WHISTLEBLOWING POLICY

The Wingu Group is committed to conducting business with honesty and integrity and expects all directors, officers, employees, consultants, agents, contractors, customers and vendors of the company (together referred to as “Business Partners”) to maintain high standards in accordance with Wingu’s policies and procedures.

A culture of openness and accountability is essential to prevent such situations occurring, or to address them when they do occur. This policy is designed to enable individuals to use internal mechanisms for reporting concerns they may have regarding wrongdoing or illegal acts of omission by people who may work for Wingu so that they are reported internally and at a high level.

Wingu encourages people to feel confident in raising concerns and provides, through this policy, a mechanism for reporting them and reassurance that if concerns are raised in good faith, they will be protected from possible reprisal or victimisation. An internal Business Partner should raise a concern it they believe any of the specified acts have occurred, is occurring or is likely to occur.

The aims of this policy are:

• To encourage individuals to report suspected wrongdoing, as soon as possible, with the knowledge that their concerns will be taken seriously and investigated, as appropriate, and that their confidentiality will be respected.
• To provide individuals with guidance as to how to raise those concerns.
• To reassure individuals that they may raise genuine concerns without fear of reprisal, even if they turn out to be mistaken.

What is whistleblowing?

Whistleblowing is the disclosure of information which relates to suspected wrongdoing (generally a breach of legal, statutory, or regulatory requirements, or unethical, immoral behaviour). This policy is intended to provide mechanisms for formal reporting and protection for Business Partners who raise legitimate concerns about matters that are deemed to be in the public interest. These are called “qualifying disclosures”.

A qualifying disclosure is one made by an individual who has a reasonable belief that the following has taken place:

• A criminal offence (e.g. fraud, bribery, corruption or theft).
• A miscarriage of justice.
• An act creating risk to health and safety.
• An act causing damage to the environment.
• A breach of any legal obligation.
• Concealment of any of the above.

Reporting/Monitoring

All whistleblowing concerns and other complaints will be investigated as detailed above. Where incidents have occurred, the ESG Officer will provide the board with a written report and provide the board with a balanced understanding of:

• Any whistleblowing reports or complaints during the year and what was done about them.
• How Wingu met its obligations.
• The operation and effectiveness of the systems and controls that are in place to meet those obligations and how they reduce the anti-money laundering and anti-bribery/corruption risks to which Wingu is exposed and how they could be improved.
• Whistleblowing investigations that were notified to local law enforcement authorities, where appropriate.

Key Principles

Business Partners should be aware of the importance of preventing and eliminating wrongdoing at work. Individuals should be watchful for illegal or unethical conduct and report anything of that nature that they become aware of. Any matter raised appropriately under this procedure will be investigated thoroughly, promptly and confidentially. No Business Partner will be victimised for raising a matter under this procedure. However, maliciously making a false allegation would be considered a disciplinary matter. Failure to notify internally before raising externally to a non-regulatory or supervisory body e.g. the media, would be regarded as misconduct.

The following procedure should be used for reporting a concern:

• Step one: If an individual has a concern about malpractice or wrongdoing covered by this policy it should first be reported to their line manager, if appropriate. If the individual feels unable to raise the matter with their manager, they should raise their concern with the relevant business unit leader, or the ESG Officer.
• Step Two: If the individual considers that their concerns have not been satisfactorily dealt with, or that they cannot discuss the matter with one of the above persons, they should raise the issue in writing with the most senior executive, unless the whistleblowing implicates them in which case it would be the board.

Following an initial assessment of the concern raised, the whistleblower will receive an acknowledgement and may be asked to provide further information as part of any investigation that is undertaken.

Complaints

A complaint is an expression of dissatisfaction, made either verbally or in writing, about the standard of service, actions or lack of action by Wingu or its employees. Wingu’s policy is:

• To provide a fair complaints procedure that is clear and easy to use for anyone wishing to make a complaint.
• To make sure all legitimate complaints are investigated fairly and in a timely manner.
• To make sure that complaints are, wherever possible, resolved and that relationships are repaired.

Reporting of Complaints

Complaints are better raised in writing. The background and history of the complaint, giving names, dates and places where possible should be set out. Complaints in writing may be emailed to complaints@wingu.africa.

Complainants may also go directly to the external body governing the jurisdiction in which the complaint is being reported.

Should the matter warrant further investigation, Wingu will write to the complainant to acknowledge that the concern has been received and that the matter will be dealt with appropriately. If possible, an indication will be given of how Wingu proposes to deal with the matter and whether any initial enquiries have been made and an estimate of how long it will take to provide a final response. Should the complainant not be satisfied with the response and wish to take the complaint further, they may contact the appropriate regulator in the relevant jurisdiction.