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Whistleblower Policy
Whistleblower Policy
Overview and Background
Wandoo Finance Group (which consists of the Parent Company Wandoo Finance SIA and all subsidiaries controlled by it) is firmly committed to maintaining the highest standards of ethics and integrity across all business practices. Recognizing that these values are foundational to its success and reputation, Wandoo Finance Group introduces this Whistleblowing Policy ('Policy') to actively encourage the reporting of concerns related to its operations, workplace culture, and ethical practices. This Policy not only provides a crucial framework for identifying and addressing potential unethical, corrupt, or illegal actions but also seeks to protect Wandoo Finance Group from financial, legal, and reputational risks. By fostering an environment where concerns can be safely raised, Wandoo Finance Group aims to reinforce its commitment to responsible, transparent, and accountable business practices.

Furthermore, Wandoo Finance Group seeks to do business with partners that share its values, strives for continuous and sustainable improvement in working conditions and practices and complies with the legal norms of the European Union (“EU”) as well as all applicable national laws. Therefore, Wandoo Finance Group expects that its suppliers and their subcontractors deal with their employees, their teams, in a legal, ethical, and equitable manner, thus Wandoo Finance Group seeks to do business only with partners that comply with the laws of the EU and the countries in which Wandoo Finance Group services are provided.
Definition of Whistleblowing
A Whistleblower is an individual who has reported any unethical, illegal, or improper conduct, believing that the information is true, and has obtained this information while performing his/her work duties or establishing a legal relationship in relation to his/her work duties, that may endanger public interest, organizational integrity, or employee welfare (“Report”). This includes actions that could mislead the public about the company’s financial health, involvement in fraudulent activities, or other information that, if misrepresented, might harm the company’s reputation or stakeholders.

A whistleblowing disclosure can include any concern about Wandoo Finance Group, its clients’ or suppliers’ work, values, people or policies.

For a Report to be an eligible disclosure, and therefore eligible for protection under the Whistleblower regime and this Policy, it must contain information based on which the Whistleblower has objectively reasonable grounds to suspect concerns, misconduct or an improper situation / circumstance in relation to Wandoo Finance Group, including the conduct of its employees or officers.

A non-exhaustive list of examples of Reports that can qualify as eligible (whistleblowing) disclosures are potential violations of laws or regulations; criminal acts (e.g., theft, corruption, bribery, market abuse); inappropriate gifts or payments to clients or other third parties, including vendors; inaccuracies in financial statements or statements to the firm’s auditors; anti-competitive behavior or otherwise dishonest or unethical behavior; fraud, negligence, default, breach of trust or breach of duty; systemic issues that a regulator should know about to properly perform its functions; business behavior or practices that may cause consumer harm; tax-related misconduct; a breach of a protection described in this Policy; unauthorized disclosure, insider trading or other misuse of confidential information; activities that endanger someone's health and safety; risk of or actual damage to the environment; miscarriage of justice; discrimination, severe bullying, severe harassment, physical violence, threats, and sexual harassment; unethical behavior; and deliberate concealment of any of the mentioned before. Notwithstanding the above, the examples provided in this Policy are not intended to be exhaustive, and Wandoo Finance Group encourages anyone who is aware of potential wrongdoing to raise their concern, even if they are unsure whether this Policy specifically applies.
Reporting Potential Misconduct
Wandoo Finance Group offers an open-door policy and encourages everyone to share their questions, concerns, suggestions, or complaints. Employees and external stakeholders have the possibility of reporting suspected misconduct securely and confidentially through a confidential and anonymous system which makes it easy to report various misconducts.

Wandoo Finance Group has implemented a specifically designed Reporting Channel which is established, and operated in a manner that ensures the completeness, integrity and confidentiality of the information and prevents access thereto by non-authorized persons.

Reports may be submitted via https://wandoofinance.trusty.report/, a secure platform managed by an independent third party that ensures confidentiality and prevents unauthorized access (“Reporting Channel”).Reports can be submitted online, and users may report on details of misconduct, including parties involved, dates, and locations; upload relevant files or images and choose whether they wish to stay anonymous.Upon submission, Whistleblowers receive a unique case number and a password, enabling them to check their case’s progress and provide additional information if necessary. Reporting Channel is not a replacement for emergency services or law enforcement.
Review of the Reports
Wandoo Finance Group Reporting Channel is monitored and reviewed by a competent Whistleblower Report Coordinator.

