Whistleblowing Procedure

Milexia is committed to the highest standards of transparency, honesty, integrity, fairness and accountability. These principles are within our culture where ethical behaviour is promoted, and wrongdoing is safely reported and investigated.

Milexia’s whistleblower policy encourages and protects employees, former employees, and other parties with whom it has a business relationship who speak up and bring forward any allegations of illegal and improper conduct. It includes the necessary information to make serious allegations in a way that will ensure confidentiality and protection.

Scope

This Policy applies to all employees (current, former and candidates), consultants, contractors, agents or any other person(s) associated with us, including third parties, subsidiaries or their employees.

Third parties, in the context of this policy, refers to any individual or organisation our Company meets and works with. It includes actual and potential customers, suppliers, distributors, business contacts, representatives and public parties.

The procedure applies to, but is not limited to, allegations about:

• Bribery and any form of corruption
• Failure to comply with a legal obligation
• Breaches of public health and safety regulation
• Improper conduct or unethical behaviour
• Breaches of product safety regulations
• Environmental damage
• Financial malpractice, impropriety or fraud
• Criminal activity
• Attempts to conceal any of the above

Outside the scope

This procedure does not replace any other policy or procedure. Reports of personal grievances, such as harassment or bullying, are not generally covered by the whistleblower policy. If an employee a concern about the conduct of a colleague in the working environment, they should raise this with their manager or HR manager in the first instance.

Confidentiality

All allegations will be treated in confidence and every effort will be made not to reveal a whistleblower’s identity unless the whistleblower otherwise requests. However, if the matter is subsequently dealt through another procedure or court proceedings, then the whistleblower may have to give evidence.

Milexia will not, without the whistleblower’s consent, disclose their identity to anyone other than a person involved in the corresponding investigation, within the limits defined by applicable laws and regulations.

Anonymous Allegations

Whistleblowers are encouraged to put their name to an allegation wherever possible as an anonymous allegations are often difficult to substantiate or prove. Allegations made anonymously are much less powerful, but they will be considered, taking into account:

• The seriousness of the issue raised
• The credibility of the allegation
• Whether it can realistically be investigated from factors or sources other than the complainant

Untrue Allegations

Allegations include ‘proven’ breaches, malpractices, and reasonable suspicions thereof within the scope of this policy. No action, disciplinary or other, will be taken against a whistleblower who makes an allegation in the reasonable belief that the information provided is true and it is in the public interest to do so, even if the allegation is not substantiated by an investigation. However, disciplinary action may be taken against a whistleblower who makes an allegation without reasonable belief that it is in the public interest, for example making an allegation maliciously or for personal gain where there is no element of public interest.

Procedure

Allegations should preferably be made to your line manager in the first instance. However, this may depend on the seriousness and sensitivity of the issue(s) involved and who is suspected of the wrongdoing. The whistleblower may then make an allegation to the following manager or the Compliance Manager by emailing compliance@milexia.com.

Anonymous allegation can be made through the anonymous site https://anonymousemail.me emailing compliance@milexia.com with as much information as possible. No personal data will be attached to this email.

Once an allegation has been received, it will be discussed by the compliance team. After careful consideration, it will be discussed with the whistleblower and, if they wish to proceed with the allegation, then it will be investigated. If the allegation is anonymous, the compliance team will determine if an investigation should take place.

Allegation

Whether a written, oral or anonymous report is made it is important that all relevant information is provided. This includes:

• The background and history of the allegation, including relevant dates, names and positions of those who may be able to contribute to the allegation or investigation.
• The specific reason for the allegation. Although someone making an allegation will not be expected to prove the truth of any allegations, they do need to provide information to establish that there are reasonable grounds for the allegation.
• The name of the person making the allegation and a contact point if it is not anonymous.

Investigation and Actions

Once a concern has been raised, if there are reasonable grounds, it will be investigated. If you have not made the allegation anonymously, you will be asked to attend a meeting as part of this investigation and you’ll be informed of its progress as far as it is possible and appropriate, bearing in mind any confidential obligations that apply. Please note that you will not be given details of any disciplinary action taken unless we consider this appropriate.

If the allegation discloses evidence of a criminal offence a decision will be made as to whether to inform the police or regulatory body.

Timetable

An acknowledgement receipt of the allegation will be made within seven days.

• Diligent and impartial follow-up, communication, and feedback will be made within three months of the report’s submission. This will include, but it’s not limited to:
• An indication of whether any initial enquiries have been made
• Allowing the whistleblower to review and edit the report and interview notes
• An indication of how Milexia proposes to deal with the matter
• An estimate of how long it will take to provide a final response
• An indication whether further investigations will take place or if not. If not, then an explanation as to why not.

This does not apply to anonymous allegations as no communication can take place.

Dissatisfaction with the outcome of the process

If you are dissatisfied with the outcome of the investigation, you can raise the reasons for your dissatisfaction to the manager you submitted the allegation to or the persons responsible for the investigation. They must respond in writing, notifying the acceptance or rejection for further investigation and the reasons for this decision.

Breach of this Policy

Milexia reserves the right to take disciplinary measures if anyone is found to have subjected a whistleblower to any form of detrimental treatment. Also, if the reporter has intentionally misled us in respect of any matter, breached this policy in any other way and/or if we believe that you have made a false allegation maliciously.

This policy is intended to ensure that we comply with our duties under the Directive 2019/1937 of the European Parliament on the protection of persons who report breaches of Union law and UK Public Interest Disclosure Act 1998, which “protects workers from detrimental treatment or victimisation from their employer if, in the public interest, they blow the whistle on wrongdoing”.

All personal data, both that of the whistleblower and any accused persons, will be handled in accordance with MILEXIA’s Privacy Policy.

Maria Gonzalez Müller, Chief Compliance Officer

Updated: September 2022