Whistleblowing Policy

VENOVOX is committed to a high level of ethical standards and integrity in conducting its business and we encourage ethical conduct as part of our corporate culture with emphasis on sincerity, transparency and fairness. This serves to enhance the trust and confidence in the business operations and performance.

1. Purpose

This Whistleblower Policy and Procedure ("Policy") seeks to enhance corporate governance by fostering an environment of integrity and ethical behavior, allowing any illegality, improper conduct, or wrongdoing in the company to be exposed. It provides a formal, confidential channel for employees, vendors, contractors, or agents to report in good faith without fear of Detrimental Action.

2. Scope

This Policy applies to all employees and related parties. Reports can be made by internal or external individuals who are aware of any improper conduct committed by an employee.

3. Oversight and Ownership

The Audit Committee oversees this Policy, while day-to-day responsibility lies with the Internal Auditor, who is responsible for updates and distribution.

4. What is Whistleblowing

Whistleblowing is the voluntary disclosure of malpractice or wrongdoing. Improper Conduct includes criminal acts, financial misstatements, ethical breaches, corruption, or significant harm to the company or individuals.

• Criminal acts (e.g., breach of trust, extortion, sabotage)
• Financial misrepresentation or fraud
• Corruption or unauthorized disclosure of confidential information
• Abuse of power, misconduct, or concealment of the above

5. Whistleblower Protection

Protection is granted unless it is found that the report was made with malicious intent or bad faith.

6. Confidentiality

Whistleblower identity and information are kept confidential, only shared on a need-to-know basis with approval from the Audit and Risk Committee.

7. Anonymous Disclosure

Anonymous reports are accepted and encouraged to contain as many details as possible for effective investigation.

8. Rewards

VENOVOX may reward whistleblowers (if identity is known) for disclosures that lead to detection of improper conduct.

9. Reporting Procedure

Reports must be factual, with as much detail as possible. Whistleblowers can report via meeting, phone, email, or post to:

10. Investigation

Investigations will be led by the Internal Audit Department or independent function as assigned. Results will be reported to the Audit and Risk Committee and updates shared with the Board of Directors. Whistleblowers (if identified) will be informed of the outcome.