsible advertising.
• Protect customer data used in marketing activities.

3. Legal and Regulatory Considerations

• Competition and Consumer Act 2010 (Cth), including the Australian Consumer Law.
• Spam Act 2003 (Cth), covering commercial electronic messages.
• Privacy Act 1988 (Cth), covering personal information handling where applicable.
• Advertising Standards Code and relevant advertising standards.

4. Responsibilities

• Management must oversee campaigns to support compliance and brand consistency.
• Marketing and communications personnel must create brand-aligned and accurate campaigns.
• Employees must follow brand guidelines and avoid misleading claims.
• Third-party agencies must follow Avenida Australia’s brand and advertising requirements.

5. Brand Identity and Consistency

• Avenida Australia’s logo must be used in accordance with company brand guidelines.
• Logos, fonts, colours and visual schemes should remain consistent across platforms.
• Unauthorised modification of branding elements is prohibited.
• Marketing content must maintain a professional, credible and customer-focused tone.

6. Advertising and Promotional Activities

• Advertisements must not mislead or deceive customers.
• Statements should be backed by factual evidence where required.
• Marketing must not unfairly disparage competitors.
• Commercial electronic messages should include clear sender identification and a functional unsubscribe option where required.

7. Customer Engagement and Feedback Management

Customer enquiries should be addressed professionally and within a reasonable timeframe. Complaints should be acknowledged, reviewed and escalated where necessary.

8. Data Privacy and Consumer Protection

Customer data must be collected lawfully, stored securely and not shared without authorisation. Potential data breaches must be reported and managed in accordance with applicable obligations.

9. Monitoring, Reporting and Compliance

Marketing campaigns may be reviewed for legal and ethical alignment. Employees must report suspected misleading advertising or unauthorised brand use.

10. Continuous Improvement and Policy Review

Avenida Australia is committed to ongoing improvement in marketing and branding by reviewing policy settings, updating brand guidance and training team members where required.

Policy Owner: John Veiga, Managing Director

Review Date: June 2026

1. Policy Statement

Avenida Australia is committed to ethical, sustainable and commercially responsible procurement and sourcing practices that align with the needs of our business and clients. Our procurement processes are designed to support fair dealing, transparency, supplier accountability and practical value.

2. Objectives

• Support procurement activities that are lawful, ethical and commercially sound.
• Promote ethical sourcing and supplier accountability.
• Drive cost-efficiency while maintaining quality and delivery standards.
• Encourage supplier diversity, including local and Indigenous suppliers where practical.
• Maintain transparency and accountability in supplier selection and contract management.

3. Legal and Regulatory Considerations

• Competition and Consumer Act 2010 (Cth), including fair trading and consumer protection.
• Modern Slavery Act 2018 (Cth), including awareness of modern slavery risks in supply chains.
• Work Health and Safety Act 2020 (WA), covering safety-related supplier obligations where applicable.
• Relevant environmental laws and regulations.
• Australian Standards and client requirements where applicable.

4. Responsibilities

• Management must develop and maintain procurement policies and procedures.
• Employees must follow Avenida Australia’s procurement procedures.
• Suppliers must comply with applicable Australian laws and industry standards.

5. Supplier Selection and Procurement Process

• Needs assessment.
• Market research and supplier identification.
• Request for quote.
• Evaluation and selection.
• Contract negotiation.
• Order placement.
• Quality control and compliance checks.
• Supplier performance monitoring.

6. Ethical and Sustainable Procurement

• Considering modern slavery risks in supply chains where relevant.
• Supporting Australian-made products and local suppliers where practical.
• Engaging with Indigenous businesses where suitable opportunities exist.
• Reducing environmental impact through responsible product and supplier choices where appropriate.

7. Risk Management and Compliance Monitoring

• Supplier due diligence and financial capability checks where required.
• Contractual safeguards, including clauses that support compliance with agreed standards.
• Procurement audits where risk, value or client requirements justify review.
• Supply chain resilience planning for potential disruptions.

8. Conflicts of Interest and Anti-Corruption

• Employees must declare personal or financial interests in supplier dealings.
• Gifts, incentives or personal benefits must not be accepted if they could influence procurement decisions.
• Tendering and supplier selection processes should be conducted fairly and transparently.
• Procurement activities should be documented and open to review.

9. Procurement Records and Documentation

• Supplier contracts and agreements.
• Purchase orders and invoices.
• Delivery and inspection records.
• Risk assessments and compliance checks.
• Supplier performance evaluations.

10. Continuous Improvement and Policy Review

Avenida Australia will review procurement processes and supplier performance to improve value, transparency, compliance and delivery efficiency.

