Whistle Blower Policy

1. Purpose

AES is committed to conducting its business with honesty, integrity, and in compliance with all
applicable laws and regulations. This Whistleblower Policy and Procedure is designed to provide a
mechanism for employees, contractors, and other stakeholders ("whistleblowers") to report concerns
about suspected unethical behaviour, illegal activities, or violations of company policies without fear
of retaliation.

2. Scope

This policy applies to all employees, contractors, vendors, customers, and other stakeholders of AES.

3. Definition of a Whistleblower

A whistleblower is any individual who, in good faith, reports concerns about wrongdoing, suspected
unethical behaviour, illegal activities, or violations of company policies.
Such a person can resort to raising ‘the issue’ through formal channels or anonymously. In either case,
he/she is entitled to protection under the Whistleblower Protection Act 2015.

4. Reporting Procedure

This policy applies to all employees, contractors, vendors, customers, and other stakeholders of AES.
a. Internal Reporting: Whistleblowers are encouraged to report their concerns internally to
Country Manager or HR Department, who will handle the matter with confidentiality and
discretion.
b. Anonymous Reporting: AES recognizes that some whistleblowers may wish to report
concerns anonymously. Anonymous reports can be submitted via email on
whistleblower@aletehadsecurity.com. Every effort will be made to maintain the anonymity
of the whistleblower, although complete confidentiality cannot be guaranteed.

5. Reporting Categories

Concerns that may be reported under this policy include, but are not limited to:

• Fraud
• Theft
• Bribery or corruption
• Discrimination or harassment
• Violations of safety regulations
• Environmental violations
• Conflicts of interest
• Falsification of records
• Retaliation against whistleblowers

6. Protection from Retaliation

AES prohibits retaliation against whistleblowers who report concerns in good faith under this policy.
Retaliation includes, but is not limited to, termination, demotion, harassment, or any adverse action
taken against the whistleblower. Any individual found to have engaged in retaliation will be subject
to disciplinary action, up to and including termination of employment or contractual relationship.

7. Investigation and Resolution

a. Upon receipt of a report, AES will promptly investigate the matter in a fair and impartial
manner. The investigation may involve gathering information from relevant parties, reviewing
documents, and conducting interviews.

b. Whistleblowers will be provided with updates on the status of the investigation to the extent
possible without compromising its integrity.

c. Upon completion of the investigation, AES will take appropriate corrective action if
wrongdoing is substantiated. This may include disciplinary action against individuals involved,
implementation of new policies or procedures, restitution, or referral to law enforcement
authorities.

d. The Whistleblower is not responsible for investigating the alleged illegal or dishonest activity,
or for determining fault or corrective measures; appropriate management officials are
charged with these responsibilities.

e. Any concerns involving the Management Team should be reported to the GM.

8. Non-Retaliation and Confidentiality Obligations

a. All employees and stakeholders are obligated to cooperate fully with investigations
conducted under this policy. Failure to cooperate may result in disciplinary action.

b. All information received will be treated confidential until the completion of an investigation.
The findings and corrective action will then be communicated to all stakeholders. However,
the anonymity (details of the whistleblower) will be kept strictly confidential. In no
circumstance will the identity of the whistleblower be divulged.

9. Policy Review and Communication

This Whistleblower Policy and Procedure will be communicated to all employees, contractors, and
stakeholders upon implementation and periodically thereafter. Updates or revisions to the policy will
be communicated promptly to ensure awareness and understanding.

10. Contact Information

Whistle Blower Policy
Whistle Blower Policy
HR-POL-AES-007-Whistleblower Policy-v01
03 March 2024
Confidential
Any queries arising from this policy or its implementation can be taken up directly with the HR
Department at whistleblower@aletehadsecurity.com and/or compliance@aletehadsecurity.com