Environmental Policy

National Digital — The Trustee for Australian Business Trust, ABN 13 744 838 758

1. Purpose and commitment

National Digital is committed to minimising the environmental impact of its operations and to
complying with the Environmental Protection Act 1994 (Qld) and all other applicable
environmental legislation.

We are a remote-first software consultancy. We operate no manufacturing, no vehicle fleet, no
warehousing and no workshop, and we hold no environmental authority or licence because our
activities do not require one. Our environmental footprint is concentrated in three places:
the energy used by the cloud infrastructure we run, the electronic equipment we buy and
retire, and business travel. This policy addresses those three, and we would rather be
specific about a small footprint than generic about a large one.

2. Scope

This policy applies to all directors, employees and contractors of National Digital, and to the
infrastructure we operate on behalf of clients.

3. Our impacts and how we manage them

3.1 Cloud infrastructure — our largest impact

Nearly all of the energy attributable to our work is consumed in data centres running the systems
we build and host. We manage this by:

• Consolidating workloads. We have progressively migrated client applications from
  individually provisioned servers onto shared, efficiently utilised hosts. Idle and duplicated
  infrastructure is decommissioned rather than left running, which reduces both cost and energy
  consumption.
• Preferring static and edge delivery. Where a site does not require server-side processing,
  we deliver it as static content from an edge network rather than keeping an application server
  running continuously.
• Right-sizing. Environments are provisioned to measured need rather than to a generous
  estimate, and non-production environments are shut down when not required.
• Choosing providers with published commitments. We favour infrastructure providers that
  operate on renewable energy or publish credible emissions-reduction commitments, and we consider
  this alongside cost, performance and data-sovereignty requirements when selecting a provider.

Efficient infrastructure is also cheaper infrastructure, so this commitment is durable — it is
aligned with our commercial interest rather than working against it.

3.2 Electronic equipment and e-waste

Computing equipment is our main material purchase. We:

• Buy for longevity and keep devices in service for their full useful life rather than replacing on a cycle
• Repair and upgrade in preference to replacing where it is economic to do so
• Dispose of retired equipment through e-waste recycling services, never to general waste
• Securely erase all data-bearing devices before disposal or resale

3.3 Business travel

Remote-first working substantially reduces commuting and travel. We conduct client meetings by
video conference by default and travel only where physical presence is genuinely required. Where
travel is necessary, we prefer direct routes and combine purposes in a single trip.

3.4 Paper and consumables

We operate a paperless business. Contracts, invoices, specifications and records are created,
exchanged and stored electronically. Printing is rare and by exception.

3.5 Office and home workspaces

We do not operate a commercial office. Workers operate from home workspaces where energy and
waste are managed as part of the household. We encourage energy-efficient equipment settings and
powering down equipment outside working hours.

4. Working with purchasers

We will cooperate with the reasonable requests of clients and purchasers to achieve their
environmental objectives, including targets for recycling, sustainability and green practices, and
will report on our environmental practices where a contract requires it.

Where a client's own environmental objectives can be advanced by how we build — for example by
reducing the compute footprint of an application, extending the service life of existing hardware,
or replacing a paper-based process with a digital one — we will identify and propose it. Digitising
manual, paper-based council processes is itself an environmental benefit, and we regard it as part
of the value we deliver rather than incidental to it.

5. Responsibilities

The CEO is accountable for environmental performance and for approving this policy.

All workers and contractors are responsible for applying it in their daily work, particularly
in provisioning infrastructure responsibly and disposing of equipment correctly.

6. Compliance and continuous improvement

We monitor our obligations under applicable environmental legislation and comply with them. We are
not currently certified to AS/NZS ISO 14001 and do not hold a formal environmental management
system beyond this policy; given our size and the nature of our operations, we consider a
documented policy with specific, applicable controls to be proportionate.

We review our infrastructure footprint as part of routine cost and architecture review, which
gives us a regular, practical mechanism for identifying reductions.

7. Review

This policy is reviewed annually, and additionally on any material change to our operations, such
as the establishment of commercial premises, the acquisition of vehicles, or a change in our
principal infrastructure providers.

Cameron Young
Chief Executive Officer, National Digital
17 August 2026