Whistleblower Policy

Purpose and Scope

Kaelo Global is committed to conducting business with integrity, transparency, and in compliance with all applicable laws and regulations. This Whistleblower Policy (the "Policy") establishes the framework through which employees, contractors, suppliers, clients, and any other stakeholders can report concerns about actual or suspected misconduct, malpractice, illegal activity, or unethical behaviour within Kaelo Global or its supply chain, without fear of retaliation or adverse consequences.

This Policy applies to all directors, officers, employees, contractors, consultants, secondees, and interns of Kaelo Global and its affiliated entities across all jurisdictions in which the firm operates — including the Dubai, Singapore, and Seychelles. The Policy also applies to any third party who wishes to report a concern relating to Kaelo Global's operations, including suppliers, clients, business partners, and members of the public.

Concerns that may be reported under this Policy include, but are not limited to: fraud, theft, or financial irregularity; bribery or corruption; money laundering or terrorist financing; breach of regulatory requirements or licence conditions; market abuse or insider dealing; failure to comply with legal obligations; health and safety violations; environmental damage; modern slavery or labour exploitation; discrimination, harassment, or bullying; conflicts of interest; data protection breaches; and any deliberate concealment of any of the foregoing.

Reporting Channels

Kaelo Global provides multiple channels through which concerns can be reported. Reporters may select the channel that they consider most appropriate in the circumstances:

Direct Reporting. Employees are encouraged, where they feel comfortable doing so, to raise concerns directly with their line manager or department head. If the concern relates to the employee's line manager, or if the employee is not comfortable reporting to their line manager, the concern may be raised with any member of senior management or the Head of Compliance.

Compliance Function. Concerns may be reported directly to the Compliance function via email at compliance@kaeloglobal.com. The Compliance function is independent of operational management and reports directly to the Board. All reports received through this channel are logged, acknowledged, and handled in accordance with the investigation procedures set out below.

Confidential Hotline. An independent, confidential reporting hotline is available to all stakeholders. Reports can be made via telephone or secure online portal. The hotline is operated by an independent third party and is available 24 hours a day, seven days a week. Reports may be made anonymously — the third-party operator does not have the ability to identify reporters who choose not to provide their identity.

Board-Level Reporting. Where a concern relates to a member of senior management or the Compliance function itself, the concern may be reported directly to the Chair of the Board or a non-executive director. Contact details for Board-level reporting are maintained in the firm's internal policy manual and are available to all employees.

Protection Guarantees

Kaelo Global is committed to protecting any person who makes a good-faith report under this Policy from retaliation, victimisation, or adverse treatment of any kind. "Retaliation" includes, but is not limited to: dismissal, demotion, or suspension; harassment, intimidation, or bullying; discrimination in relation to terms and conditions of employment; threats or other forms of coercion; damage to professional reputation; and exclusion from projects, opportunities, or decision-making processes.

Any person who is found to have retaliated against a whistleblower will be subject to disciplinary action up to and including termination of employment or contract. This protection applies regardless of whether the reported concern is ultimately substantiated by investigation — the protection attaches to the act of reporting in good faith, not to the outcome of the investigation. However, this Policy does not protect individuals who make reports that they know to be false or who make reports with malicious intent. Knowingly false or malicious reports may themselves be subject to disciplinary action.

Investigation Process

All reports received under this Policy are taken seriously and are handled promptly, impartially, and proportionately. The investigation process follows a defined procedure: (a) Acknowledgement — the reporter receives confirmation that their report has been received within five business days, together with information about next steps and expected timelines; (b) Initial Assessment — the Compliance function conducts a preliminary assessment to determine whether the report falls within the scope of this Policy and whether there is sufficient information to warrant a formal investigation; (c) Investigation — if a formal investigation is warranted, an investigation lead is appointed who is independent of the subject matter of the concern. The investigation may involve document review, interviews with relevant individuals, expert analysis, and engagement of external advisers where necessary.

(d) Findings — the investigation lead produces a written report of findings, conclusions, and recommended actions; (e) Remediation — where the investigation substantiates the reported concern, appropriate remedial action is taken, which may include disciplinary measures, process improvements, regulatory notifications, or referral to law enforcement authorities; (f) Feedback — the reporter is informed of the outcome of the investigation to the extent that it is legally permissible and does not compromise the investigation or the rights of other parties involved. Where the report was made anonymously, feedback will be provided through the same anonymous channel where possible.

Confidentiality

All reports are treated with the strictest confidentiality. The identity of the reporter will not be disclosed without their consent, except where disclosure is required by law, regulatory obligation, or legal proceedings. Information relating to reports and investigations is shared only with those individuals who need to be involved in order to properly assess and investigate the concern. All persons involved in an investigation — including the reporter, the subject of the concern, and any witnesses — are required to maintain confidentiality regarding the existence and content of the investigation. Breach of this confidentiality obligation may result in disciplinary action.

Non-Retaliation Commitment

Kaelo Global's non-retaliation commitment is unconditional. We will take all reasonable steps to ensure that any person who reports a concern in good faith under this Policy does not suffer any detriment as a consequence of making the report. This commitment extends beyond the period of investigation — we monitor the circumstances of reporters for a reasonable period following the conclusion of an investigation to ensure that no delayed or indirect retaliation occurs.

Where a reporter believes that they have suffered retaliation as a result of making a report, they should report this concern immediately through any of the reporting channels described above. Allegations of retaliation are treated with the same urgency and rigour as the original report and are investigated independently. In addition to our internal protections, reporters may have statutory protections under the laws of the jurisdiction in which they are based, including the UK Public Interest Disclosure Act 1998, the DIFC Employment Law, and the Singapore Employment Act.

Governance and Review

This Policy is owned by the Compliance function and is reviewed annually by the Board. The Compliance function provides the Board with regular reports on the number of reports received, the nature of concerns raised, the outcomes of investigations, and any systemic issues or trends identified. The Board uses this information to assess the effectiveness of the Policy, to identify areas where additional controls or training may be required, and to ensure that the firm's culture supports open and honest reporting without fear of adverse consequences. This Policy was last reviewed and approved by the Board on 1 January 2025.