Whistleblowing

At BVNK, we are committed to fostering a culture of integrity, transparency, and accountability. To support this commitment, we provide a secure and confidential channel for reporting concerns related to misconduct, regulatory breaches, or unethical behaviour. **What is whistleblowing?** Whistleblowing is the act of reporting suspected wrongdoing or misconduct that could harm the company, its employees, customers, or the wider public. Examples of reportable issues include: - Financial misconduct, fraud, or misrepresentation - Breaches of regulatory obligations, including anti-money laundering (AML) and counter-terrorist financing (CTF) laws - Corruption, bribery, or conflicts of interest - Breaches of internal policies or ethical standards - Workplace misconduct such as harassment, discrimination, or abuse of power - Any other conduct that may pose a risk to public interest, safety, or the environment **Who can report?** Our whistleblowing channel is open to: - Employees, contractors, and suppliers - Business partners and shareholders - Former employees and job applicants - Any individual who has observed or has reasonable grounds to suspect misconduct related to our operations **How to report a concern** We encourage all reports to be made through our dedicated and confidential whistleblowing portal, operated by an independent third party to ensure anonymity and security. Submit a report here: [lighthouse-services.com/BVNK](https://lighthouse-services.com/BVNK) You may also submit your report through the following channels: - Email: reports@lighthouse-services.com (Include “BVNK” in the subject line) - Web portal: [lighthouse-services.com/BVNK](https://lighthouse-services.com/BVNK) (Available 24/7 for online submissions) Anonymous reporting is permitted, and all reports will be handled with strict confidentiality. **What happens after you report?** Once a report is submitted: - You will receive an acknowledgment within 7 days. - The case will be reviewed by an independent compliance team to determine the appropriate follow-up. - If required, an investigation will be conducted, ensuring fairness and impartiality. - Feedback will be provided within 3 months, where legally permissible. - All reports are managed in compliance with Maltese Protection of the Whistleblower Act (Chapter 527), Spanish Law 2/2023, the EU Whistleblowing Directive (2019/1937), and applicable financial regulations. **Protection against retaliation** We strictly prohibit retaliation against whistleblowers. If you believe you have faced retaliation for reporting in good faith, you can raise a complaint through the whistleblowing channel, and appropriate action will be taken.