Whistleblowing Policy Statement

IFCA Group is committed to a high degree of integrity, transparency, and good governance in the conduct of its operations. In view of this, the Whistleblower Policy has been established to encourage and provide an avenue for a whistleblower to raise concerns of any wrongdoings without fear of reprisals.

The objective of the Policy

The policy is:

• To help develop a culture of accountability and integrity within IFCA Group of Companies
• To provide a safe and confidential avenue for ALL employees, external parties, and other stakeholders to raise concerns about any poor or unacceptable practice or misconduct
• To reassure whistleblowers that they will be protected from detrimental action or unfair treatment for disclosing concerns in GOOD FAITH;
• To deter misconduct and promote standards of good corporate practices.

Scope of the Policy

This Policy governs the disclosures, reporting, and investigation of misconduct within the Group as well as the protection offered to the persons making those disclosures from detrimental action in accordance with the Whistleblower Protection Act 2010.

The scope of the policy applies to IFCA Group´s staff, Board members, and other stakeholders.

Misconduct includes:

• Criminal offenses like corruption, bribery, fraud;
• Intentional misrepresentations, misstatements, omissions, directly or indirectly affecting financial statements; or
• Failure to comply with any legal obligations;
• Danger to the health and safety of any individual or the environment;
• Improper conduct or unethical behavior; or
• Attempts to conceal any of the above.

Protection to Whistleblower

It is the Group´s policy to provide the whistleblower protection in terms of confidentiality of the information and safeguard the whistleblower from any act of interference that may be detrimental to the whistleblower. The Group assures that all reports will be treated with strict confidentiality and upon verification of genuine cases, the prompt investigation will be carried out.

Procedures of IFCA Group Whistleblowing Policy

Any person may report allegations of suspected serious misconduct or any breach or suspected breach of law or regulation that may adversely impact the Company.

Notification on the Outcome of the Disclosure

The Group reserves the right not to inform the whistleblower of the precise action plan and/or the outcome
of the investigation as this may infringe a duty of confidentiality owed to someone else.

Communication Channel

The Whistleblower should initially communicate a Reportable Misconduct to the Chairman of the Company or Chairman of the Audit Committee in writing.

IFCA Group also has provided various avenues which employees, vendors, or contractors are encouraged to use to report allegations of wrongdoing or unethical business behavior such as follows:

Required Evidence

The Whistleblower should, at a minimum, be required to provide in the complaint or report, in writing, information regarding the type of activity or conduct that constitutes the Reportable Misconduct, identify the person(s) suspected as being involved, when it occurred, and who was affected. The information should be first-hand knowledge of the facts disclosed in the Report.

In the event there is insufficient evidence to support their allegation, the Whistleblower should not be discouraged from making a Report.

Process of Making Disclosure