The Whistleblower Report Coordinator manages independent and secure external reporting channels for Reports handling and acknowledges that receipt of the Report within seven days of receipt of a Report, unless the reporting person explicitly requested otherwise, or the competent authority reasonably believes that acknowledging receipt of the Report would jeopardize the protection of the reporting person's identity.

All further follow-up, concern investigation and feedback to the persons triggered by the Report are done in accordance with the procedures provided for under national law. Information contained in the Report is transferred in due time to competent institutions, bodies, offices or agencies, as appropriate, for further investigation, where provided for under EU or applicable national law.
Processing of Personal Data
During this Policy, Wandoo Finance Group, as personal data controller, will process personal data contained in the Reports. Any processing of personal data carried out for the fulfilment of this Policy will be carried out in accordance with Regulation (EU) 2016/679 (GDPR).

To investigate the Reports and fulfill its legal obligations, Wandoo Finance Group may process any personal data contained in the Report and in the evidence supporting it. This may include the name, surname, contact details of the reporting person (if the report is not anonymous) and any other information contained in the Report. In specific cases, when reasonably required Wandoo Finance Group may also share the information contained in the Report with certain team members of other Wandoo Finance Group companies, for example, to carry out the investigation process, gather evidence, and provide legal support. If required, Wandoo Finance Group may share the Report and any supporting evidence with government bodies and institutions, for example, to report illegal activities or commence legal proceedings.

For the management and support of the whistleblowing process, Wandoo Finance Group cooperates with a third-party service provider Trusty AG, located in Zug, Switzerland. When providing their services to us, they are operating as Wandoo Finance Group’s data processor, based on Wandoo Finance Group instructions, and are contractually bound by strict confidentiality requirements.Wandoo Finance Group will retain information associated with the Report and its investigation for 10 (ten) years as of the date of concluding the investigation. If the Report is not deemed to be a Whistleblower’s Report, the data is retained for 3 (three) years. If necessary, personal data may be retained for a longer period in accordance with the applicable laws. For example, the period may be extended, if personal data has been provided to government bodies and institutions and its retention is required for legal proceedings.

In accordance with the GDPR Whistleblowers have certain rights in respect to the personal data Wandoo Finance Group processes during the whistleblowing process. These rights provide that Whistleblowers can request access to their personal data and ask for details on its processing; correct incorrect or inaccurate data or ask to delete their data. Please note that Wandoo Finance Group will not be able to delete data that it is required to process and retain in accordance with applicable law or that may be necessary for legal proceedings.

Given the specific nature of the whistleblowing process and Wandoo Finance Group’s legal obligation to ensure the protection and anonymity of the Whistleblower, Wandoo Finance Group may restrict certain data subject rights, which are ensured by the GDPR.

To exercise these rights, Whistleblowers can submit a written request to Wandoo Finance Group by sending it to e-mail address dpo@wandoofinance.com. Wandoo Finance Group will process the request within 30 days and provide an answer. When receiving requests for the exercise of rights, Wandoo Finance Group will verify a person’s identity, evaluate the request, and execute it in accordance with the applicable legal norms. Please note that Whistleblowers have the right to lodge a complaint with a local data protection supervisory authority.
Anonymity and Anti-Retaliation
Wandoo Finance Group does not tolerate discrimination or retaliation against persons who in good faith make a Report or participate in an investigation, therefore, it uses effective, confidential, and secure reporting channels and thereby ensures that Whistleblowers are protected effectively against retaliation.

If a person believes that they have been retaliated against for reporting or participating in an investigation, they should immediately contact Wandoo Finance Group Reporting Channel. All such Reports will be investigated confidentially.
Policy Application and Review
The Policy applies to whistleblowing disclosures received from internal and external sources, including all employees, contractors, service providers, clients, business partners, external stakeholders, or other associated persons who, during their direct or indirect collaboration with Wandoo Finance Group, may be faced with or may suspect any misconduct (including but not limited to any criminal offense, administrative violation or other violation of legal norms or violations of binding ethical or professional norms).

If applicable laws prescribe stricter rules, restrictions or obligations than provisions of this Policy, the stricter rules, restrictions or obligations under applicable laws shall prevail.

The provisions of this Policy may be amended and/or supplemented by a resolution of the Board. Amendments and supplements will enter into force on the day when they are adopted unless specified otherwise.

The Policy is reviewed annually or updated as needed.

All subsidiaries controlled by the Parent Company implement this Policy with the only change being the adaptation of the document to the legal framework of their country of registration.
This Whistleblower Policy is effective as of 15th November 2024.