1. Introduction

At Certari Asset Management Limited (“Certari”), we are committed to the highest standards of integrity and ethical conduct. This Whistleblowing Policy provides a structured and secure mechanism for employees, contractors and other stakeholders to report concerns about impropriety, unethical behaviour, fraud, or violations of law, policy or regulatory requirements without fear of retaliation.

This policy is designed to support transparency, protect whistleblowers, and ensure that all reports are handled fairly and confidentially.

2. Purpose

The objectives of this policy are to:

a. Encourage reporting of suspected or actual wrongdoing in a timely manner;

b. Provide a clear and accessible reporting process;

c. Protect whistleblowers from retaliation or victimisation;

d. Ensure that reports are investigated thoroughly, fairly, and objectively;

e. Support compliance with applicable laws and internal policies.

3. Scope and Application

This policy applies to all employees (full-time, part-time, temporary), contractors, consultants, interns, vendors and third parties acting for, or on behalf of, Certari.

a. It covers concerns about conduct that may:

b. Constitute a violation of law, regulatory requirements or internal policy;

c. Represent financial misconduct, fraud, corruption or bribery;

d. Involve misuse of company assets or resources;

e. Risk public or stakeholder harm or reputational damage;

f. Involve health and safety violations or unethical behaviour.

4. Definition of a Whistleblower

A whistleblower is any person who reports information they reasonably believe demonstrates a wrongdoing, unethical conduct, illegal activity or policy violation. A whistleblower is not responsible for conducting investigations or determining fault — that responsibility lies with designated Certari officers.

5. What Should Be Reported

Concerns raised should be about matters where the reporting party has a reasonable belief that wrongdoing has occurred. Examples include:

a. Fraud, theft or financial irregularities;

b. Corruption, bribery or conflict of interest;

c. Failure to comply with legal or regulatory obligations;

d. Misuse or misappropriation of company or client assets;

e. Threats to safety, health or environmental concerns;

f. Deliberate concealment of any of the above.

6. Reporting Channels

Reports may be made through any of the following channels:

a. Directly to the Chief Compliance Officer (CCO);

b. To the Head of Internal Audit;

c. To the Managing Director;

d. Via an anonymous reporting channel established by Certari (e.g. dedicated email or hotline).

When submitting a report, where possible, the whistleblower should include:

A summary of the concern;

a. Relevant details (dates, locations, persons involved);

b. Any supporting information available.

c. Reports may be written, oral, anonymous, or via secure electronic means.

7. Protection and Confidentiality

a. Certari will treat all whistleblower reports as confidential to the maximum extent possible.

b. Identity of the whistleblower will be protected, unless disclosure is required by law or necessary for investigation.

c. Retaliation, harassment or victimization against a whistleblower for raising a concern in good faith is strictly prohibited. Appropriate action will be taken if retaliation occurs.

d. Malicious or knowingly false reports may result in disciplinary action.

8. Investigation Process

a. All reports will be acknowledged promptly (typically within three working days).

b. A designated investigation team, independent from the subject of the report, will conduct the inquiry.

c. Investigations will be carried out objectively, fairly and in accordance with applicable laws and internal procedures.

d. The whistleblower (if identifiable) may be updated on the progress and outcome of the investigation, subject to confidentiality and legal constraints.

9. Actions and Outcomes

Following investigation:

a. If wrongdoing is confirmed, appropriate corrective action will be taken, which may include disciplinary measures, system improvements, reporting to regulators, or legal action as necessary.

b. Findings and recommendations will be communicated to relevant management and, where appropriate, to stakeholders.

10. Roles and Responsibilities

a. Board / Executive Management: Champion the policy, ensure organisational support and adequate resources.

b. Chief Compliance Officer / Head of Internal Audit: Primary custodians of the whistleblowing process, investigate reports, coordinate actions and ensure compliance.

c. Employees and Third Parties: Responsible for reporting concerns in good faith and cooperating with investigations.

11. Data Protection and Privacy

Personal information collected in connection with whistleblowing reports will be processed and stored in compliance with applicable data protection laws and Certari’s privacy standards. Information will only be shared with individuals directly involved in the investigation or where legally required.

12. Policy Review and Updates

This policy will be reviewed periodically (at least every two years) and updated as necessary to reflect regulatory changes, organizational needs or best practices.