PURPOSE

• The purpose of this policy is to provide individuals with a mechanism to report any actions or behaviors that they believe violate laws, regulations, ethical standards, or the Company’s policies and procedures.

SCOPE

• This policy applies to all employees, contractors, suppliers, clients, and any other person associated with the Company (“whistleblowers”). It covers all business activities, both domestic and international.

REPORTING CHANNELS

• Whistleblowers are encouraged to report their concerns through established and confidential reporting channels, which may include direct communication with supervisors, management, the human resources department, or the designated whistleblower hotline or email address.

CONFIDENTIALITY AND ANONYMITY

• The Company is committed to protecting the confidentiality of whistleblowers to the extent permitted by law. Whistleblowers have the option to remain anonymous when reporting concerns, and the Company will make every effort to maintain confidentiality throughout the investigation process.

NON-RETALIATION

• The Company strictly prohibits any form of retaliation against whistleblowers who report concerns in good faith. Whistleblowers are protected from adverse employment actions or any form of retaliation, and the Company is committed to taking appropriate measures to prevent and address retaliation.

INVESTIGATION PROCESS

• Reports received under this policy will be promptly and thoroughly investigated. The Company will appoint an individual or team to conduct the investigation. Whistleblowers may be contacted for additional information during the investigation, and confidentiality will be maintained as much as possible.

REPORTING FALSE CLAIMS

• Making false or malicious allegations is a serious violation of this policy. Individuals who intentionally make false reports will be subject to disciplinary action.

COMMUNICATION AND AWARENESS

• The Company will communicate the existence of this Whistleblowing Policy to all stakeholders and provide training to employees to ensure awareness and understanding of the policy and reporting procedures.

LEGAL COMPLIANCE

• This policy is designed to comply with all applicable whistleblowing laws and regulations, including the protection measures provided for whistleblowers.

REVIEW AND UPDATE

• This policy will be reviewed periodically to ensure its effectiveness and relevance. Amendments may be made to reflect changes in applicable laws or business practices.

PROCESS RESPONSIBILITIES

• The responsibilities for preparing, reviewing, issuing, filing, and updating this policy and related processes fall under the obligation of the Director of Operations or a duly appointed representative. The monitoring, measurement, and continuous improvement of the procedure or process are the responsibility of the Compliance Officer or a duly appointed representative.