Privacy Notice

1. Introduction

New Britain Palm Oil Limited (“NBPOL”, “we”, “us”, “our”) is committed to protecting your personal data and respecting your privacy.

This Privacy Notice explains how we collect, use, store and disclose personal data when you interact with our website, services, events, recruitment processes or other business activities.

NBPOL operates as a wholly owned subsidiary of SD Guthrie and applies Group‑aligned data protection standards.

2. Scope

This Privacy Notice applies to:

• Visitors to our website
• Job applicants
• Business partners, suppliers and contractors
• Community members and stakeholders
• Event participants and visitors to our premises

By accessing our website or providing personal data to us, you acknowledge that you have read and understood this Privacy Notice.

3. Personal Data We Collect

Depending on the nature of your interaction with us, we may collect:

• Identification details (e.g. name, nationality, ID/passport number)
• Contact details (e.g. address, email, phone number)
• Employment or recruitment‑related information
• Business or professional information
• Images or recordings (e.g. CCTV at premises, event photos)
• Technical data (e.g. IP address, cookies, browser information)

Where required, we may collect sensitive personal data (e.g. health or biometric data) strictly in accordance with applicable laws and safeguards.

4. How We Collect Personal Data

We collect personal data:

• Directly from you (forms, emails, applications, events)
• Through our website and digital platforms
• From third parties (e.g. recruitment agencies, regulators, service providers)
• From publicly available sources, where permitted by law

5. Purposes of Processing

We process personal data for legitimate business purposes, including to:

• Manage business relationships and contracts
• Process job applications and recruitment activities
• Conduct due diligence, compliance and screening
• Communicate with stakeholders and respond to enquiries
• Organise events, visits and community engagement
• Ensure workplace, site and community safety
• Comply with legal, regulatory and reporting obligations
• Prevent fraud, misconduct and security incidents

Where required by law, we will obtain your consent.

6. Lawful Basis

We process personal data based on one or more of the following:

• Performance of a contract
• Compliance with legal obligations
• Legitimate business interests
• Consent (where required)

7. Direct Marketing

We may send you communications about NBPOL or SD Guthrie activities where permitted by law.

You may opt out of marketing communications at any time by:

• Using the unsubscribe link in communications, or
• Contacting us directly (see Section 13)

8. Cookies

Our website uses cookies and similar technologies to improve functionality and user experience. Cookies may be:

• Necessary
• Analytical
• Preference‑based
• Marketing‑related

You may manage cookie preferences through your browser settings or via the cookie settings tool on our website.

For more information, please refer to our Cookies Notice (where applicable)

9. Data Sharing

We may share personal data with:

• SD Guthrie Group companies
• Service providers (IT, professional advisors, auditors)
• Business partners and contractors
• Government authorities or regulators where required

All third parties are required to protect personal data and use it only for authorised purposes.

10. International Transfers

Personal data may be transferred to countries outside Papua New Guinea, including to SD Guthrie Group entities.

Where such transfers occur, we implement appropriate safeguards to ensure adequate protection of personal data.

11. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, unless longer retention is required by law.

Examples:

• Tax and employment records: retained in line with statutory requirements
• Complaint records: retained for a defined legal period

12. Your Rights

Subject to applicable laws, you may have the right to:

• Access your personal data
• Correct or update your data
• Request deletion or restriction
• Object to processing
• Withdraw consent (where applicable)
• Lodge a complaint with a data protection authority

Residents of the EEA or UK are afforded additional rights under GDPR, where applicable.

13. Security

We implement appropriate technical and organisational measures to safeguard personal data against loss, misuse, unauthorised access or disclosure.

14. Contact Us

If you have questions, requests or concerns about this Privacy Notice or our handling of personal data, please contact:

Email: nbpol.info@sdguthrie.com

Address:
New Britain Palm Oil Limited
NBPOL Corporate Office
Mosa, West New Britain Province
Papua New Guinea

15. Updates to This Notice

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

Last updated: 5 May 2026