Deed of Release

JULIETTE BOOTH

and

J. WALTER THOMPSON AUSTRALIA

JULIA GOLDIE

NICK MUNCASTER

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Level 26, 530 Collins Street, Melbourne VIC 3000 Australia Telephone +61 3 8644 3500
PO Box 3, Collins Street West VIC 8007 Australia Facsimile 1300 365 323 (Australia) +61 3 9034 3257 (International)
DX 564 Melbourne hwlebsworth.com.au
Deed of Release
Date

Parties JULIETTE BOOTH of 75 Cotham Road, Kew, VIC 3101

(Applicant)

and

J. WALTER THOMPSON AUSTRALIA PTY LIMITED (ACN 056 510

868) c/- of HW L Ebsworth Lawyers, Level 26, 530 Collins Street
Melbourne VIC 3000

JULIA GOLDIE c/- of HW L Ebsworth Lawyers, Level 26, 530 Collins

Street Melbourne VIC 3000

NICK MUNCASTER c/- of HWL Ebsworth Lawyers, Level 26, 530 Collins
Street Melbourne VIC 3000

(together the Respondents)

Background A. The Applicant was employed by J. W alter Thompson Australia Pty

Ltd pursuant to a written employment contract (Employment
Contract) from 10 August 2015 to 17 February 2017 in the position
of Stylist (Employment).

B. J Walter Thompson Australia Pty Ltd terminated the Employment

on 17 February 2017 by reason of Redundancy (Termination).

C. The Applicant filed a general protections application (C2017/1334)

dated 10 March 2017 against the Respondents (Proceeding).

D. With an express denial of any liability, the parties have agreed to

settle all matters relating to the Employment, Employment
Contract, Proceeding and Termination on the terms set out in this
Deed.

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1. Definitions

1.1 In this Deed (including the background) unless the context otherwise requires:

Associated has the meaning given to that term in the Corporations Act 2001
Entities (Cth).

Circumstances means the Employment, Employment Contract, Proceeding and

Termination.

Claims means all actions, claims, demands, suits, complaints, liabilities,

debts, sums of money, damages, judgments and costs.

Employment has the meaning given in the Background to this Deed.

Employment has the meaning given in the Background to this Deed.

Contract

Group means J Walter Thompson Australia Pty Limited and its

Associated Entities from time to time.

Proceeding has the meaning given in the Background to this Deed.

Settlement means the payment at clauses 2.1(a).

Payment

Statement of means the Statement of Service set out at the Schedule.

Service

Termination has the meaning given in the Background to this Deed.

2. Obligations on Respondents

2.1 Within 21 days of the Respondents' solicitors, HWL Ebsworth Lawyers, receiving an
original of this Deed executed by the Applicant and subject to the Applicant strictly
complying with the terms of this Deed, J W alter Thompson Australia Pty Limited will:

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 (a) pay to the Applicant a sum of $9,500 (as general damages and without
deduction of taxation); and

(b) provide the Applicant with a Statement of Service in the form set out in the
Schedule of this Deed.

2.2 Without limiting clause 4.1, the Applicant acknowledges that the Settlement Payment is
inclusive of and paid in full and final satisfaction of any and all payments, entitlements or
benefits that J W alter Thompson Australia Pty Limited owes to the Applicant in
connection with the Employment, the Employment Contract and the Termination.

3. Obligations on Applicant

3.1 The Applicant warrants that she has returned to the J Walter Thompson Australia Pty
Limited all of its property in her possession, custody or control.

4. Release and Discharge

4.1 In consideration of the Settlement Payment, the Applicant unconditionally releases and
discharges the Respondents, each person and entity in the Group and their respective
directors, employees, servants, agents, shareholders, assigns and insurers from all
Claims no matter how the same arose and on every count which now exists or which
but for this Deed would exist in relation to or arising from or in connection with any
matter referred to in the Circumstances or any other matter referred to or concerning the
same subject matter as that referred to in the Background to this Deed, save for any
claim under workers' compensation legislation or superannuation guarantee legislation.

5. Confidentiality of Deed

5.1 The parties each covenant that they will not disclose the Settlement Payment or the
terms of this Deed to any other person or persons, except:

(a) as required by law;

(b) for the purpose of enforcement of this Deed;

(c) where the information disclosed has come into the public domain through no
fault of the relevant party.

5.2 Notwithstanding anything to the contrary, nothing in this Deed prevents the disclosure of
the terms of this Deed of any matter relating to the settlement of the Proceeding to
lawyers, accountants, auditors, insurers/reinsurers (if any), together with such
insurers/reinsurers third party service providers, actuaries or intermediaries (collectively
Recipients) or regulators, provided the disclosure of the information is reasonably
necessary to effectuate the terms of this Deed, or is required for tax, financial reporting,
or governmental compliance purposes, or to transact the business of insurance. Prior

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 to disclosure, the Recipients must be informed of the confidential nature of the
information and must agree to keep such information confidential.

