Corporate compliance policy

Policy document number: CCP0004 Version: 12 Last updated: 14 July 2026

1. Overview

1.1 At a glance

Sydney Water is committed to comply with all relevant laws and other voluntary commitments that we have adopted (compliance obligations).

To be consistent with the International Standard for Compliance Management Systems (ISO 37301:2021), including meeting the intent of this Corporate Compliance Policy, Sydney Water maintains a Corporate Compliance Management System (CCMS). The CCMS provides the framework for Sydney Water to meet its compliance obligations.

1.2 Scope

This policy applies to all Sydney Water staff (including agency hire), partners and contractors.

1.3 Objective

This policy declares Sydney Water's commitment to comply with all identified legislative requirements as well as any voluntary compliance commitments we have made.

The policy covers actions taken to manage, implement, monitor and report on compliance with obligations including:

• Sydney Water Act 1994
• Sydney Water Operating Licence
• legally enforceable instruments that apply to Sydney Water
• voluntary commitments to other standards and codes.

2. Policy in detail

Sydney Water is committed to comply with all relevant laws and other voluntary commitments which is consistent with our values and risk appetite. We do this because we are committed to deal fairly with customers, stakeholders, suppliers, partners, contractors and competitors. We also commit to protect the safety of our staff, public health and the environment in which we operate.

Compliance is the responsibility of everyone working for or on behalf of Sydney Water. If Sydney Water, its staff, partners and contractors do not meet their compliance obligations, statutory actions including penalties may be imposed on Sydney Water and on individual Directors, staff or contractors. Sydney Water employees who knowingly ignore processes, leading to a compliance breach, might be fined by a court and face disciplinary action.

As reflected in the Board's risk appetite statement, Sydney Water will operate in accordance with our legal and regulatory requirements and expects all engaged contractors to do the same. Staff, partners and contractors should follow set procedures to ensure compliance with both our legal requirements and non-statutory requirements we have voluntarily committed to meet. Any failure to comply with operational processes is taken very seriously.

Sydney Water expects and trusts its staff, partners and contractors to be ethical and has no tolerance for fraud or corruption.

The Corporate Compliance Management System (CCMS) provides the framework for Sydney Water to identify and monitor its compliance obligations. The Audit and Risk Committee is responsible for the review and endorsement of the CCMS and this policy. The Managing Director is responsible for its approval.

Continuous improvement is an important component of the CCMS to ensure ongoing compliance. The CCMS is reviewed periodically to ensure appropriate processes are in place to identify, manage and report on compliance obligations.

The continual improvement process includes the proactive reporting of potential compliance issues. Sydney Water promotes a positive reporting culture where issues are reported openly and dealt with in accordance with our Fair and Just process. Any compliance issue should be notified to compliance@sydneywater.com.au for review.

3. Definitions