Policy Owner: John Veiga, Managing Director

Review Date: June 2026

1. Policy Statement

Avenida Australia is committed to identifying, assessing and managing risks to support business continuity, legal compliance, stakeholder confidence and the protection of employees, clients, suppliers and assets.

2. Objectives

• Establish a structured risk management framework.
• Identify and manage operational, financial, regulatory, cybersecurity, environmental and safety risks.
• Support compliance with Australian laws, industry regulations and contractual obligations where applicable.
• Protect the health, safety and wellbeing of employees and stakeholders.
• Support business continuity through effective crisis management and contingency planning.

3. Legal and Regulatory Considerations

• Corporations Act 2001 (Cth).
• Work Health and Safety Act 2020 (WA).
• Privacy Act 1988 (Cth).
• Competition and Consumer Act 2010 (Cth).
• AS ISO 31000:2018 Risk Management Guidelines.
• Relevant environmental laws, employment laws, contractual obligations and client requirements.

4. Responsibilities

• Management must implement and maintain a practical risk management framework.
• Employees must report potential risks, incidents or compliance breaches promptly.
• Suppliers and contractors must comply with Avenida Australia’s risk management and compliance requirements where applicable.

5. Risk Management Framework

• Identify internal and external risks that may affect business operations.
• Evaluate risks based on likelihood and impact.
• Implement controls such as updated policies, safety measures, supplier checks and technology safeguards.
• Conduct periodic reviews and audits.

6. Compliance Monitoring and Auditing

• Internal compliance audits.
• Regulatory reporting where required.
• Policy reviews and updates.
• Confidential reporting processes where appropriate.

7. Business Continuity and Crisis Management

• Establish emergency response processes for major events where required.
• Identify critical business functions and backup arrangements.
• Maintain secure data storage and disaster recovery measures.
• Maintain communication channels during business disruptions.

8. Workplace Health and Safety Risk Management

Avenida Australia follows risk management processes to support WHS obligations, including site safety inspections, PPE requirements, hazard reporting and emergency planning where applicable.

9. Financial Risk Management

• Monitor cash flow, accounts receivable and expense control.
• Maintain fraud prevention measures for financial transactions.
• Follow up overdue payments and manage debtor risk.

10. Continuous Improvement and Policy Review

Avenida Australia will review this policy periodically to ensure risk management practices remain practical and aligned with business operations.

Policy Owner: John Veiga, Managing Director

Review Date: June 2026

1. Policy Statement

Avenida Australia is committed to upholding human rights and taking reasonable steps to ensure modern slavery and human trafficking have no place in our operations or supply chains. We recognise the importance of identifying and managing risks associated with forced labour, debt bondage, human trafficking, servitude, child labour and other exploitative practices.

2. Purpose

• Outline Avenida Australia’s commitment to preventing modern slavery and human trafficking.
• Establish procedures for identifying, assessing and mitigating related risks.
• Support responsible practice under the Modern Slavery Act 2018 (Cth) and other relevant Australian legislation where applicable.
• Promote transparency and accountability in procurement and supplier relationships.

3. Scope

This policy applies to all individuals working for or on behalf of Avenida Australia, including employees, contractors, suppliers and business partners.

4. Definitions

Modern Slavery includes situations where coercion, threats or deception are used to exploit individuals and deprive them of freedom. This may include slavery, servitude, forced labour, debt bondage, human trafficking, forced marriage and child labour.

Human Trafficking means the recruitment, transportation, transfer, harbouring or receipt of persons through coercion, abduction, fraud or deception for the purpose of exploitation.

5. Legislative Framework

• Modern Slavery Act 2018 (Cth), which requires certain large entities operating in Australia to report annually on modern slavery risks and actions taken to address those risks.
• Criminal Code Act 1995 (Cth), which contains offences related to slavery, servitude, forced labour and human trafficking.
• Fair Work Act 2009 (Cth), which supports lawful employment conditions and protections against exploitative work practices.

6. Responsibilities

• Management must implement and maintain this policy.
• Employees must be alert to indicators of modern slavery or human trafficking.
• Suppliers and contractors must take reasonable steps to ensure their own operations and supply chains are free from modern slavery.

7. Due Diligence Processes

• Risk assessments of operations and supplier relationships.
• Supplier due diligence, especially for higher-risk industries, labour arrangements or regions.
• Contractual obligations requiring suppliers to support anti-slavery measures.
• Supplier engagement through declarations, information requests or supporting documents where appropriate.

8. Training and Awareness

Avenida Australia may provide information, training or guidance to employees and stakeholders on modern slavery risks, indicators and reporting procedures.

