Whistleblowing Policy

As part of Voltade's commitment to good corporate governance, this policy provides accessible channels and guidance for reporting suspected misconduct, and guarantees that concerns raised in good faith are investigated impartially and addressed appropriately.

This policy is open to everyone: Voltade employees and contractors, as well as third parties (customers, suppliers, business partners, and members of their value chains) who observe conduct by Voltade or its personnel that they believe to be illegal, unethical, or in breach of Voltade's policies or of a business partner's code of conduct.

Reportable concerns include, without limitation:

• Bribery, corruption, fraud, or money laundering (see our Anti-Bribery & Corruption Policy)
• Misuse of personal data or breaches of data protection obligations
• Breaches of law, regulation, or contractual obligations
• Harassment, discrimination, or unsafe working conditions
• Conflicts of interest, or violations of a customer's or partner's code of conduct
• Attempts to conceal any of the above

Reports can be submitted by email to [email protected], received directly and only by Voltade's Chief Executive Officer and handled in strict confidence.

• Anonymous reporting is accepted: reports may be made from an anonymous email account, and no reporter is required to identify themselves
• Where the concern involves the CEO, the report may be addressed to any other Voltade director
• Reports should describe the concern, the parties involved, and any supporting evidence, so the matter can be investigated effectively

All reports, including the identity of the reporter where known, are handled with the strictest confidentiality. Information is disclosed only to the extent necessary for a proper investigation or where disclosure is required by law. Anonymous reports are investigated with the same rigour as named reports.

1. Acknowledgement: reports with a reachable sender are acknowledged within five (5) business days
2. Assessment & investigation: the matter is assessed and investigated by a director or officer with no conflict of interest in the matter, impartially and without prejudgement
3. Outcome: where a violation is substantiated, Voltade takes corrective action, which may include disciplinary measures, contract termination, notification of affected business partners, and referral to the relevant authorities
4. Records: investigations and outcomes are documented and retained confidentially

Voltade strictly prohibits any form of retaliation (including dismissal, demotion, harassment, intimidation, or any other adverse treatment) against any person who raises a concern in good faith or assists an investigation, even where the concern is not ultimately substantiated. Any act of retaliation is itself a serious violation of this policy and will result in disciplinary action.