Whistleblowing policy

POLICY STATEMENT

This Policy applies to the management, employees, contractors, contract staff, consultants, and trainees (collectively referred to as "Employees") of AFEX Global HoldCo Limited and any of its related or affiliated entities (collectively referred to as "AFEX" or the "Company"). AFEX is committed to conducting its business fairly, honestly, transparently, and in compliance with all legal and regulatory obligations. We expect all AFEX management, employees, and anyone acting on its behalf to uphold the highest standards of ethical business behavior. However, as all organizations face varying levels of risks, a culture of openness and accountability is essential to prevent frequent recurrence of incidents and address them accordingly upon occurrence.

A key aspect of ensuring and maintaining AFEX's commitment to integrity and fairness is providing a robust whistleblowing policy and reporting channel to ensure all employees can report any wrongdoing in confidence. At AFEX, we encourage employees to report any concerns as they arise; such concerns can be of any nature, including any matters related to AFEX's personnel, customers, suppliers, and other third parties.

The aim of this policy is to:

• Encourage and empower employees to report suspected wrongdoings that violate AFEX policies and the law, knowing that their concerns will be efficiently addressed, treated with utmost confidentiality, and investigated appropriately.
• Ensure employees understand the reporting mechanism for any incidents.
• Reassure employees of their ability to raise genuine concerns without any fear of reprisals.
• Continue to foster a culture of openness within the organization.
• Ensure AFEX is in compliance with the relevant legislations.

This policy is not intended to question AFEX's financial decisions or business strategy.

SCOPE

This policy applies to all AFEX employees, irrespective of their office location and subject to local laws. It governs actions by employees and any concerns raised against customers, suppliers, or any other third parties interacting with AFEX.

WHAT TYPE OF MISCONDUCT SHOULD BE REPORTED?

Any unlawful, dishonest, or unethical conduct must be reported as soon as possible and may include the following:

• Criminal activity or offenses, including fraud, theft, and embezzlement.
• Bribery or corruption.
• Blackmail.
• Financial malpractice, impropriety, or mismanagement.
• Facilitating tax evasion.
• Failure to comply with any legal, professional obligation, or regulatory requirement.
• Actions likely to damage AFEX's reputation or financial well-being.
• Actions that endanger the health and safety of AFEX personnel or the public.
• Actions that cause damage to the environment.
• The deliberate provision of false information to public officers.
• Unauthorized disclosure of confidential information.
• The deliberate concealment of information relating to any of the above matters.
• Any retaliatory acts against whistleblowers.
• Harassment of any form.

This list is not exhaustive. Employees are encouraged to report any concerns of misconduct. AFEX operates an open-door policy and promotes transparency and fairness.

REPORTING MECHANISMS

Employees can report concerns using the following mechanisms:

Option 1 - Line Manager

An employee can make a direct report to their line manager orally or in writing for further investigation. If the concern directly implicates the line manager, alternative reporting routes should be used.

Option 2 - Appropriate Parties

If the first option is not feasible, an employee can report directly to the Head of the Legal Squad, the Vice President of Risk, Audit and Assurance, or any executive management member for further investigation and resolution.

ADDRESSING CONCERNS

Upon raising a concern, the respective senior management will decide who is best placed to investigate the matter. Depending on the severity of the incident, the GCEO may also be informed. AFEX will keep the reporting employee updated on the investigation's progress while maintaining confidentiality.

If an investigation finds that the whistleblower knowingly made false allegations, disciplinary action will be taken.

PROTECTION AGAINST RETALIATION

AFEX ensures that genuine concerns raised in good faith can be reported without fear of retaliation. Any harassment, victimization, or retaliation against a whistleblower will be treated as a serious offense and may result in disciplinary action.

ANONYMOUS REPORTING

To protect whistleblower anonymity, AFEX guarantees that anonymous reports will not be traced back to the complainant unless they choose to disclose their identity. Employees can submit anonymous complaints through a Whistleblowing link on the HRMS landing page: (https://talentmanagement.africaexchange.com/). The whistleblower can submit grievances and upload supporting documents anonymously.

The Talent Management, Risk Management, and Legal teams will evaluate and investigate anonymous complaints and take appropriate corrective action if warranted.

GOOD FAITH

Reports must be made honestly and with the intention of addressing concerns. Whistleblowers acting in good faith will not face any action even if their concern turns out to be unfounded. However, malicious or knowingly false reports may lead to disciplinary actions, including dismissal or legal proceedings.

CONFIDENTIALITY

All reports will be handled in strict confidence, and the identity of the whistleblower will only be disclosed on a need-to-know basis for investigation purposes.