Booth and Partners Philippines Incorporated
Whistleblower Policy

Objective

This policy sets out the processes and protections for persons who make Protected Disclosures (defined below). The aims of the policy are to:
• Encourage B&P employees to raise suspected Protected Disclosures as soon as possible.
• Provide B&P employees with guidance as to how to disclose their concerns; and
• To reassure B&P employees that they are able to disclose genuine, good faith concerns without fear of retaliation, even if they turn out to be mistaken.

Scope of this Policy

This policy applies to the reporting of Protected Disclosures. A “Protected Disclosure” means a report of conduct that the reporter believes in good faith to improper which includes conduct that may be:
• Dishonest;
• Fraudulent;
• Corrupt;
• Illegal;
• Unethical;
• In breach of internal policy (Including the B&P employee manual);
• Misconduct or an improper state of affair in relation to B&P; or
• A danger, or represents a danger, to the public or financial system.

Generally, personal work-related grievances are not Protected Disclosures under this Policy, however, we encourage you to raise any concerns that you might have.

Disclosing a Concern

The People and Growth department is responsible for ensuring the maintenance, regular review, and updating of this policy. Any queries on the application or interpretation of this policy must be discussed with the People and Growth department before any action being taken. This policy applies to Protected Disclosures made to any of the following:

• An officer of senior manager of B&P or its entities;
• A member of the People and Growth team;
• A member of the external Legal Team;
• A member of the B&P Ethics committee (e.g. CEO, Managing Director, Chief People Officer, Chief Finance Officer, Director of People and Growth)

Nothing is this policy is intended to restrict you from disclosing misconduct, providing information to, or communicating with a government agency, law enforcement body, or regulator in accordance with any relevant law or regulation applicable in a jurisdiction in which B&P operates.

If you would like more information about with whom to speak about a Protected Disclosure, please contact B&P’s Compliance and Ethics Committee (ethics@boothandpartners.com) or a member of the People and Growth team.

C. Sharing/Outsourcing/
Subcontracting

Booth & Partners Philippines Inc. (B&P) will keep the personal information that you provide confidential. However, it may be necessary for
the Company to transfer and disclose your personal information to our affiliates, subsidiaries, or partners in other jurisdictions for
employment consideration purposes.

Confidentiality

We hope that B&P employees feel unrestricted to voice whistleblowing concerns freely under this policy. However, if you want to disclose your concern confidentially, we will make every effort to keep your identity confidential while still complying with our legal obligations. If it is necessary for anyone investigating your concern to know your identity, we will discuss this with you.

While we endeavor to keep your information confidential, in certain circumstances we would have to involve and release information received in a whistleblowing context to those in the Company with the authority to act, including supervisors and other personnel who may be under a duty to report that information to various government agencies, regulators and/or other external bodies.

Process

Colleagues are encouraged to raise issues on an informal basis with their immediate manager with a view to early resolution of any issues or concerns at work. It is hoped that this approach may resolve problems quickly and simply and as part of the everyday approach to working together. However, should this not work, or should a colleague feel that the issue should be dealt with formally, then they should use the formal procedure as detailed below. Every effort should be made to resolve the matter at the lowest level of this procedure. At each stage of the formal procedure, People and Growth and the appropriate manager should invite the colleague to attend a hearing to discuss the issue within five (5) working days of the grievance being raised or as soon as is practically possible. The colleague should be informed of their
right to be accompanied by a fellow Booth and Partner colleague to provide support. Such hearings can be adjourned to enable further investigation or to seek advice. Unless there is a substantial operational need or mutual agreement by the parties concerned, no changes to employment conditions should be made until the procedure has been completed.

Reporting Procedure and Investigation

Upon receipt of a Protected Disclosure, the Ethics & Compliance Team is responsible for ensuring that the matter is investigated appropriately in a timely manner as the circumstances allow. Appropriate corrective action will be taken if warranted by the investigation. While not all Protected Disclosures will necessarily lead to an investigation, they will be assessed and a decision made as to whether they should be investigated. For example, the Ethics & Compliance Team may decide that concerns were investigated previously following a prior report and that a new investigation will not be undertaken.

Due to confidentiality and privilege considerations, B&P generally does not release the specifics of any internal investigation, but you may be able to contact the Chief People Officer or Compliance & Ethics Officer to learn whether an investigation has been closed.

Anonymity

When making a Protected Disclosure, you may do so anonymously through this link. While you are encouraged to share your identity when making a Protected Disclosure, as it will make it easier for B&P to address your disclosure, you are not required to do so. If you do not share your identity, B&P will assess your disclosure in the same way as if you had revealed your identity. However, there may be some practical limitations in conducting the investigation if you do not share your identity.

If an anonymous Protected Disclosure is made through B&P’s Compliance & Ethics email address (ethics@boothandpartners.com), you will receive a unique reference identifier. You can then provide further information or request an update at any time using the unique reference identifier.

Retaliation Prohibited

B&P strictly prohibits all forms of retaliation. “Retaliation” means any actual or threatened conduct that could cause a detriment to you as a result of your good faith reporting of a Protected Disclosure or your cooperation in an investigation of such a report, including adverse employment action, discrimination, harassment, poor work assignments, and/or threats of physical harm.

B&P will take all reasonable steps to protect you from Retaliation and will take action it considers appropriate where such conduct is identified.

False Allegations

When making a Protected Disclosure, you will be expected to have reasonable, good faith grounds to suspect the information you are disclosing is true. You will not be penalized if the information turns out to be incorrect. However, you must not make a report you know is not true or is misleading. Where it is found that you knowingly made a false report, this is a breach of B&P’S Code of Conduct and will be considered a serious matter that may result in disciplinary action. There may also be legal consequences if you make a knowingly false report.