9. Reporting Mechanisms

Employees, suppliers and stakeholders are encouraged to report concerns related to modern slavery or human trafficking. Reports will be handled seriously and assessed promptly. Avenida Australia will not tolerate retaliation against a person who reports a concern in good faith.

10. Continuous Improvement

Avenida Australia is committed to improving its approach to identifying and managing modern slavery risks through policy review, supplier engagement and practical procurement controls.

Policy Owner: John Veiga, Managing Director

Review Date: June 2026

1. Definitions

Avenida means Avenida Australia, Nova Onda Pty Ltd ABN 34 679 468 985 and its directors or authorised representatives.

Supplier means the party named on the Purchase Order engaged to provide goods and or services.

Goods and or Services means all items, materials, equipment, works or services supplied under the Purchase Order.

Client means the end-user or project recipient for whom Avenida facilitates procurement.

Order means the Purchase Order and any documents or correspondence referenced within it.

2. Relationship of the Parties

The Supplier is engaged as an independent provider. Nothing in the Order creates a partnership, employment or agency relationship between Avenida and the Supplier. The Supplier is solely responsible for supervising its personnel, subcontractors and operations under its scope of supply.

3. Scope of Supply

• The Supplier must deliver Goods and or Services in accordance with specifications, quantities and timeframes stated in the Order.
• The Supplier must comply with written scope, correspondence and applicable Australian Standards, legislation and safety requirements.
• The Supplier must promptly notify Avenida of any delay, variation or issue that may affect delivery, compliance or project outcomes.

4. Pricing and Payment

• Prices stated in the Order are fixed unless otherwise agreed in writing.
• Invoices must quote the Purchase Order number and clearly itemise charges.
• Payment terms are 30 days EOM from receipt of a valid invoice, subject to satisfactory delivery and acceptance.
• Any commission, rebate or referral arrangement must be agreed in writing before engagement.
• Where Avenida processes orders through its accounts on behalf of a client, payment to the Supplier is contingent upon receipt of funds from the client unless otherwise agreed in writing.

5. Insurance and Indemnity

• The Supplier must maintain workers compensation insurance where required.
• The Supplier must maintain public and product liability insurance for an amount not less than AUD $20,000,000 per occurrence.
• Certificates of currency must be provided to Avenida upon request.
• The Supplier indemnifies Avenida against claims, loss or damage arising from the Supplier’s work, personnel or equipment.

6. Warranties and Compliance

• Goods and or Services must be new unless otherwise stated and of merchantable quality.
• Goods and or Services must comply with relevant laws, standards and specifications.
• Goods and or Services must be fit for the agreed purpose.
• Defects or non-conformances identified within a reasonable period must be rectified promptly at the Supplier’s cost.

7. Health, Safety and Environment

• The Supplier must comply with WHS laws, site safety rules and environmental regulations.
• The Supplier must ensure personnel are competent, qualified and equipped with suitable PPE.
• The Supplier must immediately report incidents, injuries or environmental breaches connected with its works.

8. Delivery, Title and Risk

• Delivery must occur at the location and time specified in the Order unless otherwise agreed.
• Risk remains with the Supplier until Goods and or Services are successfully delivered and accepted.
• Title transfers to Avenida Australia or its nominated client upon full payment and acceptance.

9. Confidentiality

Both parties must keep confidential all pricing, project and client information obtained through the engagement, except where disclosure is required by law or with prior written consent.

10. Termination

Avenida may terminate the Order immediately by written notice if the Supplier breaches these terms and fails to remedy within 7 days or becomes insolvent, bankrupt or ceases trading.

11. Limitation of Liability

Avenida’s total liability to the Supplier under the Order is limited to the amount payable for the specific Goods and or Services successfully delivered and accepted. Avenida is not liable for consequential loss, loss of profit or indirect or incidental damages arising from or in connection with the Order.

12. Dispute Resolution

Any dispute arising under the Order must first be discussed in good faith between authorised representatives. If unresolved within 14 days, the matter may be referred to mediation in Perth, Western Australia before court proceedings are initiated.

13. Governing Law

The Order is governed by the laws of Western Australia and both parties submit to the exclusive jurisdiction of its courts.

14. Entire Agreement

The Purchase Order, together with referenced documents, constitutes the entire agreement between Avenida and the Supplier and supersedes prior communications or understandings.

15. Disclaimer of Role

Avenida Australia acts primarily as a procurement, coordination and supply provider. Where Avenida purchases, resells or hires Goods, its role remains administrative and commercial only. All onsite works, installation and operational use remain under the Supplier’s or Client’s control, supervision and insurance unless expressly agreed otherwise in writing.

Review Date: June 2026