Purpose

This Whistleblowing Policy ensures that all individuals associated with Teroxx Worldwide UAB can report concerns about possible breaches of law or company policies in a safe and secure manner, without the fear of retaliation.

Who can Report?

This policy applies to:

• Employees (current and former).
• Business Partners.
• Contractors, consultants, and other associated parties.

What Can Be Reported?

You can report:

1. Legal Violations: Breaches of laws or regulations.
2. Corruption: Fraud, bribery, embezzlement, or misuse of resources.
3. Harassment or Discrimination: Including psychological or gender-based violence.
4. Policy Violations: Breaches of internal policies, unethical behaviour, or misuse of company resources.
5. Safety Concerns: Data protection, environmental harm, or workplace safety issues.
6. any other acts that might be in breach of applicable laws or the Company policies

How to Report?

You can report concerns through the following channels:

1. Internal Reporting:
   • Mail: Send to Vilniaus St. 31, LT-01402 Vilnius, Lithuania, marked “To the Head of Compliance and Risk”
   • Online Portal: https://whistleblower-portal.teroxx.eu/
   • Email: report@teroxx.eu
2. External Reporting:
   • Report directly to the Bank of Lithuania or other competent authorities. Guidance is available here: https://www.lb.lt/en/forms/reporting-of-breaches-of-legal-acts-regulating-the-financial-market#ex-1-7

Your Rights as a Whistleblower

1. Confidentiality: Your identity will be protected unless disclosure is required by law.
2. Protection Against Retaliation: No adverse actions (e.g., dismissal, demotion, harassment) will be taken against you for reporting in good faith.
3. Anonymous Reporting: You can report anonymously, and your concerns will be treated with the same seriousness.
4. Right to Know the Outcome: You may be informed of the investigation’s outcome, subject to legal and confidentiality restrictions.

How We Handle Reports

1. Acknowledgment: We will confirm receipt of your report within 5 business days (unless anonymous).
2. Preliminary Assessment: We will review your report within 14 business days to determine if it falls under this policy or if the information is sufficient.
3. Investigation: A full investigation will be conducted within 30 business days from submission. If delays occur, you will be informed.
4. Outcome: Findings and actions will be documented, and if possible, you may be informed of the results.

False or Malicious Allegations

While we encourage reporting genuine concerns, false or malicious allegations may result in disciplinary action.

Training and Awareness

• Annual training sessions will be conducted to all staff to promote awareness of this policy.
• Updates to the policy will be shared to reflect regulatory or organizational changes.

Record Keeping

• All whistleblowing reports and related documentation will be securely stored for 5 years.
• Records will remain confidential and accessible only to authorized personnel.

This policy reflects the commitment of Teroxx Worldwide UAB to integrity, transparency, and accountability. For more details, please contact the Compliance Department