Whistleblower Protection Policy

The purpose of this Whistleblower Policy (the "Policy") is to ensure that any current or former employee of Coresignal or any individual who has or had a contractual relationship with Core signal ("the Company") can raise concerns regarding illegal, unethical, or improper conduct without fear of retaliation. The Company requires that both it s operations and the actions of it s employees adhere to all relevant laws, regulations, and internal policies. This Policy encourages the reporting of suspected violations and provides protections to those who do so in good faith.

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Reportable conduct

A whistleblower is any person who reports activities they believe to be illegal or unethical. The following are examples of actions that should be reported under this Policy:

  • Violations of regulations.
  • Unethical business conduct, including conflicts of interest.
  • Fraudulent financial reporting.
  • Misuse of Company assets or resources.
  • Health and safety violations.
  • Discriminations or harassment.
  • Environmental law violations.

This list is not exhaustive. Any suspected illegal, unethical, or improper activity that thretens the integrity of the Company or its operations may be reported.

Reporting procedure

To submit a confidential whistleblower report, a person should use the "Whistleblower Hotline" channel, accessible via the Company's website coresignal.com/whistleblower-hotline, or send a notice to [email protected].The report can be in any format, as the Company does not provide a specific template. However, the Company requests that persons include the following details in their report:

  • Who is involved in the breach, when it occurred, and the nature of the breach.
  • The date and circumstances of discovering the breach.
  • Any relevant documents, data, or information related to the potential breach.
  • The whistleblower's name, surname, personal identification number, and other contact information (e.g., phone number, personal email addr ss) are optional, but if not provided, the whistleblower will not receive a response regarding the outcome of the investigation.

Investigation process

  1. Upon receiving a whistleblower report, the Competent body will acknowledge receipt of the report within 3 business days. The whistleblower will be notified that the report has been received and is under review.
  2. The Competent body will conduct an initial review of the report to assess the nature of the alleged misconduct and determine if there is sufficient basis for a full investigation. After the initial evaluation is completed, the whistleblower will be informed of the results no later than 5 business days from the receipt of the report:
    1. If the report has merit and will proceed to a full investigation
    2. If the report is determined to be unfounded or lacks sufficient evidence to proceed further.
  3. If the initial evaluation indicates that further inquiry is necessary, a full investigation will be initiated. The Competent body will form an investigation team that may include legal counsel, HR representatives, and other relevant personnel depending on the nature of the case. The investigation team will gather all relevant facts, which may include interviews with the whistleblower and individuals named in the report, collection and review of document s, emails, consultation with experts. The investigation must be completed within 30 business days from the date of the initial evaluation. In cases where the complexity of the matter requires additional time, the Competent body may extend the investigation period. The whistleblower will be informed of the investigation's outcome and any actions taken.
  4. In cases where the report lacks evidence, the whistleblower will be informed of the insufficiency and given an opportunity to submit additional information or documentation to support their claim. If further evidence is provided, the Competent body will re-evaluate the report and determine whether it meets the threshold for investigation.

Corrective action

If the investigation confirms the reported conduct, the Company will take swift and appropriate corrective actions, which may involve:

  • Disciplinary actions against those responsible.
  • Revisions to policies or additional training.
  • Reporting to regulatory authorities, if necessary.
  • Other measure to prevent future violations.

Confidentiality

Reports will be handled with confidentiality as much as possible, in line with the requirements for conducting a thorough investigation. All reasonable efforts will be made to keep the whistleblower's identity confidential, except where disclosure is legally mandated.

No retaliation

The Company has a strict policy against retaliation toward anyone who, in good faith, reports suspected illegal, unethical, or improper behavior, or who takes part in any investigation related to such behavior. Retaliation encompasses, but is not limited to:

  • Termination or demotion.
  • Decrease in pay or benefits.
  • Harassment or discrimination.
  • Any other negative action

Acting in good faith

Anyone submitting a report under this Policy must do so in good faith and have reasonable grounds to believe that the information provided suggests a violation. False allegations made with malicious intent may result in disciplinary measures, civil, administrative, or criminal liability, depending on the nature and severity of the violation.

Legal protections

This Policy aims to align with all relevant whistleblower protection laws, including the Delaware Whistleblower Protection Act (DWPA). Persons are protected from retaliation for reporting in good faith and are entitled to seek remedies if they experience retaliation for their reports of misconduct.

Amendments

The Company retains the right to modify this Policy at any time.