Whistleblowing Policy

1. Purpose

The purpose of this Whistleblower Policy is to establish guidelines and procedures for reporting and addressing concerns regarding unethical or illegal activities within the Group. This policy is designed to encourage employees, contractors, vendors, and other stakeholders to report any wrongdoing they may observe or become aware of without fear of retaliation. By providing a mechanism for reporting such concerns, the Group aims to maintain the highest standards of integrity, ethics, and compliance within the Group.

2. Scope

This policy applies to all employees, contractors, vendors, and stakeholders associated with the Group. It covers a wide range of concerns, including but not limited to financial impropriety, fraud, corruption, unethical conduct, safety violations, discrimination, harassment, and any other illegal or unethical activities that could harm the Group or its stakeholders.

3. Reporting Mechanisms 

3.1. Internal Reporting

Employees, contractors, vendors, and stakeholders are encouraged to report concerns related to unethical or illegal activities internally first. Reports can be made through the following channels:

• Direct supervisor or manager
• Human Resources department
• Compliance officers
• Whistleblower hotline

• External Reporting

If individuals are uncomfortable or unable to report concerns internally, they may choose to report concerns to relevant external authorities or agencies, such as regulatory bodies or law enforcement agencies. However, internal reporting is strongly encouraged as the Group is committed to addressing concerns internally first and resolving them in a timely and appropriate manner.

4. Confidentiality

The Group is committed to maintaining the confidentiality of whistleblowers to the extent allowed by law. All reports will be treated as confidential to the fullest extent possible while still allowing for a thorough investigation. The Group will not tolerate any form of retaliation against whistleblowers who make reports in good faith.

5. Investigation Process

Upon receiving a report of wrongdoing, the Group will promptly initiate an investigation. The investigation will be conducted impartially and with appropriate confidentiality. The Group will take appropriate corrective action if wrongdoing is substantiated.

6. Non-Retaliation

The Group prohibits any form of retaliation against individuals who make good-faith reports of unethical or illegal activities. Any form of retaliation, including but not limited to termination, demotion, harassment, or discrimination, will be subject to disciplinary action.

7. False Reporting

Reports that are found to be knowingly false or made with malicious intent will be subject to appropriate disciplinary action, which may include termination of employment or legal action.

8. Compliance Training and Awareness

The Group will provide training and awareness programs to educate employees, contractors, vendors, and stakeholders about this Whistleblower Policy and the importance of ethical conduct and reporting.

9. Policy Review

This policy will be reviewed periodically to ensure its effectiveness and compliance with changing laws and regulations. Any necessary updates will be made to this policy to reflect these changes.

10. Contact Information

For questions, concerns, or to report wrongdoing, please contact the Group’s Chief Risk Officer or send an email to whistleblower@zicoholdings.com.