Whistleblowing Policy

This policy is applicable to ZainTECH and all its subsidiaries and business units operating in the countries where the Company has a presence. All employees, contractors, and third-party service providers engaging with the Company’s business operations. All business functions, including but not limited to IT, cybersecurity, finance, human resources, legal, and operations. Each subsidiary must comply with local regulations and laws applicable in its jurisdiction. The Company’s global governance and compliance standards as outlined in this policy.

ZainTECH is committed to maintaining an effective Anti-Corruption Management System (ACMS), supported by a comprehensive Anti-Corruption Policy and Code of Conduct that apply to all employees and business partners, reflecting our zero-tolerance approach to corruption.

This Whistleblowing Policy strengthens ZainTECH ACMS by encouraging employees and business partners report any unethical conducts or policy violations without fear of retaliation.

A “Business Partner” (or “partner”) refers to any external party with whom ZainTECH has, or intends to establish, a business relationship — such as clients, suppliers, contractors, consultants, agents, or investors.

This policy applies to all individuals and entities engaged with ZainTECH, including employees, Individual contractors, and all business partners acting on its behalf.

The policy is communicated through the Communication Plan, with periodic training and awareness sessions conducted in line with the Training Plan to ensure understanding and compliance. These two documents are established and maintained to support the effective implementation and continual improvement of the management system.

This policy references other documents and standards. The applicability of these documents will follow the relevant laws, regulations, and operational practices of each country.

However, in the event that any provision of this Policy conflicts with applicable statutory or regulatory requirements, the local statutory and regulatory requirements shall take precedence.

ZainTECH is committed to maintaining an effective Anti-Corruption Management System (ACMS), supported by a comprehensive Anti-Corruption Policy and Code of Conduct that apply to all employees and business partners, reflecting our zero-tolerance approach to corruption.

• Ensure that ZainTECH adopts an effective mechanism for employees and partners to report any potential or actual violation of ZainTECH Policies, Code of Conduct or any Ethical or Legal violation in general.
• Ensure that all reports are handled promptly, confidentially, and with appropriate follow-up.
• Ensure that ZainTECH give assurance of prohibiting retaliation against individuals who report concerns in good faith, i.e. having reasonable grounds to believe the information disclosed indicates a violation.
• Promote a positive workplace environment based on trust and accountability.
• ZainTECH is committed to upholding transparency and accountability. Whistleblowers acting in good faith are protected from any form of retaliation.

ZainTECH provides multiple secure and confidential channels for reporting concerns. All reports are treated with the utmost confidentiality and are investigated impartially.

• Anonymous online reporting portal accessible to all employees and business partners.
• Dedicated whistleblowing email address monitored by the Compliance team.
• Direct communication with the Chief Compliance Officer or the Board Audit Committee.
• Confidential hotline available 24/7 for all ZainTECH subsidiaries and operating regions.

Reports may be submitted anonymously. However, providing contact information, where safe to do so, may assist in the investigation. The identity of the reporter will be kept strictly confidential unless disclosure is required by law.

ZainTECH strictly prohibits any form of retaliation against individuals who report concerns in good faith. Retaliation includes but is not limited to:

• Demotion, suspension, or termination of employment.
• Harassment, intimidation, or threats of any kind.
• Denial of promotion, training, or other employment benefits.
• Any other adverse action that would discourage reporting.

Any employee or business partner found to have engaged in retaliatory conduct will be subject to disciplinary action, up to and including termination of the business relationship or employment.

All reports received through the whistleblowing channels will be subject to a formal and impartial investigation process conducted in accordance with ZainTECH’s internal investigation procedures and applicable laws.

• All reports will be acknowledged within five (5) working days of receipt.
• A designated investigator or investigation team will be appointed for each case.
• Investigations will be completed within a reasonable timeframe, typically within 60 days, unless complexity requires an extension.
• Reporters will be updated on the status of their report where legally permissible and appropriate.
• Investigation findings and recommended actions will be reported to senior management and the Board where required.

Whistleblowing protections apply only to reports made in good faith. ZainTECH takes a firm stance against misuse of this policy. Any individual who knowingly makes a false or malicious report with the intent to harm another individual or cause disruption may be subject to disciplinary action or legal proceedings.

This provision does not apply to individuals who, in good faith, report concerns that are ultimately unsubstantiated following investigation. Good faith is defined as having reasonable grounds to believe the information disclosed indicates a violation, regardless of the outcome.

This policy is owned by the ZainTECH Chief Compliance Officer and is reviewed annually or as required following significant regulatory changes, material incidents, or changes in business structure. Any amendments to this policy must be approved by the Board Audit Committee.

All employees and business partners are required to acknowledge receipt and understanding of this policy upon onboarding and following any significant update. Training on this policy is provided as part of ZainTECH’s annual compliance training programme.