6. Non-Disparagement

6.1 The Applicant agrees not to discredit or disparage the Respondents, the Group or their
respective directors, applicants, servants, agents, shareholders, assigns and insurers in
relation to or in connection with the Circumstances or any other matter referred to or
concerning the same subject matter as that referred to in the Background to this Deed.

6.2 J Walter Thompson Australia Pty Limited will use its reasonable endeavours to ensure
that their directors and officers do not discredit or disparage the Applicant in relation to
any matter arising out of the Circumstances or any other matter referred to or
concerning the same subject matter as that referred to in the Background to this Deed.

6.3 Julia Goldie agrees not to discredit or disparage the Applicant in relation to any matter
arising out of the Circumstances or any other matte referred to or concerning the same
subject matter as that referred to in the Background to this Deed.

6.4 Nick Muncaster agrees not to discredit or disparage the Applicant in relation to any
matter arising out of the Circumstances or any other matte referred to or concerning the
same subject matter as that referred to in the Background to this Deed.

7. Warranties

7.1 The Applicant warrants that:

(a) this Deed is voluntarily entered into;

(b) she has consulted with her legal advisors as to the nature and effect of this
Deed;

(c) she understands the legal significance and effect of executing this Deed

(d) none of the Respondents, the Group or their respective directors, employees,
servants, agents, shareholders, assigns and insurers have made any promise,
representation or inducement or been party to any conduct material to the entry
into this Deed other than as set out in this Deed; and

(e) she is aware that the Respondents is relying upon these warranties.

8. General

8.1 This Deed may be pleaded as a full and complete defence by the Respondents, each
person and entity in the Group and their respective directors, employees, servants,
agents, shareholders, assigns and insurers, including as a bar to any claim or action

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 commenced, continued or taken by or on behalf of the Applicant in connection with any
of the matters referred to in this Deed.

8.2 J Walter Thompson Australia Pty Limited holds the benefit of this Deed for itself and on
trust for each person and entity in the Group and their respective associates, directors,
employees, servants, agents, shareholders, assigns and insurers.

8.3 This Deed is governed by and interpreted in accordance with the laws of Victoria and
each party submits to the exclusive jurisdiction of the Courts of Victoria and the
Commonwealth of Australia.

8.4 This Deed is on a without prejudice basis until executed by all parties.

8.5 If any provision of this Deed is or becomes invalid or unenforceable for any reason,
then:

(a) where the offending provision can be read down so as to give it a valid and
enforceable operation of a partial nature, it must be read down to the minimum
extent necessary to achieve that result; and

(b) in any other case the offending provision must be severed from these terms, in
which event the remaining provisions of these terms operate as if the severed
provision had not been included.

8.6 This Deed may be executed in any number of counterparts and all counterparts, taken
together, constitute one instrument. A party may execute this Deed by executing any
counterpart.

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Signing page

Executed as a deed

Executed by J. WALTER THOMPSON

AUSTRALIA PTY LIMITED in accordance
with section 127 of the Corporations Act
2001 (Cth) by:

Signature of Director Signature of Director/Company Secretary

Full name (print) Full name (print)

Signed, sealed and delivered by JULIA

GOLDIE in the presence of:

Signature of witness Signature of Julia Goldie

Full name of witness (print)

Address of witness (print)

Signed, sealed and delivered by NICK

MUNCASTER in the presence of:

Signature of witness Signature of Nick Muncaster

Full name of witness (print)

Address of witness (print)

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Signed, sealed and delivered by
JULIETTE BOOTH in the presence of:

Signature of witness Signature of Juliette Booth

Full name of witness (print)

Address of witness (print)

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Schedule

[Insert J. Walter Thompson Australia Pty Limited letterhead]

[insert date]

To who m i t ma y c o nc e r n

S t a t e me nt o f S e r v i c e

I , He i di Mi t c he l l , c o nf i r m t ha t J ul i e t t e Bo o t h wa s e mpl o y e d by t he
Co mpa ny f r o m 10 t h Aug us t 2015 unt i l
17 t h F e br ua r y 2017 i n t he po s i t i o n o f

S t o c k r o o m Co - o r di na t o r / S t y l i s t .

J ul i e t t e s dut i e s i nc l ude d:

Pr e pa r i ng pr o duc t f o r pho t o s ho o t s
S t y l i ng s t i l l l i f e pr o duc t o n pho t o s h o o t s
S e t t i ng up a nd pa c k i ng do wn s e t s
Pa c k i ng s t o c k f o r r e t ur n t o c l i e nt .

J ul i e t t e s po s i t i o n wa s ma de r e dunda nt a nd t he e mpl o y me nt e nde d

f o r t ha t r e a s o n o n 17t h F e br ua r y 2017. We wi s h J ul i e t t e a l l t he

be s t wi t h he r f ut ur e e nde a v o ur s .

He i di Mi t c he l l
Ta l e nt Ma na g e r

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