Whistleblower Policy

1. Introduction

1.1 Digital Matter is committed to the highest standards of integrity, transparency, and accountability. We encourage the prompt reporting of suspected and/or actual misconduct, breaches of law, policy violations, and unethical practices across our operations and value chain. 

1.2 This policy applies globally and is designed to ensure that all persons/entities bound by it can raise concerns in good faith without fear of retaliation, victimisation, or adverse treatment.

2. Purpose of the Policy

2.1 This policy aims to:

• 2.1.1 Provide clear and accessible channels for reporting suspected or actual wrongdoing;
• 2.1.2 Protect whistleblowers from retaliation and maintain confidentiality to the fullest extent permitted by law;
• 2.1.3 Support the effective detection, investigation, and resolution of concerns;
• 2.1.4 Promote a culture of lawful, ethical, and responsible conduct.

3. Scope

• 3.1.1 All employees, directors, officers, contractors, consultants, agents, resellers, distributors, manufacturers, suppliers, and/or any other third parties engaged by Digital Matter.

• 3.1.2.1 bribery, corruption, facilitation payments, or kickbacks;
• 3.1.2.2 fraud, theft, or misappropriation of assets;
• 3.1.2.3 breaches of environmental, social, governance, or corporate compliance standards;
• 3.1.2.4 violations of human rights, labour standards, or workplace safety requirements;
• 3.1.2.5 breaches of applicable laws, regulations, or contractual obligations;
• 3.1.2.6 misuse of confidential information or intellectual property;
• 3.1.2.7 any conduct that could reasonably be expected to harm Digital Matter’s reputation, operations, or stakeholders;
• 3.1.2.8 misrepresentation of products/services;
• 3.1.2.9 data privacy breaches.

4. Reporting Channels

• 4.1.1 Email: legal@digitalmatter.com (confidential handling assured);
• 4.1.2 Directly to the Group General Counsel (anonymity preserved if requested);
• 4.1.3 Any other designated reporting mechanism as communicated from time to time.

5. Protections and Confidentiality

5.1 Retaliation, victimisation, or adverse treatment against a whistleblower is strictly prohibited.

5.2 Digital Matter will take all reasonable steps to protect the identity of the whistleblower, except where disclosure is required by law or necessary to ensure a fair investigation.

5.3 Concerns raised in good faith will be taken seriously, investigated promptly, and handled in accordance with applicable laws and internal procedures.

6. Governance and Investigation

6.1 The Legal Department, in coordination with any appointed compliance officer, will oversee the receipt, assessment, and resolution of all whistleblower reports.

6.2 Where appropriate, independent investigators or external experts may be engaged to ensure impartiality.

6.3 Findings will be documented, and remedial actions implemented as necessary.

7. Consequences of Breach

 7.1 Any retaliation against a whistleblower, obstruction of an investigation, or bad-faith reporting will be treated as a serious violation of this policy and may result in disciplinary action, termination of engagement, legal proceedings, and/or regulatory reporting.

8. Acceptance of Policy

8.1 By engaging with, conducting business for and/or on behalf of, supplying goods and/or services to, and/or otherwise entering into any contractual and/or commercial relationship with Digital Matter, all persons/entities described in clause 3.1.1 are deemed to have read, understood, and accepted the terms of this policy. Such acceptance shall be both express and tacit, and shall bind such a person/entity to comply with this policy unconditionally for the duration of their relationship with Digital Matter, to the extent permitted by applicable
laws.

9. Governing Law and Jurisdiction

9.1 This policy shall be governed by, and construed in accordance with, the laws of Western Australia, without its conflicts of law principles.

9.2 All disputes arising from or in connection with this policy shall submit to the non-exclusive jurisdiction of the courts of Western Australia,
and/or any other court of competent jurisdiction in any territory in which Digital Matter maintains a registered entity, branch, or principal
place of business.

10. Review and Amendments

10.1 This policy shall be reviewed periodically and may be amended at any time to ensure continued compliance with applicable laws, regulations, and best practice standards.

10.2 The most current version of this policy shall be made available on Digital Matter’s official website, or such other publicly accessible location as determined by Digital Matter from time to time. It is the responsibility of all persons/entities bound by this policy to review the then-current version prior to engaging with Digital Matter, as envisaged in clause 3. Any continued or renewed engagement with Digital Matter after the publication of any amendments shall constitute conclusive acceptance of the most recent version of this policy.

11. Precedence

11.1 Insofar as there is any conflict and/or inconsistency between this policy and the Anti-Bribery and Corruption (ABC) Policy and/or the Environmental, Social, and Governance (ESG) Policy, the provisions of this Whistleblower Policy shall prevail, but only to the extent of such conflict or inconsistency.